Who Breached the APA, and When?

“In SCO’s Response to Novell’s motion for an order Directing SCO
to pay them all future royalties upon receipt, SCO made this
remarkable statement:

“Nowhere in the Motion does Novell state (because it cannot)
that the Debtors (or their predecessors in interest) have ever
failed to remit the required royalty payments in a timely fashion
in the 12 years since the APA was executed.

“I beg to differ. Allow me to fill in some blanks…”