A great deal more will follow. Some of the exhibits are documents we have already, so we won't redo those, but as you will see, there are some new goodies. Thanks go to Henrik Grouleff for transcribing for us.

********************************

SNELL & WILMER LLP
Alan L. Sullivan (3152)
Todd M. Shaughnessy (6651)
Amy F. Sorenson (8947)
[address, phone, fax]

CRAVATH, SWAINE & MOORE LLP
Evan R. Chesler (admitted pro hac vice)
David R. Marriott (7572)
[address, phone, fax]

Attorneys for Defendant/Counterclaim-Plaintiff
International Business Machines Corporation

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH

THE SCO GROUP, INC.,

Plaintiff/Counterclaim-Defendant,

v.

INTERNATIONAL BUSINESS
MACHINES CORPORATION,

Defendant/Counterclaim-Plaintiff.

DECLARATION OF AMY F. SORENSON

Civil No. 2:03CV-0294 DAK

Honorable Dale A. Kimball

Magistrate Judge Brooke C. Wells

---------------------------------------

I, Amy F. Sorenson, declare as follows:

1. I represent IBM in the lawsuit brought by SCO against IBM, titled The SCO Group, Inc. v. International Business Machines Corporation, Civil No. 2:03CV-0294 DAK (D. Utah 2003). This declaration is submitted in support of Defendant/Counterclaim-Plaintiff IBM's Memorandum in Opposition to SCO's Motion to Dismiss or Stay Count Ten of IBM's Second Amended Counterclaims.

2. Attached hereto are true and correct copies of the following documents:

(a) Exhibit 1 is SCO's Opening Brief in Support of its Motion to Dismiss in Red Hat, Inc. v. The SCO Group, Inc., Civ. No. 03-772, (D. Del.), dated September 15, 2003.

(b) Exhibit 2 is the Memorandum Order issued by Judge Sue L. Robinson in the Red Hat case on April 6, 2004.

(c) Exhibit 3 is SCO's Opposition to Red Hat's Motion for Reconsideration in Red Hat, dated May 4, 2003.

(d) Exhibit 4 is a letter from D. McBride to L. Noto, dated May 12, 2003.

(e) Exhibit 5 is "Event Transcript: SCO Group (SCOX) Conference Call", dated July 21, 2003.

(f) Exhibit 6 is a transcript of the December 5, 2003 hearing before Magistrate Judge Wells.

(g) Exhibit 7 is a form letter from R. Tibbitts to "Linux User", dated December 19, 2003.

(h) Exhibit 8 is AutoZone, Inc.'s Motion to Stay or, in the Alternative, For a More Definite Statement, filed April 23, 2004 in The SCO Group, Inc. v. AutoZone, Inc., Case No. CV-S-04-0237 (D. Nev.).

3. I declare under penalty of perjury that the foregoing is true and correct.

Executed: May 18th, 2004

Salt Lake City, Utah

______[signature]_______

Amy F. Sorenson

CERTIFICATE OF SERVICE

I hereby certify that on the 18th day of May, 2004, a true and correct copy of the foregoing was sent by U.S. Mail, postage prepaid, to the following:

Brent O. Hatch
Mark F. James
HATCH, JAMES & DODGE, P.C.
[address]

Stephen N. Zack
Mark J. Heise
BOIES, SCHILLER & FLEXNER LLP [address]

Kevin P. McBride
[address]