Claims for Sale

Sale of the Seller Claims (which is expressly incorporated herein by reference) and all legal and equitable rights and obligations related thereto, whether now existing or arising in the future, including but not limited to benefits arising from and/or relating to the Seller Claims and the injuries alleged therein, and any rights to monetary recovery associated therewith (including all service award payments), or the benefits that may be monetized from settlements, judgements, or any other form of resolution of the litigation or claims or the operative facts alleged therein, all as further set forth herein. The seller is currently the named plaintiff or a plaintiff class member in nineteen pending class action antitrust lawsuits brought against pharmaceutical manufacturers (collectively, the “Antitrust Claims”). Three of the Antitrust Claims have been settled and are awaiting distribution to the plaintiff class (the “Settled Claims”), and more described as below:

• In re LoEstrin 24 Fe Antitrust Litigation, Case No. 13-2472 (D. R.I.);
• In re Namenda Direct Purchaser Antitrust Litigation, Case No. 15-07488 (S.D.N.Y.); and
• In re Restasis (Cyclosporine Ophthalmic Emulsion) Antitrust Litigation, Case No. 18-2819 (E.D.N.Y.).