• Cross-licences; • Agreements as to territories for sale; • Trade-offs between competing IP rights; • Negotiated royalty rates; • Agreements not to sue, and agreements not to oppose; • Agreements to changes in the IP rights to be claimed: e.g.: classes for a trade mark, narrowing of claims for a patent; • Agreed redesigns, rewordings, reworkings; and • Apologies. In fact, the opportunities for “value-add” in settlement are probably richer in IP than in any other field of commercial litigation. At this point, some might say: “can’t we achieve all of that through negotiation? Why do we need to mediate?”. But research shows that mediation can greatly increase the chances of achieving settlement, and of such settlements being lasting and effective. There are also intangible benefits to mediation. In particular: • Mediation can be the best way to repair relationships. A lot of hard-nosed lawyers scoff at the importance of relationships in commercial disputes. They are wrong to do so. In a speech on mediation in 2015, Lord Neuberger, then President of the UK Supreme Court, cited a 2007 UK survey, “which reported that 47% of respondents involved in commercial litigation admitted that a personal dislike of the other side had been responsible for driving them into costly and lengthy litigation” . (From address by Lord Neuberger to the Civil Mediation Conference, 12 May 2015, citing: http://www.newlawjournal.co.uk/nli/content/litigation-v-mediation)