Contract analysis

I. Purpose and Scope The purpose of this memorandum is to establish the custodian identification list, document collection methodology, applicable date ranges, data sources, de-duplication and filtering protocols, and vendor coordination procedures for compliance with the Second Request issued by the Federal Trade Commission on May 29, 2023 (FTC File No. 231-0487) (the "Second Request"). This protocol is intended to

II. Transaction Background This section provides a summary of the proposed transaction and the key parties involved, for context in understanding the custodian identification rationale and collection scope set forth in subsequent sections. Acquirer. The acquiring entity is Solara Digital Infrastructure Fund IV LP ("Fund IV"), a Delaware limited partnership with approximately $4.2 billion in committed capital. Fund IV

III. Custodian Identification A. Overview The team has identified a total of eighteen (18) custodians on the Solara side of the transaction whose files are expected to contain documents responsive to one or more of the forty-seven (47) Second Request specifications. These custodians are organized into two groups: • Solara GP / Fund IV Custodians: Twelve (12) custodians from the Solara GP management team, Fund IV inve

IV. Document Collection Methodology A. Data Sources The following data sources have been identified for collection from the eighteen (18) Solara-side custodians. This inventory is based on preliminary information gathered through custodian notification questionnaires and initial interviews with Solara GP and Meridian IT personnel. The data source inventory may be supplemented based on the results of the custodian int

1. Email Systems Solara GP / Fund IV. Solara GP utilizes Microsoft Outlook / Exchange hosted on Ashgrove Software as its primary email platform. Collection will encompass primary mailboxes and archive folders for all twelve (12) Solara custodians. Archived and journaled email will be collected in addition to active mailbox contents to ensure completeness. Ashgrove Software retention policies have been confirmed to pr

2. Shared Drives and File Servers Solara GP. Solara GP maintains a Westvale Services Inc. site for Fund IV deal files, which includes a dedicated folder structure for the Pinnacle deal room as well as a Meridian portfolio management folder containing ongoing operational and financial reporting materials. The team will collect all documents from the Pinnacle deal room folder and targeted subfolders of the Meridian por

3. Messaging and Collaboration Platforms Meridian Solutions (Solara GP). Solara GP uses Meridian Solutions as its primary internal instant messaging and team collaboration platform. The team will collect messages from the following Meridian Solutions channels, which have been identified as potentially containing responsive communications: • #pinnacle-deal (dedicated channel for the Pinnacle acquisition deal team) • #

4. Personal Devices Custodian interview questionnaires (to be completed by June 12, 2023) will include specific questions designed to identify any use of personal email accounts (e.g., Northgate Software, Cascade Health IT, personal Ridgeline Technologies accounts), personal mobile devices (including text messages, coss, and Meridian Services Inc. messages), or personal cloud storage services (e.g., Larkspur Technolo

5. Cloud Repositories Solara GP. Solara GP utilizes a firmwide box enterprise account for document management and file sharing. Targeted collection will be performed from deal-specific folders within the box account, including folders related to the Pinnacle acquisition, Meridian portfolio oversight, and Fund IV strategic planning. Meridian. Certain members of Meridian's product and engineering teams utilize Crestlin

6. Structured Data / Business Systems In addition to unstructured documents and communications, the Second Request requires the submission of structured data from various business systems. The following structured data sources have been identified: • Quillon Data Systems (Meridian): Meridian's customer relationship management system contains customer lists, pipeline data, opportunity records, win/loss records, and re

V. Estimated Collection Volume and Processing A. Estimated Collection Volume Based on preliminary volume estimates provided by Solara GP and Meridian IT departments, as well as Keymark's initial assessment of the identified data sources, the team estimates that the total volume of documents collected across all eighteen (18) Solara-side custodians will be approximately 1,240,000 documents (1.24 million). This estimat

VI. Search Term Development Search terms are a critical component of the Second Request compliance process and serve as the primary mechanism for reducing the collected document universe to a reviewable population of potentially responsive documents. Consistent with standard FTC Second Request practice, search terms will be developed in consultation with FTC Bureau of Competition, Mergers IV Division staff, following

VII. Review Workflow and Quality Control A. Review Team Structure The document review will be conducted by a team of twenty-two (22) contract review attorneys engaged through Keymark Document Solutions LLC. The contract review attorneys have been selected based on their experience with antitrust and merger review matters, their familiarity with Crestline Technologies, and their availability to commit to the anticipat

VIII. Coordination with Keymark Document Solutions LLC Vendor. Keymark Document Solutions LLC ("Keymark") has been engaged as the e-discovery vendor for this engagement. Keymark will provide a comprehensive suite of services encompassing forensic collection support, data processing, hosted review, contract review staffing, and production support. Project Manager. The Keymark Project Manager for this engagement is Dan

1. Forensic Collection Support. Keymark will provide trained forensic collection specialists and tools to perform on-site and remote collections from all identified data sources, as described in Section IV.C above.

2. Data Processing. Keymark will ingest all collected data into its processing pipeline, performing text and metadata extraction, de-NIST filtering, de-duplication, and file-type filtering in accordance with the protocols described in Sections V.B and V.C above.

3. Hosting of Crestline Technologies Review Environment. Keymark will host and maintain the Crestline Technologies review environment for this engagement, including workspace configuration, user management, analytics setup, and ongoing technical support throughout the review period.

4. Staffing and Management of Contract Review Attorneys. Keymark will provide and manage the team of twenty-two (22) contract review attorneys who will conduct the first-pass document review under the supervision of the Calderwood & Harkness team.

5. Production Formatting. Upon completion of the review, Keymark will prepare all responsive, non-privileged documents for production in compliance with the FTC's standard production format specifications, including Bates stamping, TIFF/PDF conversion, and load file preparation.

6. Privilege Log Generation Support. Keymark will provide Crestline Technologies-based privilege log generation tools and support to assist the team in compiling the privilege log in compliance with FTC standards. Estimated Vendor Costs. Based on the estimated collection volume, processing requirements, hosting duration, contract review attorney staffing levels, and production volume described in this protocol, Keyma

IX. Production Targets and Timeline A. Target Milestones The following table sets forth the target milestone dates for the key phases of the Second Request compliance effort on the Solara side: The team targets filing Solara's Substantial Compliance Certification within approximately 115–120 days of the Second Request issuance. Based on the Second Request issuance date of May 29, 2023, this translates to a target cer