Claim Against Visa U.S.A. Inc.

Sale of rights to any payments the Debtors' may recover as a result of their potential involvement as putative class members in the litigation styled In re: Payment Card Interchange Fee and Merchant-Discount Antitrust Litigation (Case No. 1:05-md-01720-JG-JO), Describe as: On October 20, 2005, the Class Action Interchange Litigation was commenced in the United States District Court for the Eastern District of New York ("District Court") by various retailers and trade associations (the "Plaintiffs") against, among other entities, Visa U.S.A. Inc. ("Visa") and Mastercard International, Inc. ("Mastercard" and collectively with all other named defendants in the Class Action Interchange Litigation, the "Defendants"). The Plaintiffs claim that, between January 1, 2004 and the present, the Defendants conspired to unlawfully fix the price of "interchange fees" and other fees charged to merchants for transactions processed over the Visa and Mastercard networks. An Interchange fee is a fee that a merchant's bank pays a customer's bank when merchants accept cards using card networks such as Visa and MasterCard for purchases.