Remedy sought (retyped from the complaint filing):

Red Hat respectfully requests:

A. A permanent injunction restraining SCO and its officers, directors, partners, agents, servants, employees, and attorneys, and those personas in active concert or participation with SCO from representing by any means whatsoever, directly or indirectly, or doing any other act or things calculated or likely to cause confusion, mistake, or to deceive purchasers, business partners, and/or investors into believing that Red Hat's LINUX products and/or the LINUX products used by Red Hat's customers and partners violates any of SCO's intellectual property or trade secret rights;

B. Under Count I, a Declaratory Judgement pursuant to 28 U.S.C. sect. 2201 et seq. that Red Hat's and its customers' actions in providing, creating, maintaining, debugging, developing, copying, selling, transferring, installing, operating, or otherwise using any of Red Hat's LINUX products and services doe not violate any SCO rights under Section 106 of the Copyright Act, 17 U.S.C. sect. 101 et seq., and a Declarative Judgement that any SCO copyright claimed to be infringed by Red Hat or its customers in conjunction with any of Red Hat's products is unenforceable;

C. Under Count II, a Decaratory Judgement pursuant to 28 U.S.C. sect. 2201 et seq. that Red Hat's and its customers' actions in providing, creating, maintaining, debugging, developing, copying, selling, transferring, installing, operating, or otherwise using any of Red Hat's LINUX products and services doe not constitute a misappropriation of a SCO trade secret, a Declaratory Judgement that the Linux kernel and operating system are public and therefore cannot constitute a trade secret, and a Declaratory Judgement that any SCO trade secret claimed to be misappropriated by Red Hat or its customers in conjuction with any of Red Hat's product is unenforceable;

D. Under Count III-VII, an award of actual damages to Red Hat by reason of SCO's actions in an amount to be established at trial;

E. An other that Red Hat's actual damages be trebled pursuant to the Delaware Deceptive Trade Practices Act;

J. An award of Red Hat's attorney's fees and costs incurred in connection with this matter pursuant to the Delaware Deceptive Trade Practices Act; and

K. Such further relief as the Court may deem just and proper.

Red Hat requests a trial by jury on all issues so triable.

RED HAT, INC.
By its attorneys,
[signed]
Josy W. Ingersoll (#1088)
Adam W. Poff (#3990)
YOUNG CONAWAY STARGATT & TAYLOR, LLP
The Brandywine Building
1000 West Street
P.O. Box 391
Wilmington DE 19899-0391
Telephone: (302) 571-6672


[RM notes: Omission of points F-I in the requested remedies was present in the original.]