engagement-letter-redstone-gaming.docx

1033-00004 · Redstone Gaming Corp · Engagement

engagement-letter-redstone-gaming.docx DOCUMENT Litigation

8 / 12 ← → ✕

CALDERWOOD & HARKNESS LLP Attorneys at Law 600 South Grand Avenue, Suite 4400 Los Angeles, California 90071 Telephone: (213) 555-8200 Facsimile: (213) 555-8201 www.calderwoodharkness.com

April 3, 2024

Priya Venkatesh, Esq. General Counsel Redstone Gaming Corp. 4100 Obsidian Tower Boulevard, Suite 2200 Las Vegas, NV 89109

Re: Engagement of Calderwood & Harkness LLP — Defense of Luminos Interactive LLC v. Redstone Gaming Corp., Case No. 2:24-cv-00587-RWL, United States District Court for the District of Nevada

Matter No.: 1033-00004

Dear Ms. Venkatesh:

1. Introduction and Purpose

Thank you for selecting Calderwood & Harkness LLP (the "Firm," "we," or "us") to represent Redstone Gaming Corp. ("Redstone," "RGC," or the "Company") in the above-referenced matter. We are pleased to have the opportunity to work with you and your team, and we are committed to providing Redstone with the highest quality legal representation.

The purpose of this letter is to confirm the terms and conditions upon which the Firm will represent Redstone in connection with the defense of the claims asserted by Luminos Interactive LLC ("Luminos"), a Texas limited liability company, in the above-captioned lawsuit. As you are aware, Luminos filed a complaint on March 18, 2024, in the United States District Court for the District of Nevada, alleging copyright infringement arising from certain visual assets incorporated in Redstone's multiplayer title Ironclad Dominion. The case has been assigned to the Honorable Rebecca W. Langford.

This engagement letter, together with the Firm's Standard Terms of Engagement enclosed herewith and incorporated by reference, constitutes the entire agreement between the Firm and Redstone with respect to this engagement. We ask that you please review this letter carefully and, if you agree to the terms set forth herein, countersign and return a copy to the undersigned at your earliest convenience so that we may formally commence our representation. We are happy to discuss any questions or concerns you may have regarding any provision of this letter.

2. Scope of Representation

Calderwood & Harkness LLP is engaged to represent Redstone Gaming Corp. in defending against the copyright infringement claims asserted by Luminos Interactive LLC in Luminos Interactive LLC v. Redstone Gaming Corp., Case No. 2:24-cv-00587-RWL, pending in the United States District Court for the District of Nevada (the "Litigation" or the "Matter").

The scope of this engagement encompasses all aspects of the defense of the Litigation, including without limitation: all pretrial proceedings, responsive pleadings, discovery (both written and oral), motion practice (including dispositive motions), trial preparation, trial (if necessary), and any post-trial motions filed during the pendency of the trial court proceedings. Specifically, the Luminos complaint alleges that thirty-seven (37) specific visual assets contained in Redstone's multiplayer online game Ironclad Dominion are substantially similar to corresponding assets found in Luminos's title Shardfall Chronicles. These thirty-seven assets are categorized in the complaint as follows:

(a) Twelve (12) character armor designs (identified in the complaint as Exhibits A-1 through A-12);

(b) Nine (9) environmental crystal textures (identified in the complaint as Exhibits B-1 through B-9);

(d) Eight (8) background matte paintings (identified in the complaint as Exhibits D-1 through D-8).

Luminos seeks injunctive relief prohibiting the continued use, display, and distribution of the allegedly infringing assets, actual damages in the amount of Twenty-Eight Million Five Hundred Thousand Dollars ($28,500,000.00), statutory damages in the alternative pursuant to 17 U.S.C. § 504(c), and an award of attorney's fees and costs pursuant to 17 U.S.C. § 505.

The scope of this engagement does not extend to any other litigation, regulatory, transactional, intellectual property prosecution, licensing, or advisory matter involving Redstone unless separately agreed upon in writing between the parties. Additionally, any expansion of the scope of this engagement — including, without limitation, the assertion of counterclaims against Luminos, the filing of cross-claims or third-party claims, joinder of additional parties, or representation in any related proceedings or investigations — will require a separate written agreement or a written amendment to this engagement letter executed by both parties.

3. Engagement Team

The following attorneys will comprise the primary engagement team responsible for the day-to-day management and prosecution of Redstone's defense in this Matter:

Catherine Bloom — Responsible Partner, intellectual Property Litigation Group. Ms. Bloom will serve as the lead partner with overall supervisory responsibility for the Matter. She will direct litigation strategy, oversee all substantive work product, and serve as the primary point of contact for the Company. Ms. Bloom has over twenty-two years of experience representing major technology and entertainment companies in high-stakes intellectual property disputes, including copyright, trade secret, and patent litigation in federal courts throughout the United States.

Alan Ngo — Billing Partner, intellectual Property Litigation Group. Mr. Ngo will serve as the billing partner for this engagement and will be responsible for all fee arrangements, invoicing, billing-related communications, and financial administration of the Matter. Mr. Ngo will also provide substantive support on complex copyright and digital media issues as needed.

Omar Siddiqui — Lead Associate, intellectual Property Litigation Group. Mr. Siddiqui will manage day-to-day litigation activities under Ms. Bloom's supervision. His responsibilities will include drafting and filing pleadings and motions, conducting and responding to written discovery, preparing for and attending depositions, and coordinating with expert witnesses, forensic consultants, and local counsel. Mr. Siddiqui brings extensive experience in copyright infringement litigation, with particular expertise in the interactive entertainment and digital media industries.

Christy Bauer — Working Associate, intellectual Property Litigation Group. Ms. Bauer will provide research, analysis, and drafting support across all phases of the Litigation. Her responsibilities will include legal research and memoranda preparation, document and e-discovery review, deposition preparation, and motion drafting. Ms. Bauer has significant experience in large-scale document review and e-discovery protocols relevant to digital content and software development matters.

From time to time, additional attorneys, paralegals, litigation support professionals, and other support staff may be assigned to the Matter as reasonably necessary to provide efficient and effective representation. The Firm will notify Redstone of any material changes to the core engagement team, including the addition of any new attorneys who are expected to have a significant role in the Matter.

4. Local Counsel

Due to the filing of this action in the United States District Court for the District of Nevada, the Firm will coordinate with Thorngate & Associates, PC (300 South Fourth Street, Suite 1100, Las Vegas, Nevada 89101) to serve as local Nevada counsel for Redstone in the Litigation. The engagement with Thorngate & Associates will be led by Patricia Thorngate, Esq., the firm's principal, who is admitted to practice before the District of Nevada and is well acquainted with the local rules, practices, and procedures of that court.

Thorngate & Associates will be responsible for handling all local filings with the Clerk of Court for the District of Nevada, attending local court appearances and status conferences in Las Vegas (whether in person or by telephone/video as directed by the Court), and coordinating with chambers on scheduling and procedural matters. Thorngate & Associates will work closely with our team and will be kept fully apprised of all strategic decisions and developments in the Litigation.

Thorngate & Associates will bill Redstone separately under its own engagement arrangement, the terms of which will be set forth in a separate engagement letter between Redstone and Thorngate & Associates. Notwithstanding this separate billing arrangement, all substantive legal strategy and direction of the Litigation will be coordinated and directed by Calderwood & Harkness LLP. To the extent any disagreement arises between the firms regarding strategy, Calderwood & Harkness's direction shall control unless Redstone instructs otherwise.

By executing this engagement letter, Redstone authorizes Calderwood & Harkness to share privileged and confidential information, including attorney-client communications and attorney work product, with Thorngate & Associates as reasonably necessary to facilitate the joint representation and the effective defense of the Litigation. Thorngate & Associates will be subject to the same obligations of confidentiality as Calderwood & Harkness with respect to such shared information.

5. Fees and Billing Rates

The Firm will bill for professional services rendered in connection with this engagement on an hourly basis. The current hourly billing rates for the members of the engagement team are as follows:

The Firm's billing rates are subject to periodic adjustment, which typically occurs on an annual basis effective January 1 of each calendar year. Redstone will receive advance written notice of not less than thirty (30) days prior to the effective date of any rate changes. Any adjusted rates will apply to services rendered on or after the effective date of the adjustment.

All professional time will be recorded and billed in increments of one-tenth (1/10) of an hour (i.e., six-minute increments). Detailed descriptions of the services performed will be included in each invoice entry to permit Redstone and its insurer to evaluate the reasonableness and necessity of the time expended.

The Firm reserves the right to assign additional timekeepers — including partners, associates, of counsel attorneys, and paralegals — to the Matter as the needs of the engagement may require. The rates for any additional timekeepers will be commensurate with their experience and seniority, and the Firm will inform Redstone of the applicable billing rates for any such additional timekeepers at the time of their assignment.

6. Expenses and Disbursements

In addition to professional fees for legal services, Redstone will be responsible for the reimbursement of out-of-pocket costs and disbursements reasonably incurred by the Firm in connection with the representation. Such costs and disbursements include, but are not limited to, the following:

(a) Court filing fees, service of process costs, and related court charges;

(b) Travel expenses, including airfare, hotel accommodations, ground transportation (including rental cars, taxis, and rideshare services), parking, and meals incurred in connection with depositions, court hearings, trial, settlement conferences, and other proceedings that require travel;

(c) Expert witness fees and costs, including retainer fees, hourly charges for analysis and testimony, and expenses incurred by experts in connection with their engagement (subject to Redstone's prior approval as set forth in Section 7 below);

(d) Forensic consulting and e-discovery vendor costs, including costs associated with the collection, processing, hosting, review, and production of electronically stored information;

(e) Deposition transcript fees, court reporter charges, and videography fees for depositions taken or defended in the course of the Litigation;

(f) Copying, printing, binding, and document production costs, including costs associated with the preparation of trial exhibits and demonstrative aids;

(g) Overnight delivery charges, courier services, and postage for mailings requiring special handling;

(h) Computerized legal research charges, including charges for services such as Westmark Data Systems, Calderon Systems, PACER, and other research databases; and

(i) Any other reasonable out-of-pocket costs and disbursements incurred in the course of the representation.

For any single expense item or category of related expenses expected to exceed Ten Thousand Dollars ($10,000.00), the Firm will seek Redstone's advance authorization before incurring the expense. The Firm will endeavor to provide Redstone with estimates of significant anticipated expenses in advance where practicable, and will exercise reasonable judgment in managing costs throughout the engagement.

7. Retention of Experts and Consultants

The Firm anticipates that it will be necessary to retain one or more expert witnesses and forensic consultants to support Redstone's defense of the claims asserted in the Litigation. Expert testimony and consulting support are likely to be critical in several areas, including the comparative analysis of the visual assets at issue, the evaluation of Redstone's independent creation defenses, and the authentication and analysis of digital development records.

All expert retentions will be subject to Redstone's advance approval as to the identity of the proposed expert or consultant, the scope of the proposed engagement, and the fee arrangements under which the expert or consultant will be retained. The Firm will present recommendations to Redstone and will not finalize any expert retention without Redstone's written or email authorization.

Expert and consultant fees and expenses will be billed to Redstone as disbursements and will be separate from the Firm's professional fees for legal services. The Firm will pass through expert and consultant invoices at cost, without markup.

At this time, the Firm currently contemplates the following expert engagements:

(a) Digital Media / Game Design Expert: The Firm intends to retain a qualified expert in digital media and interactive entertainment game design to conduct a detailed visual asset comparison analysis of the thirty-seven assets identified in the Luminos complaint, evaluating whether the similarities alleged by Luminos rise to the level of substantial similarity under applicable copyright law, and assessing the extent to which any similarities are attributable to common design conventions, industry-standard techniques, or the merger doctrine.

(b) Digital Forensics Consultant: The Firm intends to retain a digital forensics consultant to perform metadata verification and analysis of Redstone's art pipeline, creation timestamps, version-control records (including the "ironclad-main" Git repository and associated commit histories), and development workflow documentation, in order to establish the independent creation timeline and provenance of Redstone's visual assets.

The Firm may also recommend additional experts or consultants as the Litigation progresses and the specific needs of the defense become further defined. Any such additional retentions will likewise be subject to Redstone's advance approval.

8. Insurance Coordination — Pinnacle Mutual Insurance Co.

Redstone has informed the Firm that defense costs incurred in connection with this Matter may be covered, in whole or in part, under Redstone's media and entertainment liability insurance policy issued by Pinnacle Mutual Insurance Co., located at 200 Commerce Drive, Hartford, Connecticut 06103 (the "Carrier" or "Pinnacle Mutual"). The relevant policy details, as provided by Redstone, are as follows:

Carrier: Pinnacle Mutual Insurance Co.

Policy Number: PML-IP-2023-08841

IP Litigation Sub-Limit: $15,000,000.00 per occurrence

Deductible: $5,000.00 per claim

The Firm will cooperate with Pinnacle Mutual's designated claims adjuster, Franklin Teague (Claim No. PML-CLM-2024-3392), in submitting invoices, billing narratives, and such other documentation as the Carrier reasonably requires in connection with its evaluation and payment of defense costs under the policy. The Firm will comply with any reasonable billing guidelines promulgated by Pinnacle Mutual to the extent consistent with the Firm's professional obligations to Redstone and the effective prosecution of the defense.

The Firm will promptly tender notice of the claim to Pinnacle Mutual on Redstone's behalf, to the extent such notice has not already been provided, and will furnish such additional information as the Carrier reasonably requires in connection with its coverage determination, subject at all times to the preservation of the attorney-client privilege and attorney work-product protections belonging to Redstone.

Redstone acknowledges and understands that the Firm's client in this engagement is Redstone Gaming Corp. and not Pinnacle Mutual Insurance Co. The Firm's professional obligations, including the duties of loyalty, confidentiality, and zealous representation, run solely to Redstone. In the event of any disagreement, dispute, or coverage determination by Pinnacle Mutual that is adverse to Redstone's interests, such circumstances will not affect the Firm's obligation to represent Redstone's interests in the Litigation. The Firm will not accept direction from Pinnacle Mutual that, in the Firm's professional judgment, would be contrary to Redstone's interests.

Redstone remains ultimately responsible for the payment of all professional fees and costs incurred in connection with this engagement, regardless of any coverage determinations, reservation of rights, or coverage disputes between Redstone and Pinnacle Mutual. In the event that Pinnacle Mutual denies coverage, reduces payment, or delays reimbursement, Redstone's obligation to pay the Firm's invoices in accordance with the terms of this engagement letter shall not be diminished or excused.

9. Invoicing and Payment Terms

The Firm will issue itemized monthly invoices detailing professional fees incurred during the preceding billing period, including a description of services rendered, the identity of each timekeeper, the hours worked by each timekeeper, the applicable billing rate, and a summary of all disbursements and out-of-pocket costs. Invoices will be prepared in a format that is consistent with any reasonable billing guidelines provided by Pinnacle Mutual and agreed upon by the Firm.

All invoices are due and payable within thirty (30) days of the invoice date. Invoices will be directed to Priya Venkatesh, General Counsel, at the address set forth at the beginning of this letter, or at such other address (including an electronic billing address) as Redstone may designate in writing from time to time.

The Firm reserves the right to charge interest at the rate of one percent (1.0%) per month (twelve percent (12.0%) per annum) on any balance that remains outstanding for more than sixty (60) days past the invoice due date. The Firm will provide written notice to Redstone before commencing the accrual of interest on any past-due balance.

Redstone may direct the Firm to submit invoices concurrently to Pinnacle Mutual Insurance Co. for direct payment under the applicable insurance policy. The Firm will make reasonable efforts to facilitate prompt payment by the Carrier. However, as noted in Section 8 above, Redstone remains the obligor for any amounts not paid by Pinnacle Mutual, including any amounts subject to the policy deductible, any amounts in excess of the IP Litigation Sub-Limit, or any amounts that the Carrier declines to pay for any reason.

10. Client Responsibilities

Redstone agrees to cooperate fully with the Firm throughout the course of this engagement and to provide, in a timely manner, all information, documents, data, and access to Company personnel as may be reasonably necessary for the Firm to conduct an effective defense of the Litigation. Prompt and thorough cooperation is essential to the Firm's ability to meet court-imposed deadlines, prepare a complete factual record, and develop the strongest possible defense.

Redstone will designate a primary client contact for day-to-day communications relating to the Litigation. For the time being, the designated primary contact will be Priya Venkatesh, General Counsel. If at any time Redstone wishes to designate a different primary contact, it shall provide the Firm with written notice of the change together with the new contact's name, title, email address, and direct telephone number.

Redstone will promptly notify the Firm of any communications received from Luminos Interactive LLC, its counsel of record (Hargrove, Tanaka & Whitmore LLP, led by partner Daniel Hargrove), or any third party relating to the Litigation, including but not limited to settlement overtures, subpoenas served on Redstone or its employees, inquiries from regulatory agencies, and media inquiries relating to the subject matter of the Litigation. All such communications should be forwarded to the Firm without response, unless the Firm has otherwise advised Redstone regarding a particular type of communication.

In connection with the commencement of this Litigation, Redstone will implement and maintain a litigation hold to ensure the identification and preservation of all documents and electronically stored information ("ESI") that are potentially relevant to the claims and defenses asserted in the Litigation. The scope of the litigation hold should include, but not be limited to, the following categories of materials:

(a) All concept art files, digital sketches, texture files, 3D model files, and other visual asset files relating to the development of Ironclad Dominion, including draft, interim, and final versions;

(b) All version-control logs and commit histories, including without limitation the "ironclad-main" Git repository and any branches, forks, or archives thereof;

(c) All internal communications — including emails, instant messages (e.g., Meridian Solutions, Northgate Data Systems, discord), memoranda, and meeting notes — relating to the development, design, and art direction of Ironclad Dominion;

(d) All personnel records, employment agreements, and contractor agreements for members of the creative development team who worked on visual assets for Ironclad Dominion; and

(e) Any other documents or ESI that Redstone reasonably believes may be relevant to the claims, defenses, or damages issues in the Litigation.

The Firm will provide Redstone with a more detailed litigation hold memorandum under separate cover, which will include specific instructions regarding the identification, preservation, and collection of relevant materials.

11. Confidentiality

All communications between Redstone and the Firm in connection with this engagement are intended to be, and shall be treated as, privileged and confidential under the attorney-client privilege and/or the attorney work-product doctrine, to the fullest extent permitted by applicable law. The Firm recognizes the sensitivity of the information that Redstone will share with us during the course of this representation, including proprietary game development processes, trade secrets, financial data, and strategic business information, and the Firm will take all reasonable steps to safeguard such information.

The Firm will not disclose confidential information received from Redstone without Redstone's prior written consent, except as required by law, court order, or applicable rules of professional conduct, or as reasonably necessary in the course of the representation. Disclosures made in the ordinary course of the representation include, without limitation, disclosures to Thorngate & Associates, PC in its capacity as local counsel, and disclosures to retained experts and consultants, in each case subject to appropriate confidentiality agreements or protections. The Firm will ensure that any experts, consultants, or other third parties to whom confidential information is disclosed are bound by appropriate confidentiality obligations before any such disclosure is made.

12. Conflicts of Interest

The Firm has conducted a thorough conflicts check in accordance with its standard procedures and the applicable California Rules of Professional Conduct. Based on the results of that conflicts check, the Firm has identified no conflicts of interest that would preclude or limit this engagement.

To the Firm's knowledge, after reasonable inquiry, neither Calderwood & Harkness LLP nor any of its attorneys, of counsel, or staff currently represents, or has within the past twenty-four months represented, Luminos Interactive LLC, its members, or its principals, including Tobias Crane and Elara Whitfield, in any matter. Similarly, the Firm does not currently represent, and has not recently represented, Hargrove, Tanaka & Whitmore LLP or any of its partners in any matter.

Redstone acknowledges that Calderwood & Harkness LLP is a large, multi-practice law firm with a substantial and diverse client base. Redstone agrees that the Firm may continue to represent, and may in the future undertake to represent, other clients in matters that are unrelated to the subject matter of this engagement and that do not present a direct, material conflict with the interests of Redstone in this Litigation. In the event that a potential conflict of interest arises during the course of this engagement, the Firm will promptly notify Redstone and take all steps required by the applicable rules of professional conduct, including, where appropriate, seeking Redstone's informed written consent to continued representation.

13. Termination of Engagement

Either party may terminate this engagement upon written notice to the other party, subject at all times to the applicable rules of professional conduct governing the termination of the attorney-client relationship and to any orders of the Court that may require the Firm to obtain leave of court before withdrawing from the representation.

In the event of termination by either party, Redstone will remain responsible for the payment of all professional fees and costs incurred through the effective date of termination, in accordance with the fee and billing provisions of this engagement letter. The Firm will prepare and submit a final invoice reflecting all fees and costs incurred through the termination date.

Upon termination, the Firm will promptly return to Redstone, or make available for retrieval, all original client files, documents, and materials in the Firm's possession belonging to Redstone. The Firm may retain copies of such files and documents as reasonably necessary to comply with its professional, ethical, and legal obligations, including document retention requirements.

14. Limitation of Scope

This engagement letter governs only the representation described herein — specifically, the defense of Redstone Gaming Corp. in Luminos Interactive LLC v. Redstone Gaming Corp., Case No. 2:24-cv-00587-RWL, pending in the United States District Court for the District of Nevada.

This engagement does not include representation of Redstone in connection with any appeal from the final judgment or any interlocutory order entered in the Litigation, any related or unrelated legal proceeding (whether judicial, administrative, or arbitral), any regulatory inquiry or investigation, any transactional or corporate advisory matter, or any other matter of any kind unless such representation is separately agreed upon in writing between Calderwood & Harkness and Redstone.

This engagement does not include the provision of tax advice. To the extent that any issue arising in the Litigation may have tax implications for Redstone, Redstone should consult with its tax advisors regarding such matters.

15. Governing Law and Dispute Resolution

This engagement letter shall be governed by and construed in accordance with the laws of the State of California, without regard to principles of conflicts of law.

In the event of any dispute between the Firm and Redstone regarding fees, costs, billing, or any other term or condition of this engagement, the parties agree to first attempt to resolve such dispute through good-faith negotiation between senior representatives of each party. If the parties are unable to resolve the dispute through negotiation within thirty (30) days of written notice of the dispute, the matter shall be submitted to final and binding arbitration administered by JAMS in Los Angeles County, California, in accordance with JAMS' then-current Streamlined Arbitration Rules and Procedures. The arbitrator's decision shall be final and binding on both parties, and judgment on the arbitration award may be entered in any court of competent jurisdiction.

16. Acknowledgment and Acceptance

We are grateful for the trust and confidence that Redstone Gaming Corp. has placed in Calderwood & Harkness LLP, and we look forward to providing you with excellent representation in this important matter. We believe we are well positioned to mount a vigorous and effective defense of the claims asserted by Luminos Interactive LLC, and we are committed to working closely with you and your team throughout the course of this Litigation.

Please review this engagement letter carefully. If the foregoing terms accurately reflect your understanding of our engagement, we respectfully request that you indicate Redstone's acceptance by having an authorized representative sign in the space provided below and return a fully executed copy of this letter to the undersigned. This letter, together with the enclosed Standard Terms of Engagement, supersedes any and all prior oral or written understandings, discussions, or agreements between the Firm and Redstone with respect to the engagement described herein.

We are available at your convenience to discuss any aspect of this letter or the Litigation. Please do not hesitate to contact me directly at (213) 555-8217 or at cbloom@calderwoodharkness.com.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Name: Catherine Bloom

Title: Partner, intellectual Property Litigation Group

Date: April 3, 2024

ACCEPTED AND AGREED

By signing below, the undersigned, on behalf of Redstone Gaming Corp., acknowledges that she has read and understood the foregoing engagement letter, including the enclosed Standard Terms of Engagement incorporated by reference herein, and agrees to be bound by the terms and conditions set forth herein.

REDSTONE GAMING CORP.

By: ________

Name: Priya Venkatesh

Title: General Counsel

Date: ________

Please retain a copy of this letter for your records.

Enclosures:

1. Copy of Complaint, Luminos Interactive LLC v. Redstone Gaming Corp., Case No. 2:24-cv-00587-RWL (filed March 18, 2024)

2. Calderwood & Harkness LLP Standard Terms of Engagement (incorporated by reference)

cc:

Alan Ngo, Calderwood & Harkness LLP Omar Siddiqui, Calderwood & Harkness LLP Patricia Thorngate, Thorngate & Associates, PC Franklin Teague, Claims Adjuster, Pinnacle Mutual Insurance Co. (re: Claim No. PML-CLM-2024-3392)

Timekeeper	Role	Current Hourly Rate
Catherine Bloom	Partner	$1,150.00
Alan Ngo	Partner	$1,100.00
Omar Siddiqui	Senior Associate	$725.00
Christy Bauer	Associate	$575.00
Paralegals / E-discovery Support	Blended Rate	$295.00

CALDERWOOD & HARKNESS LLP Attorneys at Law 600 South Grand Avenue, Suite 4400 Los Angeles, California 90071 Telephone: (213) 555-8200 Facsimile: (213) 555-8201 www.calderwoodharkness.com
April 3, 2024
Priya Venkatesh, Esq. General Counsel Redstone Gaming Corp. 4100 Obsidian Tower Boulevard, Suite 2200 Las Vegas, NV 89109
Re: Engagement of Calderwood & Harkness LLP — Defense of Luminos Interactive LLC v. Redstone Gaming Corp., Case No. 2:24-cv-00587-RWL, United States District Court for the District of Nevada
Matter No.: 1033-00004
Dear Ms. Venkatesh:
1. Introduction and Purpose
Thank you for selecting Calderwood & Harkness LLP (the "Firm," "we," or "us") to represent Redstone Gaming Corp. ("Redstone," "RGC," or the "Company") in the above-referenced matter. We are pleased to have the opportunity to work with you and your team, and we are committed to providing Redstone with the highest quality legal representation.
The purpose of this letter is to confirm the terms and conditions upon which the Firm will represent Redstone in connection with the defense of the claims asserted by Luminos Interactive LLC ("Luminos"), a Texas limited liability company, in the above-captioned lawsuit. As you are aware, Luminos filed a complaint on March 18, 2024, in the United States District Court for the District of Nevada, alleging copyright infringement arising from certain visual assets incorporated in Redstone's multiplayer title Ironclad Dominion. The case has been assigned to the Honorable Rebecca W. Langford.
This engagement letter, together with the Firm's Standard Terms of Engagement enclosed herewith and incorporated by reference, constitutes the entire agreement between the Firm and Redstone with respect to this engagement. We ask that you please review this letter carefully and, if you agree to the terms set forth herein, countersign and return a copy to the undersigned at your earliest convenience so that we may formally commence our representation. We are happy to discuss any questions or concerns you may have regarding any provision of this letter.
2. Scope of Representation
Calderwood & Harkness LLP is engaged to represent Redstone Gaming Corp. in defending against the copyright infringement claims asserted by Luminos Interactive LLC in Luminos Interactive LLC v. Redstone Gaming Corp., Case No. 2:24-cv-00587-RWL, pending in the United States District Court for the District of Nevada (the "Litigation" or the "Matter").
The scope of this engagement encompasses all aspects of the defense of the Litigation, including without limitation: all pretrial proceedings, responsive pleadings, discovery (both written and oral), motion practice (including dispositive motions), trial preparation, trial (if necessary), and any post-trial motions filed during the pendency of the trial court proceedings. Specifically, the Luminos complaint alleges that thirty-seven (37) specific visual assets contained in Redstone's multiplayer online game Ironclad Dominion are substantially similar to corresponding assets found in Luminos's title Shardfall Chronicles. These thirty-seven assets are categorized in the complaint as follows:
(a) Twelve (12) character armor designs (identified in the complaint as Exhibits A-1 through A-12);
(b) Nine (9) environmental crystal textures (identified in the complaint as Exhibits B-1 through B-9);
(c) Eight (8) user-interface ("UI") icon sets (identified in the complaint as Exhibits C-1 through C-8); and
(d) Eight (8) background matte paintings (identified in the complaint as Exhibits D-1 through D-8).
Luminos seeks injunctive relief prohibiting the continued use, display, and distribution of the allegedly infringing assets, actual damages in the amount of Twenty-Eight Million Five Hundred Thousand Dollars ($28,500,000.00), statutory damages in the alternative pursuant to 17 U.S.C. § 504(c), and an award of attorney's fees and costs pursuant to 17 U.S.C. § 505.
The scope of this engagement does not extend to any other litigation, regulatory, transactional, intellectual property prosecution, licensing, or advisory matter involving Redstone unless separately agreed upon in writing between the parties. Additionally, any expansion of the scope of this engagement — including, without limitation, the assertion of counterclaims against Luminos, the filing of cross-claims or third-party claims, joinder of additional parties, or representation in any related proceedings or investigations — will require a separate written agreement or a written amendment to this engagement letter executed by both parties.
3. Engagement Team
The following attorneys will comprise the primary engagement team responsible for the day-to-day management and prosecution of Redstone's defense in this Matter:
Catherine Bloom — Responsible Partner, intellectual Property Litigation Group. Ms. Bloom will serve as the lead partner with overall supervisory responsibility for the Matter. She will direct litigation strategy, oversee all substantive work product, and serve as the primary point of contact for the Company. Ms. Bloom has over twenty-two years of experience representing major technology and entertainment companies in high-stakes intellectual property disputes, including copyright, trade secret, and patent litigation in federal courts throughout the United States.
Alan Ngo — Billing Partner, intellectual Property Litigation Group. Mr. Ngo will serve as the billing partner for this engagement and will be responsible for all fee arrangements, invoicing, billing-related communications, and financial administration of the Matter. Mr. Ngo will also provide substantive support on complex copyright and digital media issues as needed.
Omar Siddiqui — Lead Associate, intellectual Property Litigation Group. Mr. Siddiqui will manage day-to-day litigation activities under Ms. Bloom's supervision. His responsibilities will include drafting and filing pleadings and motions, conducting and responding to written discovery, preparing for and attending depositions, and coordinating with expert witnesses, forensic consultants, and local counsel. Mr. Siddiqui brings extensive experience in copyright infringement litigation, with particular expertise in the interactive entertainment and digital media industries.
Christy Bauer — Working Associate, intellectual Property Litigation Group. Ms. Bauer will provide research, analysis, and drafting support across all phases of the Litigation. Her responsibilities will include legal research and memoranda preparation, document and e-discovery review, deposition preparation, and motion drafting. Ms. Bauer has significant experience in large-scale document review and e-discovery protocols relevant to digital content and software development matters.
From time to time, additional attorneys, paralegals, litigation support professionals, and other support staff may be assigned to the Matter as reasonably necessary to provide efficient and effective representation. The Firm will notify Redstone of any material changes to the core engagement team, including the addition of any new attorneys who are expected to have a significant role in the Matter.
4. Local Counsel
Due to the filing of this action in the United States District Court for the District of Nevada, the Firm will coordinate with Thorngate & Associates, PC (300 South Fourth Street, Suite 1100, Las Vegas, Nevada 89101) to serve as local Nevada counsel for Redstone in the Litigation. The engagement with Thorngate & Associates will be led by Patricia Thorngate, Esq., the firm's principal, who is admitted to practice before the District of Nevada and is well acquainted with the local rules, practices, and procedures of that court.
Thorngate & Associates will be responsible for handling all local filings with the Clerk of Court for the District of Nevada, attending local court appearances and status conferences in Las Vegas (whether in person or by telephone/video as directed by the Court), and coordinating with chambers on scheduling and procedural matters. Thorngate & Associates will work closely with our team and will be kept fully apprised of all strategic decisions and developments in the Litigation.
Thorngate & Associates will bill Redstone separately under its own engagement arrangement, the terms of which will be set forth in a separate engagement letter between Redstone and Thorngate & Associates. Notwithstanding this separate billing arrangement, all substantive legal strategy and direction of the Litigation will be coordinated and directed by Calderwood & Harkness LLP. To the extent any disagreement arises between the firms regarding strategy, Calderwood & Harkness's direction shall control unless Redstone instructs otherwise.
By executing this engagement letter, Redstone authorizes Calderwood & Harkness to share privileged and confidential information, including attorney-client communications and attorney work product, with Thorngate & Associates as reasonably necessary to facilitate the joint representation and the effective defense of the Litigation. Thorngate & Associates will be subject to the same obligations of confidentiality as Calderwood & Harkness with respect to such shared information.
5. Fees and Billing Rates
The Firm will bill for professional services rendered in connection with this engagement on an hourly basis. The current hourly billing rates for the members of the engagement team are as follows:
The Firm's billing rates are subject to periodic adjustment, which typically occurs on an annual basis effective January 1 of each calendar year. Redstone will receive advance written notice of not less than thirty (30) days prior to the effective date of any rate changes. Any adjusted rates will apply to services rendered on or after the effective date of the adjustment.
All professional time will be recorded and billed in increments of one-tenth (1/10) of an hour (i.e., six-minute increments). Detailed descriptions of the services performed will be included in each invoice entry to permit Redstone and its insurer to evaluate the reasonableness and necessity of the time expended.
The Firm reserves the right to assign additional timekeepers — including partners, associates, of counsel attorneys, and paralegals — to the Matter as the needs of the engagement may require. The rates for any additional timekeepers will be commensurate with their experience and seniority, and the Firm will inform Redstone of the applicable billing rates for any such additional timekeepers at the time of their assignment.
6. Expenses and Disbursements
In addition to professional fees for legal services, Redstone will be responsible for the reimbursement of out-of-pocket costs and disbursements reasonably incurred by the Firm in connection with the representation. Such costs and disbursements include, but are not limited to, the following:
(a) Court filing fees, service of process costs, and related court charges;
(b) Travel expenses, including airfare, hotel accommodations, ground transportation (including rental cars, taxis, and rideshare services), parking, and meals incurred in connection with depositions, court hearings, trial, settlement conferences, and other proceedings that require travel;
(c) Expert witness fees and costs, including retainer fees, hourly charges for analysis and testimony, and expenses incurred by experts in connection with their engagement (subject to Redstone's prior approval as set forth in Section 7 below);
(d) Forensic consulting and e-discovery vendor costs, including costs associated with the collection, processing, hosting, review, and production of electronically stored information;
(e) Deposition transcript fees, court reporter charges, and videography fees for depositions taken or defended in the course of the Litigation;
(f) Copying, printing, binding, and document production costs, including costs associated with the preparation of trial exhibits and demonstrative aids;
(g) Overnight delivery charges, courier services, and postage for mailings requiring special handling;
(h) Computerized legal research charges, including charges for services such as Westmark Data Systems, Calderon Systems, PACER, and other research databases; and
(i) Any other reasonable out-of-pocket costs and disbursements incurred in the course of the representation.
For any single expense item or category of related expenses expected to exceed Ten Thousand Dollars ($10,000.00), the Firm will seek Redstone's advance authorization before incurring the expense. The Firm will endeavor to provide Redstone with estimates of significant anticipated expenses in advance where practicable, and will exercise reasonable judgment in managing costs throughout the engagement.
7. Retention of Experts and Consultants
The Firm anticipates that it will be necessary to retain one or more expert witnesses and forensic consultants to support Redstone's defense of the claims asserted in the Litigation. Expert testimony and consulting support are likely to be critical in several areas, including the comparative analysis of the visual assets at issue, the evaluation of Redstone's independent creation defenses, and the authentication and analysis of digital development records.
All expert retentions will be subject to Redstone's advance approval as to the identity of the proposed expert or consultant, the scope of the proposed engagement, and the fee arrangements under which the expert or consultant will be retained. The Firm will present recommendations to Redstone and will not finalize any expert retention without Redstone's written or email authorization.
Expert and consultant fees and expenses will be billed to Redstone as disbursements and will be separate from the Firm's professional fees for legal services. The Firm will pass through expert and consultant invoices at cost, without markup.
At this time, the Firm currently contemplates the following expert engagements:
(a) Digital Media / Game Design Expert: The Firm intends to retain a qualified expert in digital media and interactive entertainment game design to conduct a detailed visual asset comparison analysis of the thirty-seven assets identified in the Luminos complaint, evaluating whether the similarities alleged by Luminos rise to the level of substantial similarity under applicable copyright law, and assessing the extent to which any similarities are attributable to common design conventions, industry-standard techniques, or the merger doctrine.
(b) Digital Forensics Consultant: The Firm intends to retain a digital forensics consultant to perform metadata verification and analysis of Redstone's art pipeline, creation timestamps, version-control records (including the "ironclad-main" Git repository and associated commit histories), and development workflow documentation, in order to establish the independent creation timeline and provenance of Redstone's visual assets.
The Firm may also recommend additional experts or consultants as the Litigation progresses and the specific needs of the defense become further defined. Any such additional retentions will likewise be subject to Redstone's advance approval.
8. Insurance Coordination — Pinnacle Mutual Insurance Co.
Redstone has informed the Firm that defense costs incurred in connection with this Matter may be covered, in whole or in part, under Redstone's media and entertainment liability insurance policy issued by Pinnacle Mutual Insurance Co., located at 200 Commerce Drive, Hartford, Connecticut 06103 (the "Carrier" or "Pinnacle Mutual"). The relevant policy details, as provided by Redstone, are as follows:
Carrier: Pinnacle Mutual Insurance Co.
Policy Number: PML-IP-2023-08841
IP Litigation Sub-Limit: $15,000,000.00 per occurrence
Deductible: $5,000.00 per claim
The Firm will cooperate with Pinnacle Mutual's designated claims adjuster, Franklin Teague (Claim No. PML-CLM-2024-3392), in submitting invoices, billing narratives, and such other documentation as the Carrier reasonably requires in connection with its evaluation and payment of defense costs under the policy. The Firm will comply with any reasonable billing guidelines promulgated by Pinnacle Mutual to the extent consistent with the Firm's professional obligations to Redstone and the effective prosecution of the defense.
The Firm will promptly tender notice of the claim to Pinnacle Mutual on Redstone's behalf, to the extent such notice has not already been provided, and will furnish such additional information as the Carrier reasonably requires in connection with its coverage determination, subject at all times to the preservation of the attorney-client privilege and attorney work-product protections belonging to Redstone.
Redstone acknowledges and understands that the Firm's client in this engagement is Redstone Gaming Corp. and not Pinnacle Mutual Insurance Co. The Firm's professional obligations, including the duties of loyalty, confidentiality, and zealous representation, run solely to Redstone. In the event of any disagreement, dispute, or coverage determination by Pinnacle Mutual that is adverse to Redstone's interests, such circumstances will not affect the Firm's obligation to represent Redstone's interests in the Litigation. The Firm will not accept direction from Pinnacle Mutual that, in the Firm's professional judgment, would be contrary to Redstone's interests.
Redstone remains ultimately responsible for the payment of all professional fees and costs incurred in connection with this engagement, regardless of any coverage determinations, reservation of rights, or coverage disputes between Redstone and Pinnacle Mutual. In the event that Pinnacle Mutual denies coverage, reduces payment, or delays reimbursement, Redstone's obligation to pay the Firm's invoices in accordance with the terms of this engagement letter shall not be diminished or excused.
9. Invoicing and Payment Terms
The Firm will issue itemized monthly invoices detailing professional fees incurred during the preceding billing period, including a description of services rendered, the identity of each timekeeper, the hours worked by each timekeeper, the applicable billing rate, and a summary of all disbursements and out-of-pocket costs. Invoices will be prepared in a format that is consistent with any reasonable billing guidelines provided by Pinnacle Mutual and agreed upon by the Firm.
All invoices are due and payable within thirty (30) days of the invoice date. Invoices will be directed to Priya Venkatesh, General Counsel, at the address set forth at the beginning of this letter, or at such other address (including an electronic billing address) as Redstone may designate in writing from time to time.
The Firm reserves the right to charge interest at the rate of one percent (1.0%) per month (twelve percent (12.0%) per annum) on any balance that remains outstanding for more than sixty (60) days past the invoice due date. The Firm will provide written notice to Redstone before commencing the accrual of interest on any past-due balance.
Redstone may direct the Firm to submit invoices concurrently to Pinnacle Mutual Insurance Co. for direct payment under the applicable insurance policy. The Firm will make reasonable efforts to facilitate prompt payment by the Carrier. However, as noted in Section 8 above, Redstone remains the obligor for any amounts not paid by Pinnacle Mutual, including any amounts subject to the policy deductible, any amounts in excess of the IP Litigation Sub-Limit, or any amounts that the Carrier declines to pay for any reason.
10. Client Responsibilities
Redstone agrees to cooperate fully with the Firm throughout the course of this engagement and to provide, in a timely manner, all information, documents, data, and access to Company personnel as may be reasonably necessary for the Firm to conduct an effective defense of the Litigation. Prompt and thorough cooperation is essential to the Firm's ability to meet court-imposed deadlines, prepare a complete factual record, and develop the strongest possible defense.
Redstone will designate a primary client contact for day-to-day communications relating to the Litigation. For the time being, the designated primary contact will be Priya Venkatesh, General Counsel. If at any time Redstone wishes to designate a different primary contact, it shall provide the Firm with written notice of the change together with the new contact's name, title, email address, and direct telephone number.
Redstone will promptly notify the Firm of any communications received from Luminos Interactive LLC, its counsel of record (Hargrove, Tanaka & Whitmore LLP, led by partner Daniel Hargrove), or any third party relating to the Litigation, including but not limited to settlement overtures, subpoenas served on Redstone or its employees, inquiries from regulatory agencies, and media inquiries relating to the subject matter of the Litigation. All such communications should be forwarded to the Firm without response, unless the Firm has otherwise advised Redstone regarding a particular type of communication.
In connection with the commencement of this Litigation, Redstone will implement and maintain a litigation hold to ensure the identification and preservation of all documents and electronically stored information ("ESI") that are potentially relevant to the claims and defenses asserted in the Litigation. The scope of the litigation hold should include, but not be limited to, the following categories of materials:
(a) All concept art files, digital sketches, texture files, 3D model files, and other visual asset files relating to the development of Ironclad Dominion, including draft, interim, and final versions;
(b) All version-control logs and commit histories, including without limitation the "ironclad-main" Git repository and any branches, forks, or archives thereof;
(c) All internal communications — including emails, instant messages (e.g., Meridian Solutions, Northgate Data Systems, discord), memoranda, and meeting notes — relating to the development, design, and art direction of Ironclad Dominion;
(d) All personnel records, employment agreements, and contractor agreements for members of the creative development team who worked on visual assets for Ironclad Dominion; and
(e) Any other documents or ESI that Redstone reasonably believes may be relevant to the claims, defenses, or damages issues in the Litigation.
The Firm will provide Redstone with a more detailed litigation hold memorandum under separate cover, which will include specific instructions regarding the identification, preservation, and collection of relevant materials.
11. Confidentiality
All communications between Redstone and the Firm in connection with this engagement are intended to be, and shall be treated as, privileged and confidential under the attorney-client privilege and/or the attorney work-product doctrine, to the fullest extent permitted by applicable law. The Firm recognizes the sensitivity of the information that Redstone will share with us during the course of this representation, including proprietary game development processes, trade secrets, financial data, and strategic business information, and the Firm will take all reasonable steps to safeguard such information.
The Firm will not disclose confidential information received from Redstone without Redstone's prior written consent, except as required by law, court order, or applicable rules of professional conduct, or as reasonably necessary in the course of the representation. Disclosures made in the ordinary course of the representation include, without limitation, disclosures to Thorngate & Associates, PC in its capacity as local counsel, and disclosures to retained experts and consultants, in each case subject to appropriate confidentiality agreements or protections. The Firm will ensure that any experts, consultants, or other third parties to whom confidential information is disclosed are bound by appropriate confidentiality obligations before any such disclosure is made.
12. Conflicts of Interest
The Firm has conducted a thorough conflicts check in accordance with its standard procedures and the applicable California Rules of Professional Conduct. Based on the results of that conflicts check, the Firm has identified no conflicts of interest that would preclude or limit this engagement.
To the Firm's knowledge, after reasonable inquiry, neither Calderwood & Harkness LLP nor any of its attorneys, of counsel, or staff currently represents, or has within the past twenty-four months represented, Luminos Interactive LLC, its members, or its principals, including Tobias Crane and Elara Whitfield, in any matter. Similarly, the Firm does not currently represent, and has not recently represented, Hargrove, Tanaka & Whitmore LLP or any of its partners in any matter.
Redstone acknowledges that Calderwood & Harkness LLP is a large, multi-practice law firm with a substantial and diverse client base. Redstone agrees that the Firm may continue to represent, and may in the future undertake to represent, other clients in matters that are unrelated to the subject matter of this engagement and that do not present a direct, material conflict with the interests of Redstone in this Litigation. In the event that a potential conflict of interest arises during the course of this engagement, the Firm will promptly notify Redstone and take all steps required by the applicable rules of professional conduct, including, where appropriate, seeking Redstone's informed written consent to continued representation.
13. Termination of Engagement
Either party may terminate this engagement upon written notice to the other party, subject at all times to the applicable rules of professional conduct governing the termination of the attorney-client relationship and to any orders of the Court that may require the Firm to obtain leave of court before withdrawing from the representation.
In the event of termination by either party, Redstone will remain responsible for the payment of all professional fees and costs incurred through the effective date of termination, in accordance with the fee and billing provisions of this engagement letter. The Firm will prepare and submit a final invoice reflecting all fees and costs incurred through the termination date.
Upon termination, the Firm will promptly return to Redstone, or make available for retrieval, all original client files, documents, and materials in the Firm's possession belonging to Redstone. The Firm may retain copies of such files and documents as reasonably necessary to comply with its professional, ethical, and legal obligations, including document retention requirements.
14. Limitation of Scope
This engagement letter governs only the representation described herein — specifically, the defense of Redstone Gaming Corp. in Luminos Interactive LLC v. Redstone Gaming Corp., Case No. 2:24-cv-00587-RWL, pending in the United States District Court for the District of Nevada.
This engagement does not include representation of Redstone in connection with any appeal from the final judgment or any interlocutory order entered in the Litigation, any related or unrelated legal proceeding (whether judicial, administrative, or arbitral), any regulatory inquiry or investigation, any transactional or corporate advisory matter, or any other matter of any kind unless such representation is separately agreed upon in writing between Calderwood & Harkness and Redstone.
This engagement does not include the provision of tax advice. To the extent that any issue arising in the Litigation may have tax implications for Redstone, Redstone should consult with its tax advisors regarding such matters.
15. Governing Law and Dispute Resolution
This engagement letter shall be governed by and construed in accordance with the laws of the State of California, without regard to principles of conflicts of law.
In the event of any dispute between the Firm and Redstone regarding fees, costs, billing, or any other term or condition of this engagement, the parties agree to first attempt to resolve such dispute through good-faith negotiation between senior representatives of each party. If the parties are unable to resolve the dispute through negotiation within thirty (30) days of written notice of the dispute, the matter shall be submitted to final and binding arbitration administered by JAMS in Los Angeles County, California, in accordance with JAMS' then-current Streamlined Arbitration Rules and Procedures. The arbitrator's decision shall be final and binding on both parties, and judgment on the arbitration award may be entered in any court of competent jurisdiction.
16. Acknowledgment and Acceptance
We are grateful for the trust and confidence that Redstone Gaming Corp. has placed in Calderwood & Harkness LLP, and we look forward to providing you with excellent representation in this important matter. We believe we are well positioned to mount a vigorous and effective defense of the claims asserted by Luminos Interactive LLC, and we are committed to working closely with you and your team throughout the course of this Litigation.
Please review this engagement letter carefully. If the foregoing terms accurately reflect your understanding of our engagement, we respectfully request that you indicate Redstone's acceptance by having an authorized representative sign in the space provided below and return a fully executed copy of this letter to the undersigned. This letter, together with the enclosed Standard Terms of Engagement, supersedes any and all prior oral or written understandings, discussions, or agreements between the Firm and Redstone with respect to the engagement described herein.
We are available at your convenience to discuss any aspect of this letter or the Litigation. Please do not hesitate to contact me directly at (213) 555-8217 or at cbloom@calderwoodharkness.com.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Name: Catherine Bloom
Title: Partner, intellectual Property Litigation Group
Date: April 3, 2024
ACCEPTED AND AGREED
By signing below, the undersigned, on behalf of Redstone Gaming Corp., acknowledges that she has read and understood the foregoing engagement letter, including the enclosed Standard Terms of Engagement incorporated by reference herein, and agrees to be bound by the terms and conditions set forth herein.
REDSTONE GAMING CORP.
By: ________
Name: Priya Venkatesh
Title: General Counsel
Date: ________
Please retain a copy of this letter for your records.
Enclosures:
1.  Copy of Complaint, Luminos Interactive LLC v. Redstone Gaming Corp., Case No. 2:24-cv-00587-RWL (filed March 18, 2024)
2.  Calderwood & Harkness LLP Standard Terms of Engagement (incorporated by reference)
cc:
Alan Ngo, Calderwood & Harkness LLP Omar Siddiqui, Calderwood & Harkness LLP Patricia Thorngate, Thorngate & Associates, PC Franklin Teague, Claims Adjuster, Pinnacle Mutual Insurance Co. (re: Claim No. PML-CLM-2024-3392)
Timekeeper | Role | Current Hourly Rate
Catherine Bloom | Partner | $1,150.00
Alan Ngo | Partner | $1,100.00
Omar Siddiqui | Senior Associate | $725.00
Christy Bauer | Associate | $575.00
Paralegals / E-discovery Support | Blended Rate | $295.00

CALDERWOOD & HARKNESS LLP

ACCEPTED AND AGREED

REDSTONE GAMING CORP.

Record

Parties

Dates

Amounts