Contract analysis

1. Purpose and Overview We write to confirm the successful conclusion of the trademark infringement and coexistence dispute between our client, Meridian Consumer Brands LLC ("MCB"), and Brindoval Home Goods Inc. ("Brindoval"). As you know, Calderwood & Harkness LLP ("C&H" or the "Firm") opened this matter on September 26, 2022, following the identification of Brindoval's infringing use of the "MERIDIAN FRESH" mark an

2. Summary of Closing Events 2.1 Court Dismissal — S.D.N.Y. On May 22, 2023, the parties filed a Joint Stipulation of Dismissal with Prejudice in the United States District Court for the Southern District of New York in the matter styled Meridian Consumer Brands LLC v. Brindoval Home Goods Inc., Case No. 1:22-cv-09483, before the Honorable Patricia M. Albright, United States District Judge. The Joint Stipulation was

3. Financial Summary Set forth below is a summary of the financial outcome of this matter, including the settlement recovery, a detailed breakdown of total matter costs, and the resulting net recovery to MCB. 3.1 Settlement Recovery MCB has received a one-time, lump-sum settlement payment from Brindoval in the amount of $1,350,000. This payment was funded through the escrow mechanism described above and has been rele

4. Summary of Key Coexistence Agreement Terms For ease of reference in connection with the ongoing obligations discussed in Section 5 below, we provide a brief recapitulation of the principal terms of the Trademark Coexistence Agreement executed on May 15, 2023. This summary is intended as a convenient reference only and is not a substitute for the full text of the Agreement, a fully executed copy of which is enclose

5. MCB's Ongoing Obligations and Recommended Actions While the litigation and settlement proceedings are now concluded, the Coexistence Agreement imposes a number of ongoing obligations and affords MCB certain rights that require affirmative action and attention. Set forth below are the key areas in which MCB should take action in the near term and on a continuing basis, together with our recommendations. 5.1 Monitor

6. Procedural History For completeness of the record, set forth below is a chronological summary of the key events in the prosecution and resolution of this matter: • September 26, 2022: Matter opened at Calderwood & Harkness. Cease-and-desist letter sent to Brindoval Home Goods Inc. demanding cessation of use of the "MERIDIAN FRESH" mark and the teal-and-white trade dress with wave device in connection with househol

7. Conclusion and Availability Calderwood & Harkness is very pleased with the outcome achieved in this matter. The resolution secures both a meaningful monetary recovery of $1,350,000 — yielding a net recovery to MCB of $628,410 after all matter costs — and, equally important, long-term, comprehensive brand protection for the MERIDIAN trademark portfolio through the perpetual restrictions imposed by the Coexistence A

1. Filed-stamped Order of Dismissal with Prejudice, Meridian Consumer Brands LLC v. Brindoval Home Goods Inc., S.D.N.Y. Case No. 1:22-cv-09483 (entered May 30, 2023)

2. Executed Trademark Coexistence Agreement (dated May 15, 2023)

3. Escrow release confirmation from Dralvecen National Bank (dated May 30, 2023)

4. Final Invoice and Fee Summary, C&H Matter No. 1011-00003 (dated May 30, 2023) Timekeeper | Role | Hours | Rate ($/hr) | Total Alan Ngo | Responsible Partner | 142.0 | $1,050 | $149,100 Marcus Delgado | Billing Partner | 58.0 | $1,050 | $60,900 Christy Bauer | Lead Associate | 310.0 | $725 | $224,750 Peter Vassiliev | Working Associate | 320.0 | $575 | $184,000 Total | 830.0 | $618,750 Cost Category | Amount Attorn