Contract analysis

1. Summary of Litigation and Resolution 1.1 Background of the Action On May 9, 2024, Apex Surgical Innovations, Inc., a Delaware corporation headquartered in San Jose, California, filed a Complaint in the United States District Court for the District of Delaware, initiating Civil Action No. 1:24-cv-00587-RGA. In its Complaint, Apex alleged that the Solstice Parties willfully infringed three United States utility pate

2. Summary of Executed Settlement Terms The following is a summary of the material terms of the Settlement Agreement and related documents. This summary is provided for reference and convenience only. In the event of any discrepancy between this summary and the terms of the executed Settlement Agreement, the Settlement Agreement shall control. All capitalized terms used in this section and not otherwise defined herei

3. Outstanding Post-Settlement Obligations While the litigation phase of this matter has concluded, the Settlement Agreement imposes a number of ongoing obligations on Solstice that will require careful attention and compliance. I strongly recommend that you designate a responsible individual or team within Solstice to oversee compliance with these obligations on an ongoing basis. The principal obligations are summar

4. Insurance Matters Calderwood & Harkness notified Halcyon Specialty Insurance Co. ("Halcyon") of the Apex claim on May 13, 2024, under intellectual property litigation defense Policy No. HSI-IP-2023-04891. The relevant coverage parameters are as follows: • Coverage: Patent infringement defense costs (duty to reimburse) • Per Occurrence Limit: $5,000,000 • Aggregate Limit: $10,000,000 • Self-Insured Retention (SIR):

5. Summary of Legal Fees and Costs 5.1 Calderwood & Harkness LLP Fees and Costs The following is a summary of all fees and costs incurred by Calderwood & Harkness LLP in connection with Matter No. 10294.0017: Engagement Team: Total Attorney Fees: $2,611,480.00 Total Costs and Disbursements: $235,839.42, comprising: Note: The expert fee and e-discovery vendor figures are components of the total costs and disbursements

6. Document Retention Instructions With the conclusion of the active litigation, it is important that Solstice establish clear and appropriate document retention protocols for the various categories of materials generated or collected in connection with this matter. Calderwood & Harkness recommends the following retention periods: 6.1 Settlement and License Documentation The executed Settlement Agreement and Mutual R

7. Engagement Wind-Down With the filing of the Stipulation of Dismissal with Prejudice on July 1, 2025, and the completion of all closing deliverables — including the preparation and filing of the Stipulation, the confirmation of the Tranche 1 escrow release, the settlement reporting to Halcyon, and the issuance of this closing letter — Calderwood & Harkness considers the active phase of its engagement in this matter

8. Acknowledgments and Closing Remarks In closing, I want to extend my sincere thanks and those of the entire Calderwood & Harkness engagement team to you, Dr. Fiona Tierney, Niamh Cassidy, and Brendan Molloy for your exceptional cooperation, responsiveness, and engagement throughout the litigation and settlement process. This matter required extensive coordination across multiple time zones and jurisdictions, and yo

1. Final Invoice & Fee Summary, Calderwood & Harkness LLP Matter No. 10294.0017 (dated July 2, 2025) Note: The executed settlement documentation package (Settlement Agreement and Mutual Release, Exhibits A through F, Escrow Agreement, and MFL Side Letter dated June 16, 2025) was previously delivered to Solstice under separate cover on June 17, 2025. cc: Dr. Fiona Tierney, Chief Executive Officer, Solstice Biomedical