Contract analysis

I. Purpose and Summary This memorandum serves two distinct purposes in connection with the now-closed representation of Vantage Mobility Systems Corp. ("VMS") in the above-referenced patent infringement action. First, it documents the final status of the privilege log maintained throughout the course of the litigation, including a summary of the categories, scope, and completeness of the entries contained therein. Se

II. Privilege Log Status A. Scope and Coverage The privilege log prepared and maintained in connection with this matter encompasses a total of 247 entries. These entries represent the universe of documents withheld from production during fact discovery on the basis of the attorney-client privilege and/or the work-product doctrine, as well as documents identified during the engagement that warranted logging for comple

III. Litigation Hold — Release A. Litigation Hold History A litigation hold was initially implemented upon the filing of the Pinnacle complaint on February 28, 2024, by VMS's then-counsel, Hargrove Dunn LLP. The litigation hold was directed to VMS and its personnel and required the preservation of all documents and electronically stored information ("ESI") potentially relevant to the claims and defenses in the action

IV. Document Retention and Destruction Protocol A. Firm Standard Retention Period In accordance with Calderwood & Harkness LLP's firm-wide Records Retention and Destruction Policy, the standard retention period for closed litigation matter files is seven (7) years from the date of matter closing. Because this matter is being closed effective June 20, 2025, the retention period will extend through approximately June 2

1. A new litigation hold or preservation obligation has arisen involving VMS, the '312 Patent, or the same or related subject matter, which would require continued preservation of any portion of the matter files;

2. The client has requested in writing that the matter files (or any portion thereof) be returned to the client or that the retention period be extended beyond the standard seven-year term; or

3. Applicable law, regulation, or professional responsibility rule requires the firm to retain the matter files for a period longer than seven years from the date of matter closing. In the event that none of the foregoing circumstances exist, destruction of electronic files will be carried out through the firm's secure deletion protocols, which include the permanent erasure of all archived data from the DMS and backu

V. Third-Party Vendor and Expert File Considerations A. Greystone Technical Consulting LLC Dr. Franklin Yeoh of Greystone Technical Consulting LLC, located at 900 Research Park Drive, Suite 210, Ann Arbor, MI 48105, was retained as the technical expert for VMS in this matter. Dr. Yeoh prepared detailed claim charts, invalidity analysis materials, and draft expert opinions addressing the invalidity of Claims 1, 7, and

VI. Summary of Key Financial and Matter Data for Archival Records The following summary table is provided for inclusion on the archived file cover sheet and for reference by the firm's records-management and conflicts departments:

VII. Action Items and Recommendations The following action items should be completed to finalize the matter closing process:

1. Meridian Data Export. Confirm receipt of the final data export from Meridian Document Solutions LLC and, upon successful archive to the firm's DMS, authorize the decommissioning of the Meridian hosted platform for this matter.

2. Caldwell Barrow File Transfer. Confirm receipt of any remaining files from Caldwell Barrow LLP and incorporate such files into the master matter file in the firm's DMS.

3. Greystone File Preservation. Confirm receipt of written acknowledgment from Greystone Technical Consulting LLC of its obligation to preserve its work files for the seven-year retention period, consistent with the terms of the retention agreement.

4. Physical File Storage. Complete the boxing and indexing of any physical files associated with this matter and arrange for transfer to the firm's approved off-site records-management facility within thirty (30) days.

5. Electronic Archive. Complete the archival of all electronic files in the firm's DMS under Matter No. 1007-00003, ensuring that appropriate access controls and retention tags are applied to the archived files.

6. Destruction Date Calendar Entry. Calendar the seven-year destruction date (on or after June 20, 2032) in the firm's records-management system, with appropriate reminders and pre-destruction review protocols.

7. Client Document Return. If VMS requests the return of any original documents within sixty (60) days of the June 18, 2025 matter closing letter (i.e., by August 17, 2025), coordinate the return of such documents promptly and document the return in the matter file.

VIII. Conclusion In summary, the privilege log maintained in connection with Matter No. 1007-00003 is complete at 247 entries, encompassing all documents withheld from production on the basis of the attorney-client privilege and/or the work-product doctrine during both the Hargrove Dunn LLP and Calderwood & Harkness LLP periods of representation. No privilege challenges or motions to compel were pending at the time o