Contract analysis

I. Introduction and Purpose of Correspondence I am Alan Ngo, a partner in the intellectual Property Practice Group of Calderwood & Harkness LLP and the designated Billing Partner responsible for insurance and cost-recovery matters in the above-referenced litigation. I write on behalf of our client, Genome Dx Therapeutics Inc. ("GenomeDx"), a Delaware corporation headquartered at 4750 Torrey Pines Road, Suite 300, San

II. Notice of Litigation — Covered Claim A. Overview of the Action The following summarizes the key identifying information for the litigation: This action is an offensive patent enforcement action brought by GenomeDx against Helios Precision Diagnostics, Inc. ("Helios"), a competing molecular diagnostics company. GenomeDx asserts infringement of three United States patents directed to methods and systems for genomic

1. U.S. Patent No. 10,438,271 ("the '271 Patent") • Title: "Methods for Predicting Prostate Cancer Outcomes Using Multi-Gene Expression Classifiers" • Filing Date: June 14, 2016 • Issue Date: October 8, 2019 • Expiration Date: June 14, 2036 • Asserted Claims: 1, 3, 5, 7, 12, and 18 The '271 Patent is directed to methods of predicting clinical outcomes in prostate cancer patients using multi-gene expression classifier

2. U.S. Patent No. 11,204,893 ("the '893 Patent") • Title: "Genomic Classifier Systems and Methods for Post-Surgical Cancer Prognosis" • Filing Date: March 22, 2019 (continuation of the '271 Patent application) • Issue Date: December 21, 2021 • Expiration Date: June 14, 2036 • Asserted Claims: 1, 2, 9, 14, and 20 The '893 Patent is a continuation of the '271 Patent application and is directed to systems and methods f

3. U.S. Patent No. 11,891,647 ("the '647 Patent") • Title: "Improved Methods for Genomic Risk Stratification in Prostate Cancer Using Combined Biomarker and Clinical Variable Models" • Filing Date: September 9, 2021 • Issue Date: February 6, 2024 • Expiration Date: September 9, 2041 • Asserted Claims: 1, 4, 6, 11, and 15 The '647 Patent claims improved methods for genomic risk stratification that integrate biomarker

III. Procedural History and Current Status A. Chronological Summary The following is a chronological summary of significant events in this litigation from inception through the date of this letter: B. Current Posture As of the date of this letter, the parties are in the midst of active fact discovery, which is scheduled to close on March 6, 2026. The following summarizes the current posture of the case: Document prod

IV. Identification of Counsel and Billing Personnel Calderwood & Harkness LLP's litigation team for this matter consists of the following attorneys, each of whom has recorded time to this matter during the period covered by this report: These hourly rates are consistent with the rates approved in the Calderwood & Harkness LLP engagement letter dated March 12, 2025, a copy of which is enclosed. We note that the engage

V. Summary of Fees and Costs Incurred to Date A. Legal Fees — Calderwood & Harkness LLP The following is a summary of legal fees incurred by Calderwood & Harkness LLP for work performed on this matter during the period from March 12, 2025 through January 31, 2026, organized by litigation phase: The pre-filing investigation phase was particularly intensive, requiring Calderwood & Harkness's team to conduct a thorough

VI. Projected Costs Through Trial The Calderwood & Harkness LLP engagement letter dated March 12, 2025 set forth an estimated total litigation budget in the range of $6,800,000 to $9,200,000 through trial. Based on the work performed to date and the current posture of the case, we continue to believe this budget range is reasonable and appropriate. The following is a breakdown of projected remaining costs by phase: C

VII. Coverage Analysis and Deductible Status A. Policy Terms Summary For ease of reference, the key terms of the Policy are summarized below: B. Deductible Status As set forth in Section V above, total costs incurred through January 31, 2026 amount to approximately $2,480,000. The Policy's deductible is $2,500,000. Accordingly, approximately $20,000 remains before the deductible is fully satisfied and Greystone's cov

VIII. Policy Period Expiration and Renewal Request We draw Greystone's attention to a matter of significant importance to GenomeDx: the current Policy Period expired on December 31, 2025. The litigation, however, is very much ongoing and is expected to continue through trial in February 2027 — more than thirteen months beyond the expiration of the Policy Period. GenomeDx's complaint in this action was filed on March

1. Confirmation of Continuing Coverage. We request written confirmation from Greystone that the Policy provides tail coverage or continuing coverage for claims first made during the Policy Period. Specifically, we request confirmation that costs and expenses incurred after December 31, 2025 in connection with this claim remain covered under the Policy, subject to the Policy's terms, conditions, and limits.

2. Renewal Terms. To the extent that continuing coverage requires renewal of the Policy, we request that Greystone provide GenomeDx with information regarding renewal terms, including any proposed changes to the coverage limit, deductible amount, co-insurance structure, or premium, as well as the timeline for completing the renewal process.

3. Treatment Under Successor Policy. If a renewed or successor policy is issued, we request confirmation that the current claim will be treated as a continuing covered claim under the renewed or successor policy, without the application of a new or additional deductible, and with full credit for the deductible already satisfied under the current Policy. The importance of uninterrupted coverage cannot be overstated. G

IX. Reporting Obligations GenomeDx and Calderwood & Harkness LLP acknowledge their reporting obligations under the Policy, including the obligation to provide timely notice of the claim, periodic status reports, and supporting documentation as reasonably requested by Greystone. In fulfillment of these obligations, we commit to providing Greystone with quarterly status reports on the litigation, which will include the

X. Requests for Confirmation In summary, GenomeDx respectfully requests that Greystone provide the following confirmations and information at its earliest convenience:

1. Coverage Confirmation. Written confirmation that Policy No. GSI-IP-2024-07812 covers the litigation captioned Genome Dx Therapeutics Inc. v. Helios Precision Diagnostics, Inc., Case No. 3:25-cv-01847-JWL, pending in the U.S. District Court for the Northern District of California, as a covered claim under the Policy.

2. Deductible Credit. Confirmation that the deductible amount is $2,500,000 and that the costs incurred to date, as summarized in this letter and the enclosed cost summary, are properly credited toward satisfaction of the deductible.

3. Co-Insurance and Coverage Limit. Confirmation of the 80/20 co-insurance structure (Greystone: 80%; GenomeDx: 20%) and the $10,000,000 aggregate coverage limit applicable to this claim.

4. Continuing Coverage and Renewal. Confirmation that coverage for this claim continues notwithstanding the December 31, 2025 expiration of the Policy Period, and provision of information regarding renewal terms, renewal premium, and any proposed changes to the Policy's coverage structure for the renewal period.

5. Claims Adjuster Identification. Identification of the assigned claims adjuster or coverage counsel at Greystone who will serve as the primary point of contact for ongoing communications regarding this claim.

6. Invoicing Procedures. Specification of any required claim forms, supplemental documentation, or invoicing procedures that Calderwood & Harkness LLP should follow for submission of covered costs once the deductible is satisfied, including any required formatting, supporting detail, or approval processes. We would appreciate receiving Greystone's responses to these requests within thirty (30) days of the date of thi

XI. Enclosures The following documents are enclosed with this letter for Greystone's reference:

1. Copy of the Complaint, Genome Dx Therapeutics Inc. v. Helios Precision Diagnostics, Inc., Case No. 3:25-cv-01847-JWL (filed March 28, 2025);

2. Copy of the Scheduling Order entered by the Honorable Jessica W. Langston (June 18, 2025);

3. Copy of the Court's Order Denying Defendant's Motion to Dismiss Counts II and III (January 13, 2026);

4. Summary table of fees and costs incurred through January 31, 2026, broken down by phase, timekeeper, and cost category (redacted as necessary to preserve attorney-client privilege and work-product protections); and

5. Copy of the Calderwood & Harkness LLP engagement letter (dated March 12, 2025) (provided for reference to approved hourly rates and litigation budget estimates). Additional documents, including copies of other significant filings and orders, are available upon request.

XII. Closing We respectfully urge Greystone's prompt attention to the matters set forth in this letter. The fact discovery close date of March 6, 2026 is imminent, and the litigation is entering a phase of accelerating costs. The deductible is expected to be exceeded in the very near term, and it is essential that the invoicing and reimbursement process be in place before significant covered costs begin to accrue abo