Contract analysis

1. Summary of Documents Produced In response to IDR No. 12, PPC is producing the following categories of documents, each of which is described in greater detail in Sections 2 and 3 below: (a) PBI's commercial lease agreement for office premises at Sandyford Business Park, Dublin, Ireland; (b) Lease amendments, expansion agreements, and renewal documentation spanning the period from PBI's establishment in 2012 through

2. PBI Office Lease — Description of Produced Documents 2.1 Principal Lease Agreement The principal document produced in this category is the commercial lease agreement (the "Lease") between PBI, as tenant, and Claremount Property Holdings Limited, an unrelated Irish property management company, as landlord, for office premises comprising approximately 18,000 square feet (approximately 1,672 square meters) of Class A

3. Evidence of Physical Presence — Description of Produced Documents 3.1 Photographs and Floor Plans PPC is producing a series of date-stamped photographs of PBI's offices at Claremont House, Sandyford Business Park, as well as architectural floor plans depicting the layout and configuration of PBI's approximately 18,000-square-foot office space. The photographs and floor plans are produced at Bates numbers PPC-IDR12

4. Additional Context Regarding PBI's Physical Presence and Economic Substance While the documents produced in response to IDR No. 12 are focused specifically on PBI's office lease, physical premises, and evidence of physical presence in Ireland, PPC respectfully notes that these documents constitute one component of a broader body of evidence demonstrating PBI's substantive operations and genuine economic substance

5. Production Index Attached hereto as Exhibit A is a Production Index listing all Bates-numbered documents produced in response to IDR No. 12. The Production Index is organized in the following columnar format: The documents listed in the Production Index correspond to the categories described in Sections 2 and 3 of this letter and are organized in the same sequence. The complete Bates-numbered document production a

6. Reservation of Rights and Privilege PPC and PBI expressly reserve all rights, objections, and defenses that have not been expressly waived in connection with this response, including but not limited to any rights, objections, and defenses available under the Internal Revenue Code, the Treasury Regulations, and applicable administrative guidance and procedures. Nothing in this response or in the accompanying docume