Contract analysis

1. Purpose and Legal Obligation Calderwood & Harkness LLP has been retained by Solstice Biomedical Devices Ltd. ("Solstice" or "SBD") and its U.S. operating subsidiary, Solstice Biomedical, Inc. ("Solstice US," and together with Solstice, the "Company"), to defend a patent infringement action filed by Apex Surgical Innovations, Inc. ("Apex") in the United States District Court for the District of Delaware. The compla

2. Description of the Litigation The plaintiff in the Action is Apex Surgical Innovations, Inc. ("Apex"), a Delaware corporation with its principal place of business at 1220 North Market Street, Suite 550, Wilmington, Delaware 19801. Apex is a medical device company engaged in the development, manufacture, and sale of surgical instruments and laparoscopic access devices. In the complaint filed on May 9, 2024, Apex al

3. Accused Products The following Solstice product lines have been specifically accused of infringement in the Action and are a primary focus of this litigation hold: The PE-5000, PE-12000, and PE-15000 Series products are collectively referred to herein as the "Accused Products." The scope of this hold is not limited to the specific product models identified by name in the complaint. The hold also extends to any suc

4. Identified Custodians The following individuals and functional groups have been identified as custodians whose files, records, communications, and other materials are subject to this litigation hold. If you are identified below — either by name or by functional role — you are a custodian subject to the obligations set forth in this notice. This list may be supplemented as the Litigation progresses and additional c

5. Categories of Documents and Information to Be Preserved The following categories describe the types of documents, ESI, and tangible materials that must be preserved under this litigation hold. These categories are intended to be illustrative and not exhaustive. If you possess, have access to, or have control over any information that you believe may be relevant to the Litigation, you must preserve it even if it do

6. Scope of Preservation — ESI and Physical Media The preservation obligations imposed by this litigation hold apply to all forms of information, whether stored in paper, electronic, magnetic, optical, or any other tangible or intangible form. The following provides additional detail on the scope of preservation for each category of media: 6.1 Electronically Stored Information (ESI) ESI subject to preservation includ

7. Immediate Actions Required Each custodian receiving this notice must take the following actions immediately upon receipt: 7.1 Suspend All Document Destruction. Immediately suspend any routine document retention or destruction policies, automatic deletion settings, recycling schedules, or other information-management practices that could result in the deletion, destruction, alteration, or disposal of any documents,

8. Duration of the Hold This litigation hold remains in effect until you receive a written release from Calderwood & Harkness LLP or from Eamon Rourke, General Counsel of Solstice Biomedical Devices Ltd. No oral communication, informal notification, or passage of time should be construed as a release of the hold. Do not assume that the hold has been lifted even if you learn that the Litigation has been settled, dismi

9. Consequences of Non-Compliance The consequences of failing to comply with this litigation hold are severe and far-reaching. As noted in Section 1, courts have broad authority under Federal Rule of Civil Procedure 37(e) and their inherent powers to impose sanctions for the spoliation of evidence. Such sanctions may include: • An instruction to the jury that it may or must presume that the destroyed or lost evidence

10. Questions and Points of Contact If you have any questions regarding the scope, application, or requirements of this litigation hold, or if you become aware of any potentially relevant materials that may require special preservation measures, please contact one of the following individuals promptly: Internal Contacts: Eamon Rourke General Counsel Solstice Biomedical Devices Ltd. Unit 14, Clonskeagh Business Park,

11. Acknowledgment Each custodian receiving this notice is required to sign and return the Acknowledgment Form set forth below (or submit an electronic acknowledgment, as directed) within five (5) business days of receipt. By signing the Acknowledgment Form, you confirm the following:

1. You have received and carefully reviewed this Litigation Hold Notice in its entirety.

2. You understand your obligation to preserve all potentially relevant documents, electronically stored information, and tangible materials as described herein.

3. You agree to comply fully with the preservation requirements set forth in this notice, including the immediate actions described in Section 7.

4. You have identified, in the space provided below, any relevant materials of which you are aware that may require special preservation measures (e.g., materials stored at off-site locations, materials in the custody of third parties, data on personal devices, or materials in formats requiring special handling). Failure to return the signed Acknowledgment Form within the specified time frame will be reported to the