From the last 10-K

Revenue Recognition:

Patent Licensing

We apply the guidance of SEC Staff Accounting Bulletin Topic 13.A.3(f), Nonrefundable Up-Front Fees , to our patent license and settlement agreements using the specific performance method analogous to the sale of an asset in such literature as Financial Accounting Standards Board (“FASB”) Statement of Financial Accounting Standards (“SFAS”) No. 13, Accounting for Leases and AICPA Statement of Position 00-2, Accounting by Producers and Distributors of Films . nsed Accordingly, we recognize revenue from patent license agreements when (i) the patent license agreement is executed, (ii) the amounts due are fixed, determinable, and billable, (iii) the customer has been provided rights to the licensed technology and (iv) collection of the resulting receivable, if any, is probable. At the time we enter into a contract and provide the customer with the licensed technology we have performed all of our obligations under contract, the rights to our technology have been transferred and no significant performance obligations remain. License revenue to date consists of one-time license and settlement agreements requiring no future performance. We have no licenses that do not include settlement and covenants not to sue.

From the 10Q:

In September 2008 we recorded our first patent license revenue and by September 30, 2009 we had licensed and settled the litigation with seven of the defendants and suspended the complaint against one defendant currently in bankruptcy.