Contract analysis

1. Introduction and Purpose Calderwood & Harkness LLP serves as borrower's counsel to Ironhaven Data Centers LLC ("IHDC" or the "Borrower") in connection with the above-referenced Credit Agreement. Capitalized terms used herein and not otherwise defined shall have the meanings ascribed to such terms in the Credit Agreement. The purpose of this transmittal letter is to effect the delivery to the Administrative Agent o

2. Identification of Non-US Lenders The Lender syndicate for the Facility comprises seven (7) Lenders, holding aggregate Commitments of $950,000,000. Of the seven Lenders, five (5) are United States persons for US federal income tax purposes and are addressed separately in Section 6 below. Two (2) Lenders are not United States persons and are classified as Non-US Lenders for purposes of Section 2.17 of the Credit Agr

3. Summary of Enclosed W-8BEN-E Forms Set forth below is a detailed summary of the key information contained in each enclosed IRS Form W-8BEN-E. These summaries are provided for the Administrative Agent's reference and convenience; in the event of any discrepancy between the summaries below and the enclosed original forms, the original forms shall control. 3.1 NordBrücke AG — W-8BEN-E Summary Part I (Identification o

4. Cross-Reference to Credit Agreement Provisions The delivery of the enclosed IRS Form W-8BEN-E certificates is made in satisfaction of the requirements of Section 2.17(f) of the Credit Agreement, which provides, in pertinent part, that each Lender that is not a United States person shall deliver to the Administrative Agent and the Borrower, on or prior to the date on which such Lender becomes a Lender under the Cre

5. Administrative Instructions and Renewal Requirements We respectfully request that the Administrative Agent retain the enclosed original IRS Form W-8BEN-E certificates in its records and associate them with the applicable Lender accounts in the Administrative Agent's loan operations systems. Each form should be linked to the corresponding Lender's account for purposes of the Administrative Agent's withholding and r

6. US Lender Confirmations For completeness, and to provide the Administrative Agent with a comprehensive picture of the withholding tax status of the Lender syndicate, we note that the remaining five (5) Lenders under the Credit Agreement are each "United States persons" within the meaning of Section 7701(a)(30) of the Code and are not required to deliver IRS Form W-8BEN-E or any other withholding certificate applic

1. Crescent Harbor Bank, N.A. — Commitment: $200,000,000

2. Ridgeline National Bank — Commitment: $175,000,000

3. Marlowe Asset Management Meridian Capital, LLC — Commitment: $150,000,000

4. Atlas Peak Credit Partners, LP — Commitment: $125,000,000

5. Pacific Rim Institutional Lending Corp. — Commitment: $75,000,000 Each such US Lender is expected to deliver an IRS Form W-9 (Request for Taxpayer Identification Number and Certification) to the Administrative Agent and the Borrower on or prior to the Closing Date, confirming its status as a United States person and providing a valid taxpayer identification number ("TIN"). The Form W-9 certifies, among other thing

7. Enclosures Enclosed herewith are the following documents: Enclosure 1: IRS Form W-8BEN-E — NordBrücke AG (executed original; eight (8) pages) Enclosure 2: IRS Form W-8BEN-E — Osprey Insurance Capital, Ltd. (executed original; seven (7) pages) Enclosure 3: Summary Table of Lender Withholding Tax Status (reproduced below for convenience) Enclosure 3 — Summary Table of Lender Withholding Tax Status

8. Disclaimer and Reliance Calderwood & Harkness LLP's review of the enclosed IRS Form W-8BEN-E certificates has been limited to confirming their facial completeness, their internal consistency, their consistency with the information provided by the respective Non-US Lenders to this firm and to the Borrower, and their alignment with the withholding analysis set forth in the Tax Structure Memorandum dated April 22, 20