A sample memorandum of law supporting a Daubert motion and motions in limine to exclude testimony by a patent owner's damages expert and related evidence. This Standard Document addresses common challenges to patent owner damages experts when the expert uses non-comparable license agreements, fails to apportion, uses total sales and revenues of the accused product, refers to the accused infringer's size, wealth, and financial condition, or offers unsupported and unreliable opinions. It also contains integrated drafting notes with important explanations and drafting tips.