Contract analysis

I. Introduction and Scope of Review Calderwood & Harkness LLP ("Calderwood & Harkness" or "we") serves as borrower's counsel to Ironhaven Data Centers LLC, a Delaware limited liability company (the "Borrower" or "IHDC"), in connection with that certain Senior Secured Term Loan B Credit Agreement, dated as of May 15, 2024 (as amended, restated, supplemented, or otherwise modified from time to time, the "Credit Agreeme

II. Summary of Review Findings Based upon our review of the Policy, its schedules, endorsements, and associated documentation, we confirm the following:

1. Compliance with Credit Agreement Conditions Precedent. The Policy conforms in all material respects to the requirements of the Credit Agreement governing the delivery of title insurance as a condition precedent to the initial funding under the Virginia campus controlled disbursement escrow. The Policy has been issued in the form, amount, and substance required by the Credit Agreement and is satisfactory to us in o

2. Named Insured. The Policy correctly identifies the named insured as Pinnacle Trust Company, N.A., a national trust company, as Collateral Agent for the benefit of the Secured Parties under the Credit Agreement. The insured capacity of Pinnacle as Collateral Agent is consistent with the security structure contemplated by the Credit Agreement and the related Collateral Agency Agreement.

3. Coverage Amount. The amount of insurance under the Policy is $475,000,000.00, which corresponds to the Virginia campus Phase I construction funding amount under the use of proceeds provisions of the Credit Agreement. This amount represents the portion of the aggregate $950,000,000 facility that is allocable to the Virginia campus and is the appropriate coverage amount for the insured Deed of Trust.

4. Policy Form. The Policy is issued on the ALTA Loan Policy form (06-17-06), as approved for use in the Commonwealth of Virginia by the Virginia State Corporation Commission, Bureau of Insurance. This is the most recent approved form for lender's title insurance policies in Virginia and is the form required under the Credit Agreement.

5. Effective Date. The effective date of the Policy is June 3, 2024, at 2:30 p.m. Eastern Time, which is the date and time of recording of the Deed of Trust in the land records of Loudoun County, Virginia. This effective date is consistent with the Closing Date as defined in the Credit Agreement.

6. Estate Insured. The Policy insures a fee simple estate in the Property, vested in Ironhaven Data Centers LLC, a Delaware limited liability company. We have independently confirmed through our review of the organizational documents that the Borrower is duly organized, validly existing, and in good standing under the laws of the State of Delaware and is registered to transact business in the Commonwealth of Virginia

III. Analysis of Schedule B Exceptions We have reviewed each exception set forth in Schedule B — Part I (Exceptions from Coverage) of the Policy. Our analysis confirms that all exceptions fall within the categories of "Permitted Liens" or "Permitted Encumbrances" as defined in the Credit Agreement. No exception constitutes a material defect in title, and no exception would reasonably be expected to materially impair

IV. Endorsements Confirmed We have confirmed that the following ALTA endorsements have been obtained and are attached to the Policy, as required by the Credit Agreement: (a) ALTA 3.1 — Zoning (with Parking and Loading). This endorsement confirms that the Property is zoned under the Loudoun County zoning ordinance in a classification that permits data center and colocation facility use and that the Property complies w

V. Recommendation Based upon the foregoing review and analysis, Calderwood & Harkness LLP confirms that the ALTA Lender's Title Insurance Policy No. LTP-2024-VA-007892, issued by Keystone Title Guaranty Company, satisfies the title insurance conditions precedent to initial funding under the Credit Agreement. The Policy provides the Collateral Agent and the Secured Parties with the requisite assurance of a first-prior

Section 1 — Type of Estate or Interest in the Land: Fee Simple

Section 2 — Title to the Estate or Interest in the Land is Vested In: Ironhaven Data Centers LLC, a Delaware limited liability company Address: 4500 Dominion Ridge Boulevard, Suite 300, Ashburn, Virginia 20147 State of Organization: Delaware Registered to Transact Business in the Commonwealth of Virginia: Yes (Virginia State Corporation Commission ID No. S8724319)

Section 3 — The Insured Mortgage and Assignments Thereof, if Any, Are Identified as Follows: Deed of Trust, Assignment of Leases and Rents, Security Agreement, and Fixture Filing, dated as of June 3, 2024, executed by Ironhaven Data Centers LLC, as Grantor, to Commonwealth Land Trustees, Inc., as Trustee, for the benefit of Pinnacle Trust Company, N.A., as Collateral Agent, recorded on June 3, 2024 in the land record

Section 4 — The Land Referred to in this Policy is Described as Follows: The land described herein consists of two parcels located in Loudoun County, Virginia, which together form a single contiguous tract of approximately 142 acres, more particularly described as follows: Parcel 1 — Tax Parcel No. 087-27-1234 ALL THAT certain lot or parcel of land, together with all improvements thereon and all rights, privileges, e

1. The failure of the Land to be classified under the applicable zoning ordinances or land use regulations of Loudoun County, Virginia, in a zoning district or classification that permits data center, colocation facility, technology infrastructure, and ancillary support uses as a matter of right or as a conditional use permitted under the applicable zoning district.

2. The current zoning classification of the Land is: PD-TRC (Planned Development — Technology/Research Center), as designated under the Loudoun County Revised 1993 Zoning Ordinance (as amended through the Date of Policy).

3. The failure of the Land, as of the Date of Policy, to comply with the minimum parking and loading requirements imposed by the applicable zoning ordinances and land use regulations for the permitted use described above, including requirements for the number, location, and dimensional standards of parking spaces and loading docks. This endorsement is issued as part of the Policy. Except as it expressly states, it do

1. The Company insures against loss or damage sustained by the Insured by reason of: (a) The existence, at the Date of Policy, of any violation on the Land of any enforceable covenant, condition, or restriction contained in any document described in Schedule B of this Policy, unless such violation has been excepted in Schedule B; (b) A forced removal of any existing structure, or any part thereof, other than a bounda