In Lucent Technologies, Inc. v. State Board of Equalization, 193 Cal. Rptr. 3d 323 (Cal. Ct. App. October 8, 2015), cert. denied January 20, 2016, the California Court of Appeal held that software transferred in conjunction with the concurrent license to copy and use the software was not subject to California sales tax, despite the fact that the software was delivered via magnetic tapes and compact discs, i.e., a tangible medium. As discussed below, the Court of Appeal’s decision addresses the arguments presented by the California Board of Equalization (“Board”) and appears to provide alternative grounds for exemption: one related to bundled transactions of tangible and intangible property and the other related to intangible property transferred pursuant to a Technology Transfer Agreement (“TTA”). Both grounds favored Lucent Technologies, Inc. (“Lucent”).