Common use of Release, Discharge, and Covenant Not to Sue Clause in Contracts

Release, Discharge, and Covenant Not to Sue. 30. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement, the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now have, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning the Released Part (“Released Claims”), provided, however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released Part; (2) claims based on negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released Part; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.

Release, Discharge, and Covenant Not to Sue. 30. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement, the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ ' fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now have, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning the Released Part (“Released Claims”), provided, however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released Part; (2) claims based on negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released Part; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.

Release, Discharge, and Covenant Not to Sue. 3022. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement20, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement24, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Accounts (defined below), and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, state or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct alleged in the Complaints or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of the them), concerning Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred including but not limited to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, or that could have been alleged or asserted, in any class action or other complaints filed asserted in the Action concerning the Released Part Actions (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartBearings or Electronic Powered Steering Assemblies as to such direct purchases; (2) any claims based on made by End-Payor Plaintiffs that are indirect purchasers of Bearings or Electronic Powered Steering Assemblies; (3) any claims made by truck and equipment dealerships that are indirect purchasers of Bearings or Electronic Powered Steering Assemblies; (4) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartBearings or Electronic Powered Steering Assemblies; (36) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Bearings or Electronic Powered Steering Assemblies; (47) claims under laws other than those of the United States relating to purchases of Bearings or Electronic Powered Steering Assemblies made by Releasors of the Released Part outside of the United States; and (5) 8) damage claims concerning under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effectiveClaims.

Release, Discharge, and Covenant Not to Sue. 3022. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 20 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 24 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, state or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct alleged in the Complaint or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of the Releaseesthem), Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred concerning Automotive Wire Harness Systems including but not limited to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartAutomotive Wire Harness Systems as to such direct purchasers; (2) any claims based on made by automotive dealerships that are indirect purchasers of Automotive Wire Harness Systems; (3) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartAutomotive Wire Harness Systems; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Automotive Wire Harness Systems; (46) claims under laws other than those of the United States relating to purchases of Automotive Wire Harness Systems made by Releasors of the Released Part outside of the United States; and (57) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effectiveClaims.

Release, Discharge, and Covenant Not to Sue. 3019. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement17, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement21, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A, and for other valuable considerationEscrow Account (defined below), the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), ) and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively derivatively, or in any other capacity) ), under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any act, omission, conduct, facts, occurrences, or transactions of the Releasees, Defendants and/or alleged co-conspirators prior to the Execution Date concerning the Released Part, or to any act or omission of any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, describedreferred to, or referred to described in the Complaint Complaint, or in any future complaint concerning the Released Partprice fixing, bid rigging, or market, customer, or supply allocation of Ignition Coils, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released PartIgnition Coils; (2) claims based on any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim claims relating to the Released PartIgnition Coils; (3) claims brought outside the United States relating to purchases of the Released Part Ignition Coils outside the United States; (4) claims brought under laws other than those of the United States relating to purchases made by Releasors of the Released Part Ignition Coils outside of the United States; and (5) claims concerning any product other than the Released PartIgnition Coils. The Releasors covenant and agree that they, and each of them, will forever refrain shall not, after the date of this Agreement, seek to establish liability against or recover from institutingany Releasee based, maintainingin whole or in part, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with upon any of the Released Claims unless this Agreementthe Agreement is, for any reason, does not become finalfinally approved, or is rescinded terminated, or otherwise fails to become effective.

Release, Discharge, and Covenant Not to Sue. 3021. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement19, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement24, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Account (defined below), and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct prior to the Execution Date alleged in the Complaint, facts, occurrences, and (ii) any act or transactions omission of the Releasees (or any of them) prior to the Execution Date concerning the Released Partprice fixing, bid rigging, or market, customer, or supply allocation of Fuel Injection Systems, or any similar activity related to Fuel Injection Systems, including but not limited to any act or omission of any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released Part, including any conduct alleged and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint(s) filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released PartFuel Injection Systems; (2) claims based on involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartFuel Injection Systems; (3) claims brought outside the United States relating to purchases of the Released Part Fuel Injection Systems outside the United States; (4) claims brought under laws other than those of the United States relating to purchases made by Releasors of the Released Part Fuel Injection Systems outside of the United States; and (5) claims concerning any product other than Fuel Injection Systems. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.

Release, Discharge, and Covenant Not to Sue. 3023. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 21 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 25 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaint, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releaseesthem) concerning Access Mechanisms, Defendantsincluding, or co-conspirators now identified or later identified that are allegedbut not limited to, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartAccess Mechanisms; (2) any claims based on negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released Part; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors automotive dealerships that are indirect purchasers of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.Access Mechanisms;

Release, Discharge, and Covenant Not to Sue. 3017. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement15, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement20, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Account (defined below), and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and or unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct or transactions omission of the Releasees prior to the Execution Date concerning alleged in the Released PartComplaint, or to in any act or omission of any of the Releaseesfuture complaint concerning price fixing, Defendantsbid rigging, or co-conspirators now identified or later identified that are allegedmarket, describedcustomer, or referred to in the Complaint concerning the Released Partsupply allocation of Power Window Switches, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released PartPower Window Switches; (2) claims based on involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartPower Window Switches; (3) claims brought outside the United States relating to purchases of the Released Part Power Window Switches outside the United States; (4) claims brought under laws other than those of the United States relating to purchases made by Releasors of the Released Part Power Window Switches outside of the United States; and (5) claims concerning any product other than Power Window Switches. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.

Release, Discharge, and Covenant Not to Sue. 3021. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement19, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement23, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Account (defined below), and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct prior to the Execution Date alleged in the Complaint, facts, occurrences, and (ii) any act or transactions omission of the Releasees (or any of them) prior to the Execution Date concerning the Released PartFuel Injection Systems, or including but not limited to any act or omission of any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released Part, including any conduct alleged and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint(s) filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released PartFuel Injection Systems; (2) claims based on involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartFuel Injection Systems; (3) claims brought outside the United States relating to purchases of the Released Part Fuel Injection Systems outside the United States; (4) claims brought under laws other than those of the United States relating to purchases made by Releasors of the Released Part Fuel Injection Systems outside of the United States; and (5) claims concerning any product other than Fuel Injection Systems. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.

Release, Discharge, and Covenant Not to Sue. 3021. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement19, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement, the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A23, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement FundAmount, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct alleged in the Complaint or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of the Releaseesthem), Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released PartAutomotive Wire Harness Systems, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning (the Released Part (“Released Claims”), provided, however, that nothing . Nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartAutomotive Wire Harness Systems as to such direct purchasers; (2) any claims based on made by automotive dealerships that are indirect purchasers of Automotive Wire Harness Systems; (3) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released PartAutomotive Wire Harness Systems; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Automotive Wire Harness Systems; (46) claims under laws other than those of the United States relating to purchases of Automotive Wire Harness Systems made by Releasors of the Released Part outside of the United States; and (57) claims concerning under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreementthe Agreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3021. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 18 of this Agreement, and in consideration of payment of the Settlement Amount, Amount as specified in Paragraph 32 23 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Account (defined below), and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement this Agreement or makes a claim upon or receives a payment from participates in the below-described Settlement Fund, Funds whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct alleged in the Complaints or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of the Releaseesthem) concerning Anti- Vibration Rubber Products or Automotive Hoses, Defendants, or co-conspirators now identified or later identified that are including but not limited to any conduct alleged, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action Actions concerning the Released Part Anti-Vibration Rubber Products or Automotive Hoses (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartAnti-Vibration Rubber Parts or Automotive Hoses as to such direct purchasers; (2) any claims based on made by automotive dealerships that are indirect purchasers of Anti-Vibration Rubber Parts or Automotive Hoses; (3) any claims made by truck and equipment dealerships that are indirect purchasers of Anti-Vibration Rubber Parts or Automotive Hoses; (4) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartAnti-Vibration Rubber Parts or Automotive Hoses; (36) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Anti-Vibration Rubber Parts or Automotive Hoses; (47) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United StatesStates of Vehicles containing Anti-Vibration Rubber Parts or Automotive Hoses; and (5) 8) damage claims concerning under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effectiveClaims.

Release, Discharge, and Covenant Not to Sue. 3022. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement20, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement24, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Accounts (defined below), and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, state or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct alleged in the Complaints or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of the them), concerning Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred including but not limited to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, or that could have been alleged or asserted, in any class action or other complaints filed asserted in the Action concerning the Released Part Actions (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartBearings or Electronic Powered Steering Assemblies as to such direct purchases; (2) any claims based on made by automotive dealerships that are indirect purchasers of Bearings or Electronic Powered Steering Assemblies; (3) any claims made by truck and equipment dealerships that are indirect purchasers of Bearings or Electronic Powered Steering Assemblies; (4) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartBearings or Electronic Powered Steering Assemblies; (36) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Bearings or Electronic Powered Steering Assemblies; (47) claims under laws other than those of the United States relating to purchases of Bearings or Electronic Powered Steering Assemblies made by Releasors of the Released Part outside of the United States; and (5) 8) damage claims concerning under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effectiveClaims.

Release, Discharge, and Covenant Not to Sue. 3023. In addition to the effect of any final judgment judgments entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 21 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 25 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Funds, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement FundFunds, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, or any other costs, penalties, or expenses, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaints, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint them) concerning the Released Partany Relevant Product, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning the Released Part Actions (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released Partany Relevant Product as to such direct purchases; (2) any claims based on made by automotive dealerships that are indirect purchasers of any Relevant Product; (3) any claims made by truck and equipment dealerships that are indirect purchasers of any Relevant Product; (4) any claims made by any State, State agency, or instrumentality or political subdivision of a State as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released Partany Relevant Product; (36) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than any Relevant Product; (47) claims under laws other than those of the United States relating to purchases of any Relevant Product made by Releasors of the Released Part any Releasor outside of the United States; and (5) 8) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3022. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement20, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement, the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A24, and for other valuable consideration, the Releasees shall be Releasors completely releasedrelease, acquittedacquit, and forever discharged discharge Releasees from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs)proceedings, and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement FundAmount, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common local law or regulation of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, related to, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of them) concerning the Releaseespricing, Defendantsproduction, development, marketing, or cosale of Parking Heaters or products containing Parking Heaters up to and through June 12, 2017, which relate in any way to alleged anti-conspirators now identified or later identified that competitive activity involving Parking Heaters including claims which are alleged, described, or referred to in based on the Complaint concerning the Released Part, including any conduct alleged and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in the Indirect-Purchaser Complaint, or in any class similar action or other complaints filed in any federal or state court, including, without limitation, any claims arising under any federal or state antitrust, unjust enrichment, unfair competition, trade practice statutory or common law, and consumer protection law (to the Action concerning extent that a consumer protection claim would be based on allegations of an antitrust or unfair competition violation) (the Released Part (“Released Claims”). Releasors shall not, providedafter the date of this Agreement, howeverseek to establish liability against any Releasee based, in whole or in part, on any of the Released Claims or conduct at issue in the Released Claims, unless this Agreement is terminated or not finally approved. The Settling Parties contemplate and agree that nothing this Agreement may be pleaded as a bar to a lawsuit, and an injunction may be obtained, preventing any action from being initiated or maintained in any case sought to be prosecuted on behalf of Releasors with respect to the Released Claims. Nothing herein shall release: (1i) any claims based on indirect purchases made by direct-purchasers of the Released PartParking Heaters as to such direct purchases; (2ii) any claims made by any federal or state agency, or instrumentality or political subdivision, as to government purchases and/or penalties; (iii) claims based on negligence, involving any personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, or product defect, breach of product warranty, securities, or other similar claim defect claims relating to the Released PartParking Heaters; and (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4iv) claims under laws other than those of the United States or its several states relating to purchases of Parking Heaters made by Releasors of the Released Part outside of the United States; and (5) claims concerning . For the avoidance of doubt, no claim is being released which is based on the purchase of any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees a Parking Heater as defined in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effectiveParagraph 2.

Release, Discharge, and Covenant Not to Sue. 3024. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 22 of this Agreement, and in consideration of payment of the Settlement Amount, Amount as specified in Paragraph 32 26 of this Agreement, Agreement into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A, Settlement Fund and for other valuable consideration, the Releasees shall be completely released, acquitted, acquitted and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, individual or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now have, has or hereafter can, shall, shall or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, damages and the consequences thereof in any way arising out of or relating in any way to (i) any conduct, facts, occurrences, or transactions prior to conduct alleged in the Execution Date concerning the Released Part, or to Complaint and/or (ii) any act or omission of the Releasees (or any of the Releaseesthem) concerning Air Conditioning Systems, Defendantsincluding, or co-conspirators now identified or later identified that are allegedbut not limited to, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning (the Released Part (“Released Claims”), ) provided, however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartAir Conditioning Systems; (2) any claims based on made by automotive dealerships that are indirect purchasers of Air Conditioning Systems; (3) any claims made by any State, State agency or instrumentality or political subdivision of a State as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartAir Conditioning Systems; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Air Conditioning Systems; (46) claims under laws other than those of the United States relating to purchases of Air Conditioning Systems made by Releasors of the Released Part any Releasor outside of the United States; and (57) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3024. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 22 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 26 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaints, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releaseesthem) concerning Hydraulic Braking or Electronic Braking Systems, Defendantsincluding, or co-conspirators now identified or later identified that are allegedbut not limited to, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part Actions (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartHydraulic Braking Systems or Electronic Braking Systems; (2) any claims based on made by automotive dealerships that are indirect purchasers of Hydraulic Braking Systems or Electronic Braking Systems; (3) any claims made by any State, State agency, or instrumentality or political subdivision of a State as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartHydraulic Braking Systems or Electronic Braking Systems; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Hydraulic Braking Systems or Electronic Braking Systems; (46) claims under laws other than those of the United States relating to purchases of Hydraulic Braking Systems or Electronic Braking Systems made by Releasors of the Released Part any Releasor outside of the United States; and (57) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3022. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 20 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 24 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively derivatively, or in any other capacity) under any federal, state, local, statutory, or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct alleged in the Complaint or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of any of the ReleaseesReleasees (or combination thereof), Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released PartVehicle Wire Harness Systems, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartVehicle Wire Harness Systems as to such direct purchases; (2) any claims based on made by end-payors that are indirect purchasers of Vehicle Wire Harness Systems; (3) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartVehicle Wire Harness Systems; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any motor vehicle part other than Vehicle Wire Harness Systems; (46) claims under laws other than those of the United States relating to purchases of Vehicle Wire Harness Systems made by Releasors of the Released Part outside of the United States; and (57) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effectiveClaims.

Release, Discharge, and Covenant Not to Sue. 3022. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 20 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 24 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Account, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (a) any conductconduct alleged in the Complaint, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (b) any act or omission of the Releasees (or any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint them) concerning the Released PartShock Absorbers, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1i) any claims based on indirect purchases made by direct purchasers of the Released PartShock Absorbers; (2ii) any claims made by plaintiffs in Class Action Complaint (Case No. 2:16-cv-11256; 2:16-cv-3302) (“Automobile Dealership Action”); (iii) any claims made by any State, State agency, or instrumentality or political subdivision of a State as to government purchases and/or penalties; (iv) claims based on involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released Part; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.Shock Absorbers;

Release, Discharge, and Covenant Not to Sue. 3023. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 20 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 25 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be Erro r! U nkno wn docu ment prop er ty name. completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively derivatively, or in any other capacity) under any federal, state, local, statutory, or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen foreseen, and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct alleged in the Complaint or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of the Releaseesthem), Defendantsconcerning Automotive Brake Hoses including, or co-conspirators now identified or later identified that are allegedbut not limited to, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning (the Released Part (“Released Claims”), provided, however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartAutomotive Brake Hoses as to such direct purchases; (2) any claims based on made by Settlement Class Members and any potential Settlement Class Members who have validly and timely requested to be excluded from the Settlement Class in the Automobile Dealer case, Case No. 2:16-cv-03602-MOB-MKM, as that term is defined in the Settlement Agreement between Hitachi Metals and Automobile Dealer Plaintiffs in that case; (3) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released PartAutomotive Brake Hoses; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part Erro r! U nkno wn docu ment prop er ty name. other than Automotive Brake Hoses; (46) claims under laws other than those of the United States relating to purchases of Automotive Brake Hoses made by Releasors of the Released Part outside of the United States; and (57) claims concerning under federal law, or the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims or conduct at issue in the Released Claims unless this Agreementthe Agreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3021. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement19, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement23, into the Escrow Account (defined below), for TOKAI RIKA’s Cooperation as provided pursuant to Paragraphs 41–42 in Section F and Injunctive Relief provided in Appendix A, and for other valuable considerationparagraph 25, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kindwithout limitation costs, penalties, penalties and attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, statutory or common law of any jurisdiction in the United States, or any other law, code, rule or regulation, whether in law or in equity, that Releasors, or each of them, ever had, now have, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to alleged, described or referred to, or that could have been alleged, described or referred to, in the Execution Date concerning the Released PartComplaint, or to any act or omission of any of the Releasees, Defendants, Defendants or co-conspirators now identified or later identified that are alleged(or any of them), described, regardless of where such acts or referred to in the Complaint concerning the Released Partomissions occurred, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, asserted in any class action or other complaints the Complaint filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartAutomotive Wire Harness Systems as to such direct purchasers; (2) any claims based on negligence, personal injury, breach made by automotive dealerships that are indirect purchasers of contract Automotive Wire Harness Systems (unless such breach and who are not otherwise members of contract claim alleges anticompetitive conduct or communications among competitorsthe Settlement Class), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released Part; (3) any claims brought outside the United States relating to purchases made by truck and equipment dealerships that are indirect purchasers of Automotive Wire Harness Systems (and who are not otherwise members of the Released Part outside the United StatesSettlement Class); (4) any claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that theystate, and each of them, will forever refrain from instituting, maintaining, prosecutingstate agency, or continuing instrumentality or political subdivision of a state as to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.government purchases and/or penalties;

Release, Discharge, and Covenant Not to Sue. 3023. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 21 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 25 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaint, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and (ii) any act or omission of the Releasees (or any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint them) concerning the Released PartInstrument Panel Clusters, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released Part; (2) claims based on negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released Part; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors direct purchasers of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.Instrument Panel Clusters;

Release, Discharge, and Covenant Not to Sue. 3013. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, final as set out in Paragraph 28 11 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 16 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, have on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated unliquidated, claims, causes of action, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of the Releasees, Defendants, or co-conspirators now identified or later identified them) that are alleged, described, or referred to is alleged in the Complaint concerning up to the Released Part, including any conduct and causes date of action alleged or asserted, the execution of this Agreement or that could have been alleged in the Complaint or asserted, in any class action or other complaints complaint filed in the Action concerning (the Released Part (“Released Claims”), provided, however, that nothing herein shall release: (1) any . The Released Claims do not include claims based on indirect purchases of the Released Part; (2) claims based on negligence, for product defect or personal injury, injury or breach of contract (unless such breach arising in the ordinary course of contract claim alleges anticompetitive conduct business or communications among competitors)indirect purchaser claims for Li-Ion Cells, bailmentLi-Ion Batteries or Li-Ion Products that were not purchased directly from Defendants or their subsidiaries, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securitiesaffiliates, or other similar claim relating alleged co-conspirators. Releasors shall not, after the date of this Agreement, sue or otherwise seek to the Released Part; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning establish liability against any product other than the Released Part. The Releasors covenant and agree that theyReleasee based, and each of themin whole or in part, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with upon any of the Released Claims unless this Agreementor conduct at issue in the Released Claims. For purposes of clarity, for the Released Claims include any reasonclaims under foreign antitrust or competition laws or state antitrust or competition laws that relate to or arise out of the subject of the Plaintiffs’ Complaint, does but do not become finalinclude any foreign antitrust or competition law claims or any state law indirect purchaser claims that relate to or arise out of the sale of Li-Ion Cells, Li-Ion Batteries or Li-Ion Products that: (a) were not purchased from a Defendant, a subsidiary or affiliate of a Defendant, or is rescinded an alleged co-conspirator in the Action; or otherwise fails (b) were not billed to become effectiveor shipped to the United States.

Release, Discharge, and Covenant Not to Sue. 3020. In addition to the effect of any final order or judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreementthe Effective Date, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 paragraph 6 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 Settlement Fund, and in Appendix Aconsideration of the allowance of Claim No. 3617 as set forth above, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Pleadings, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releaseesthem) concerning Occupant Safety Restraint Systems, Defendantsincluding, or co-conspirators now identified or later identified that are allegedbut not limited to, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints pleading filed in the Action concerning the Released Part Actions (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released Part; (2) claims based on negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released Part; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.shall

Release, Discharge, and Covenant Not to Sue. 3025. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 23 of this Agreement, and in consideration of payment of the Settlement AmountAmount by NRC, as specified in Paragraph 32 27 of this Agreement, into the Settlement Fund; in consideration of the Cooperation provided pursuant obligations undertaken by NRC as specified in Paragraphs 36-F.47; in consideration of NRC’s agreement to Paragraphs 41–42 use its best efforts to secure the provision of Cooperation by the other Nishikawa Defendants; and in Appendix A, consideration of the Conduct Relief set forth in Paragraph 29; and for other valuable consideration, ; the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), suits and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaint, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releaseesthem) concerning Body Sealings, Defendantsincluding, or co-conspirators now identified or later identified that are allegedbut not limited to, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on made by direct purchasers of Body Sealings arising from those direct purchases (as opposed to separate claims arising from indirect purchases of the Released Partpurchases, which are released pursuant to this Agreement); (2) any claims based on made by automotive dealerships that are indirect purchasers of Body Sealings for resale and/or of new Body Sealings in vehicles purchased for resale arising from those indirect purchases for resale (as opposed to separate claims arising from indirect purchases not for resale, which are released pursuant to this Agreement); (3) any claims made by any State, State agency, or instrumentality or political subdivision of a State as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartBody Sealings; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Body Sealings; (46) claims under laws other than those of the United States relating to purchases of Body Sealings made by Releasors of the Released Part any Releasor outside of the United States; and (57) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does rescinded, not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3023. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 21 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 25 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaint, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releasees, Defendants, or cothem) concerning Anti-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released PartVibration Rubber Parts, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part (“"Released Claims”"), provided, provided however, that nothing herein shall release: (1I) any claims based on indirect purchases made by direct purchasers of the Released PartAnti-Vibration Rubber Parts; (2) any claims based on made by automobile dealerships that are indirect purchasers of Anti­ Vibration Rubber Parts; (3) any claims made by truck and equipment dealerships that are indirect purchasers of Anti-Vibration Rubber Parts; (4) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartAnti­ Vibration Rubber Parts; (36) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Anti-Vibration Rubber Parts; (47) claims under laws other than those of the United States relating to purchases of Anti-Vibration Rubber Parts made by Releasors of the Released Part any Releasor outside of the United States; and (5) 8) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3023. In addition to the effect of any final judgment judgments entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 21 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 25 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Funds, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement FundFunds, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaints, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releasees, Defendants, them) concerning Fuel Injection Systems or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released PartValve Timing Control Devices, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning the Released Part Actions (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartFuel Injection Systems or Valve Timing Control Devices; (2) any claims based on made‌ by automotive dealerships that are indirect purchasers of Fuel Injection Systems or Valve Timing Control Devices; (3) any claims made by truck and equipment dealerships that are indirect purchasers of Fuel Injection Systems or Valve Timing Control Devices; (4) any claims made by any State, State agency, or instrumentality or political subdivision of a State as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartFuel Injection Systems or Valve Timing Control Devices; (36) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Fuel Injection Systems or Valve Timing Control Devices; (47) claims under laws other than those of the United States relating to purchases of Fuel Injection Systems or Valve Timing Control Devices made by Releasors of the Released Part any Releasor outside of the United States; and (5) 8) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3022. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement20, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement, the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A24, and for other valuable consideration, the Releasees shall be Releasors completely releasedrelease, acquittedacquit, and forever discharged discharge Releasees from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement FundAmount, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, related to, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of them) concerning the Releaseespricing, Defendantsproduction, development, or cosale of Parking Heaters or products containing Parking Heaters up to the date of execution of this Agreement and relating in any way to alleged anti-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released Partcompetitive activity involving Parking Heaters, including any claims based on the conduct alleged and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in the Indirect Purchaser Complaint, or in any class similar action or other complaints filed in any federal or state court, including, without limitation, any claims arising under any federal or state antitrust, unjust enrichment, unfair competition, trade practice statutory or common law, and consumer protection law (to the Action concerning extent that a consumer protection claim would be based on allegations of an antitrust or unfair competition violation) (the Released Part (“Released Claims”). Releasors shall not, providedafter the date of this Agreement, howeverseek to establish liability against any Releasee based, in whole or in part, on any of the Released Claims or conduct at issue in the Released Claims, unless this Agreement is terminated or not finally approved. The Settling Parties contemplate and agree that nothing this Agreement may be pleaded as a bar to a lawsuit, and an injunction may be obtained, preventing any action from being initiated or maintained in any case sought to be prosecuted on behalf of Releasors with respect to the Released Claims. Nothing herein shall release: (1i) any claims based on indirect purchases made by direct purchasers of the Released PartParking Heaters as to such direct purchases; (2ii) any claims made by any federal or state agency, or instrumentality or political subdivision, as to government purchases and/or penalties; (iii) claims based on negligence, involving any personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, or product defect, breach of product warranty, securities, or other similar claim defect claims relating to the Released PartParking Heaters; and (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4iv) claims under laws other than those of the United States relating to purchases of Parking Heaters made by Releasors of the Released Part outside of the United States; and (5) claims concerning . For the avoidance of doubt, no claim is being released which is based on the purchase of any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees a Parking Heater as defined in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effectiveParagraph 2 above.

Release, Discharge, and Covenant Not to Sue. 3021. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 19 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 23 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Funds, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement FundFunds, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out ofrelated to, any and all known the conduct alleged in the Complaints or unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of the Releaseesthem), Defendantsconcerning Switches, Steering Angle Sensors, or co-conspirators now identified or later identified that are HID Ballasts, including but not limited to any conduct alleged, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action Actions concerning Switches, Steering Angle Sensors, or HID Ballasts (the Released Part (“Released Claims”), provided, however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartSwitches, Steering Angle Sensors, or HID Ballasts; (2) any claims based on made by automotive dealerships that are indirect purchasers of Switches, Steering Angle Sensors, or HID Ballasts; (3) any claims made by any State, State agency, or instrumentality or political subdivision of a State, as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released PartSwitches, Steering Angle Sensors, or HID Ballasts; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Switches, Steering Angle Sensors, or HID Ballasts; (46) claims under laws other than those of the United States relating to purchases made by Releasors of and the Released Part outside of the United Statesstates thereof; and (57) claims concerning for damages under the state law or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee based, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with upon any of the Released Claims or conduct at issue in the Released Claims unless this Agreementthe Agreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3023. In addition to the effect of any final judgment order entered in accordance with this Agreement, upon this Agreement becoming final, final as set out in Paragraph 28 of this Agreement21, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement, the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A26, and for other valuable consideration, including as specified in this Agreement, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in distribution of the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, state or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now have, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions the nucleus of operative facts alleged in the complaint in the Action prior to the Execution Date concerning that were made or could have been made in the Released Part, Action by Direct Purchaser Plaintiffs or to any act or omission of any of Settlement Class Members against the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred including all direct purchaser claims relating to Varsity and/or USASF’s involvement in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, or that could have been alleged or asserted, cheerleading industry based in any class action way on conduct or other complaints filed events arising out of the nucleus of operative facts alleged in the Action concerning consolidated complaint in the Released Part (“Released Claims”), provided, howeverAction, that nothing herein shall release: (1) occurred through the Execution Date. Notwithstanding the foregoing, any claims based on indirect purchases by Settlement Class Members or Releasors that may exist under the law of one or more U.S. states will not be released. In addition, and notwithstanding the foregoing, claims arising in the ordinary course between (a) any of the Released Part; Releasees, on the one hand, and (2b) claims based Direct Purchaser Plaintiffs, Settlement Class Members or Releasors, on negligencethe other, and arising under Article 2 of the Uniform Commercial Code (pertaining to sales) or similar state laws, the laws of negligence or product liability, strict liability, or implied warranty, breach of contract, breach of express warranty, or personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released Part; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Partwill also not be released. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing claims described as being released in this paragraph are referred to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against herein as the Releasees in connection with any of the “Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effectiveClaims.”

Release, Discharge, and Covenant Not to Sue. 3022. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement20, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement24, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Account (defined below), and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actionsAction, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, state or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, conduct alleged or to be alleged in the Complaint or any act or omission of the Releasees (or any of the them), concerning Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred including but not limited to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, or that could have been to be alleged or asserted, in any class action or other complaints filed asserted in the Action concerning the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartAir Conditioning Systems as to such direct purchasers; (2) any claims based on made by automotive dealerships that are indirect purchasers of Air Conditioning Systems; (3) any claims made by truck and equipment dealerships that are indirect purchasers of Air Conditioning Systems; (4) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartAir Conditioning Systems; (36) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Air Conditioning Systems; (47) claims under laws other than those of the United States relating to purchases of Air Conditioning Systems made by Releasors of the Released Part outside of the United States; and (5) 8) damage claims concerning under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effectiveClaims.

Release, Discharge, and Covenant Not to Sue. 3024. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 22 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 26 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively derivatively, or in any other capacity) under any federal, state, local, statutory, or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct alleged in the Complaint or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of any of the ReleaseesReleasees (or combination thereof), Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released PartBearings, including but not limited to any conduct and causes of action alleged or asserted, or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartBearings as to such direct purchases; (2) any claims based on made by Settlement Class Members in the End Payor case, Case No. 2:12-cv-00503-MOB-MKM, as that term is defined in the Settlement Agreement between NTN and End Payor Plaintiffs in that case; (3) any claims made by Settlement Class Members in the Automobile Dealership case, Case No. 2:12-cv-00502-MOB- MKM, as that term is defined in the Settlement Agreement between NTN and Automobile Dealership Plaintiffs in that case; (4) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartBearings; (36) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any vehicle part other than Bearings; and (47) claims under laws other than those of the United States relating to purchases of Bearings made by Releasors of the Released Part outside of the United States; States and (5) claims concerning the states thereof. Releasors shall not, after the date of this Agreement, seek to establish liability against any product other than the Released Part. The Releasors covenant and agree that theyReleasee based, and each of themin whole or in part, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with upon any of the Released Claims or conduct at issue in the Released Claims unless this Agreementthe Agreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3024. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 22 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 26 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the settlement or Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaint, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releaseesthem) concerning Hydraulic Braking Systems, Defendantsincluding, or co-conspirators now identified or later identified that are allegedbut not limited to, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartHydraulic Braking Systems; (2) any claims based on made by automotive dealerships that are indirect purchasers for resale of Hydraulic Braking Systems; (3) any claims made by any State, State agency, or instrumentality or political subdivision of a State as to government purchases and/or penalties; (4) unrelated claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartHydraulic Braking Systems; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Hydraulic Braking Systems; (46) claims under laws other than those of the United States relating to purchases of Hydraulic Braking Systems made by Releasors of the Released Part any Releasor outside of the United States; and (57) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3025. In addition to the effect of any final judgment judgments entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 23 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 27 of this Agreement, into the Settlement Fund, the Injunctive Relief, and Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AMaterials provided, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, (“Claims”) that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, or that now exist or may exist in the futureexist, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conduct, facts, occurrences, or transactions prior to conduct alleged in the Execution Date concerning the Released Part, or to CFP Complaint and/or (ii) any act or omission of the Releasees (or any of the Releaseescombination thereof), Defendantsconcerning Foodservice-Size Packaged Tuna Products, or co-conspirators now identified or later identified that are including, but not limited to, any conduct alleged, described, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning Foodservice-Size Packaged Tuna Products (the Released Part (“Released Claims”), provided, however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartFoodservice-Size Packaged Tuna Products; (2) any claims based on made by end payors that are indirect purchasers of Foodservice-Size Packaged Tuna Products; (3) any claims made by any State, State agency, or instrumentality or political subdivision of a State, as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct contract, false advertising or communications among competitors)fraud other than as alleged in the CFP Complaint, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released PartFoodservice-Size Packaged Tuna Products; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any packaged seafood product other than Foodservice-Size Packaged Tuna Products; (46) claims under laws other than those of the United States relating to purchases of Foodservice-Size Packaged Tuna Products made by Releasors of the Released Part any Releasor outside of the United States; and (57) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themsue or otherwise seek to establish liability against any Releasee based, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with upon any of the Released Claims unless this Agreementthe Agreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3023. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 21 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 25 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct prior to the Execution Date alleged in the Complaint or any amendment thereto, facts, occurrences, and/or (ii) any act or transactions omission of the Releasees (or any of them) prior to the Execution Date concerning the Released Partprice fixing, bid rigging, or to any act or omission of any of the Releaseesmarket, Defendantscustomer, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released Partsupply allocation of Automotive Exhaust Systems, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part (“Released Claims”)Action, provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released PartAutomotive Exhaust Systems; (2) claims based on involving any negligence, personal injury, breach of contract (unless to the extent that such breach of contract claim alleges anticompetitive conduct claims are unrelated to antitrust, collusion, conspiracy, or communications among competitorsany claims or actions alleged in the Complaint), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartAutomotive Exhaust Systems; (3) claims brought outside the United States relating to purchases of the Released Part Automotive Exhaust Systems outside the United States; (4) claims brought under laws other than those of the United States relating to purchases made by Releasors of the Released Part Automotive Exhaust Systems outside of the United States; and (5) claims concerning any product other than Automotive Exhaust Systems. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3024. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 22 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 26 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the this settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaint, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releaseesthem) concerning Spark Plugs, DefendantsStandard Oxygen Sensors, or co-conspirators now identified or later identified that are allegedand/or Air Fuel Ratio Sensors, describedincluding, or referred to in the Complaint concerning the Released Partbut not limited to, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartSpark Plugs, Standard Oxygen Sensors, and Air Fuel Ratio Sensors; (2) any claims based on made by automotive dealerships that are indirect purchasers of Spark Plugs, Standard Oxygen Sensors, and Air Fuel Ratio Sensors; (3) any claims made by any State, State agency, or instrumentality or political subdivision of a State as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartSpark Plugs, Standard Oxygen Sensors, and Air Fuel Ratio Sensors; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Spark Plugs, Standard Oxygen Sensors, and Air Fuel Ratio Sensors; (46) claims under laws other than those of the United States relating to purchases of Spark Plugs, Standard Oxygen Sensors, and Air Fuel Ratio Sensors made by Releasors of the Released Part any Releasor outside of the United States; and (57) claims concerning under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3026. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 24 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 28 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Member of the Settlement Class Member Classes has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common local law of any jurisdiction in the United States, States that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaints, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and (ii) any act or omission of the Releasees (or any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint them) concerning the Released PartAutomotive Lamps and HID Ballasts, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part Actions (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartAutomotive Lamps and HID Ballasts; (2) any claims based on made by automotive dealerships that are indirect purchasers of Automotive Lamps and HID Ballasts; (3) any claims made by any State, State agency, or instrumentality or political subdivision of a State as to government purchases and/or penalties; (4) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartAutomotive Lamps and HID Ballasts; (35) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Automotive Lamps and HID Ballasts; (46) claims under laws other than those of the United States federal or state laws relating to purchases of Automotive Lamps and HID Ballasts made by Releasors of the Released Part any Releasor outside of the United States; and (57) damage claims concerning under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims or as to conduct at issue in the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3025. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 23 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 Paragraphs 14 and 27 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively derivatively, or in any other capacity) under any federal, state, local, statutory, or common local law of any jurisdiction in the United States, or under the law of any other foreign jurisdiction, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct alleged in the Complaint or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or combination thereof), concerning any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released PartVehicle Parts, including without limitation any Alternators or Starters, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning or any other case in the Released Part MDL Litigation (the “Released Claims”). Notwithstanding the foregoing, provided, however, that nothing herein shall releaseReleased Claims does not include: (1) any claims based on indirect purchases made by direct purchasers of the Released PartVehicle Parts as to such direct purchases; (2) any claims based on made by Settlement Class Members in the End Payor cases, Case Nos. 2:12-cv-00703-MOB-MKM and 2:12-cv-001103-MOB-MKM, as that term is defined in the Settlement Agreement between Mitsubishi Electric and End Payor Plaintiffs in that case; (3) any claims made by Settlement Class Members in the Automobile Dealership cases, Case Nos. 2:12-cv-00702-MOB-MKM and 2:12- cv-001102-MOB-MKM, as that term is defined in the Settlement Agreement between Mitsubishi Electric and Automobile Dealership Plaintiffs in that case; (4) any claims made by any state, state agency, or instrumentality or political subdivision of a state as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartVehicle Parts; and (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (46) claims under laws other than those of the United States relating to purchases of Vehicle Parts made by Releasors of the Released Part outside of the United States; States and (5) claims concerning the states thereof. Releasors shall not, after the date of this Agreement, seek to establish liability against any product other than the Released Part. The Releasors covenant and agree that theyReleasee based, and each of themin whole or in part, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with upon any of the Released Claims or conduct at issue in the Released Claims unless this Agreementthe Agreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3024. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 22 of this Agreement, and in consideration of payment of the Settlement Amount, Amount as specified in Paragraph 32 26 of this Agreement, the injunction to be entered as described in Paragraph 21(g) of this Agreement, the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A34–50, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement this Agreement or makes a claim upon or receives a payment from the Settlement FundFunds, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out ofrelated to, any and all known the conduct alleged in the Complaint or unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of them) concerning the Releaseessale of any and all parts, Defendantsmodules, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released Partassemblies for incorporation into any Vehicle, including any conduct alleged and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action MDL Proceeding concerning the Released Part (“Released Claims”)any such parts, modules, or assemblies, provided, however, that nothing herein shall release: (1) any claims based on indirect direct purchases of the Released Partsuch parts, modules, or assemblies; (2) any claims based on made by any State, State agency, or instrumentality or political subdivision of a State, as to government purchases and/or penalties relating to such parts, modules, or assemblies; (3) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released Partsuch parts, modules, or assemblies; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; and (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and States (5) claims concerning any product other than the “Released PartClaims”). The Releasors hereby covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecutingnot to sue any Releasee in connection with, or continuing to maintain file or prosecute prosecute, any suit, action, arbitration claims released herein on their own behalf or on the behalf of any other proceeding of any kind person or collecting fromentity, seeking to recover fromon either an individual or class-wide basis, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, Agreement does not become final, obtain Final Court Approval or is rescinded otherwise terminated or otherwise fails to become effectiverescinded.

Release, Discharge, and Covenant Not to Sue. 3018. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, final as set out in Paragraph 28 of this Agreementparagraph 15 above, and in consideration of payment of the Settlement AmountFund, as specified in Paragraph 32 of this Agreement, the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member person or entity has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund), whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, capacity that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, have on account of, related to, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, and unsuspected injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of Releasees (or any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint them) concerning the Released Partpricing, production, development, marketing, sale or distribution of Vitamin C during the period from the beginning of time to the present, including any claims based on the conduct alleged and causes of action alleged or asserted, or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning by the Released Part Settling Plaintiffs, including, without limitation, any claims arising under any federal or state antitrust, unjust enrichment, unfair competition, or trade practice statutory or common law, or consumer protection law (to the extent that a consumer protection claim would be based on allegations of an antitrust or unfair competition violation) (the “Released Claims”). Releasors shall not, providedafter the date of this Agreement, howeverseek to establish liability against any Releasee based, that nothing herein shall release: (1) any claims based on indirect purchases of the Released Part; (2) claims based on negligencein whole or in part, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released Part; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with upon any of the Released Claims unless Claims. The Settling Parties contemplate and agree that this AgreementAgreement may be pleaded as a bar to a lawsuit, for and an injunction may be obtained, preventing any reason, does not become final, action from being initiated or is rescinded or otherwise fails maintained in any case sought to become effectivebe prosecuted on behalf of entities that indirectly purchased Vitamin C Products with respect to the claims released in this paragraph.

Release, Discharge, and Covenant Not to Sue. 3018. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement16, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement21, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Account (defined below), and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions conduct of the Releasees prior to the Execution Date concerning alleged in the Released PartComplaint, or to in any future complaint concerning price fixing, bid rigging, or market, customer, or supply allocation of Air Conditioning Systems, and/or any act or omission of the Releasees (or any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint them) concerning the Released PartAir Conditioning Systems, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning (the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released PartAir Conditioning Systems; (2) claims based on involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartAir Conditioning Systems; (3) claims brought outside the United States relating to purchases of the Released Part Air Conditioning Systems outside the United States; (4) claims brought under laws other than those of the United States relating to purchases made by Releasors of the Released Part Air Conditioning Systems outside of the United States; and (5) claims concerning any product other than Air Conditioning Systems. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.

Release, Discharge, and Covenant Not to Sue. 307. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement20, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement24, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix AEscrow Account (defined below), and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fundsettlement, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, state or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, conduct to be alleged in the Complaint or transactions prior to the Execution Date concerning the Released Part, or to any act or omission of the Releasees (or any of the them), concerning Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred including but not limited to in the Complaint concerning the Released Part, including any conduct and causes of action to be alleged or asserted, or that could have been alleged or asserted, in any class action or other complaints filed asserted in the Action concerning the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartPower Window Switches as to such direct purchasers; (2) any claims based on negligence, personal injury, breach made by automotive dealerships that are indirect purchasers of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released PartPower Window Switches; (3) any claims brought outside the United States relating to purchases made by truck and equipment dealerships that are indirect purchasers of the Released Part outside the United StatesPower Window Switches; (4) any claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that theystate, and each of them, will forever refrain from instituting, maintaining, prosecutingstate agency, or continuing instrumentality or political subdivision of a state as to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.government purchases and/or penalties;

Release, Discharge, and Covenant Not to Sue. 3024. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 22 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 26 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively derivatively, or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, or damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaint, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of the Releasees (or any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint them) concerning the Released PartExhaust Systems, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made‌ by direct purchasers of the Released PartExhaust Systems; (2) any claims based on negligence, personal injury, breach made by automotive dealerships that are indirect purchasers of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors), bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released PartExhaust Systems; (3) any claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that theystate, and each of them, will forever refrain from instituting, maintaining, prosecutingstate agency, or continuing instrumentality or political subdivision of a state as to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.government purchases and/or penalties;

Release, Discharge, and Covenant Not to Sue. 3022. In addition to the effect of any final judgment order entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 of this Agreement20, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 of this Agreement, the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix A24, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in distribution of the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, state or common local law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now have, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions conduct prior to the Execution Date concerning alleged in the Released Part, complaints filed in the Bearings Actions or to any act or omission of the Releasees (or any of them) alleged in the Releaseescomplaints filed in the Bearings Actions concerning price fixing, Defendantscost shifting, bid rigging, or co-conspirators now identified market or later identified that are allegedcustomer allocation of Bearings including, describedbut not limited to, or referred to in the Complaint concerning the Released Part, including any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints filed in the Action concerning Bearings Actions (the Released Part (“Released Claims”), provided. Notwithstanding the foregoing, however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released PartBearings; (2) claims based on negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released PartBearings; (3) claims brought outside the United States relating to purchases of the Released Part outside the United States; (4) claims under laws other than those of the United States relating to purchases made by Releasors of the Released Part Bearings outside of the United States; and or (54) claims concerning any product other than Bearings. After the Released Part. The Execution Date, Releasors covenant and agree that theyshall not seek to establish liability against any Releasee as to, and each of themin whole or in part, will forever refrain from instituting, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this the Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.

Release, Discharge, and Covenant Not to Sue. 3023. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 21 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 25 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each any of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out of, any and all known or and unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to (i) any conductconduct alleged in the Complaint, facts, occurrences, or transactions prior to the Execution Date concerning the Released Part, or to and/or (ii) any act or omission of of‌ the Releasees (or any of the Releasees, Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint them) concerning the Released PartIgnition Coils, including but not limited to any conduct and causes of action alleged or asserted, asserted or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning the Released Part (“Released Claims”), provided, provided however, that nothing herein shall release: (1) any claims based on indirect purchases made by direct purchasers of the Released PartIgnition Coils; (2) any claims based on made by automotive dealerships that are indirect purchasers of Ignition Coils; (3) any claims made by truck and equipment dealerships that are indirect purchasers of Ignition Coils; (4) any claims made by any State, State agency, or instrumentality or political subdivision of a State as to government purchases and/or penalties; (5) claims involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, securities or other similar claim relating to the Released PartIgnition Coils; (36) claims brought outside the United States relating to purchases of the Released Part outside the United Statesconcerning any automotive part other than Ignition Coils; (47) claims under laws other than those of the United States relating to purchases of Ignition Coils made by Releasors of the Released Part any Releasor outside of the United States; and (5) 8) claims concerning for damages under the state or local laws of any product jurisdiction other than an Indirect Purchaser State. Releasors shall not, after the Released Part. The Releasors covenant and agree that theydate of this Agreement, and each of themseek to establish liability against any Releasee as to, will forever refrain from institutingin whole or in part, maintaining, prosecuting, or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees in connection with any of the Released Claims unless this AgreementAgreement is, for any reason, does not become final, finally approved or is rescinded or otherwise fails to become effectiveterminated.

Release, Discharge, and Covenant Not to Sue. 3020. In addition to the effect of any final judgment entered in accordance with this Agreement, upon this Agreement becoming final, as set out in Paragraph 28 18 of this Agreement, and in consideration of payment of the Settlement Amount, as specified in Paragraph 32 22 of this Agreement, into the Cooperation provided pursuant to Paragraphs 41–42 and in Appendix ASettlement Fund, and for other valuable consideration, the Releasees shall be completely released, acquitted, and forever discharged from any and all claims, demands, actions, suits, damages whenever incurred, liabilities of any nature whatsoever (including damages of any kind, penalties, attorneys’ fees, and costs), and causes of action, whether class, individual, or otherwise in nature (whether or not any Settlement Class Member has objected to the settlement or makes a claim upon or receives a payment from participates in the Settlement Fund, whether directly, representatively, derivatively or in any other capacity) under any federal, state, local, statutory, or common law of any jurisdiction in the United States, that Releasors, or each of them, ever had, now havehas, or hereafter can, shall, or may ever have, that now exist or may exist in the future, on account of, or in any way arising out ofrelated to, any and all known or unknown, foreseen and unforeseen, suspected or unsuspected, actual or contingent, liquidated or unliquidated claims, injuries, damages, and the consequences thereof in any way arising out of or relating in any way to any conduct, facts, occurrences, or transactions prior to the Execution Date concerning Effective Date, alleged in the Released Part, Complaint or to any act or omission of the Releasees (or any of the Releaseesthem), Defendants, or co-conspirators now identified or later identified that are alleged, described, or referred to in the Complaint concerning the Released PartStarters, including but not limited to any conduct and causes of action alleged or asserted, or that could have been alleged or asserted, in any class action or other complaints complaint filed in the Action concerning (the Released Part (“Released Claims”), provided, however, that nothing herein shall release: (1) any claims based on indirect purchases of the Released PartStarters; (2) claims based on involving any negligence, personal injury, breach of contract (unless such breach of contract claim alleges anticompetitive conduct or communications among competitors)contract, bailment, failure to deliver lost goods, damaged or delayed goods, product defect, breach of product warranty, securities, or other similar claim relating to the Released PartStarters; (3) claims brought outside the United States relating to purchases of the Released Part Starters outside the United States; (4) claims concerning any product other than Starters, and (5) claims under laws other than those of the United States relating and the states thereof. Releasors shall not, on or after the date of this Agreement, seek to purchases made by Releasors establish liability against any Releasee, in whole or in part, based on any of the Released Part outside of the United States; and (5) claims concerning any product other than the Released Part. The Releasors covenant and agree that they, and each of them, will forever refrain from instituting, maintaining, prosecuting, Claims or continuing to maintain or prosecute any suit, action, arbitration or any other proceeding of any kind or collecting from, seeking to recover from, or proceeding against the Releasees conduct at issue in connection with any of the Released Claims unless this Agreement, for any reason, does not become final, or is rescinded or otherwise fails to become effective.