STIPULATED JUDGMENT

Filed concurrently with JOINT REQUEST FOR ENTRY OF STIPULATED JUDGMENT

PHILIP S. GUTIERREZ, District Judge.

Plaintiff Paramount Licensing Inc. ("PLI") and Defendant PHR FZ-LLC ("PHR") (together, the "Parties") having stipulated to the entry of judgment, and good cause appearing therefor, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED as follows:

1. PHR breached the license agreement, dated as of September 18, 2013, between the Parties (together with the executed amendment thereto, the "Agreement"), by failing to pay the non-refundable minimum annual royalty ("Annual Minimum Royalty Guarantee"), as required by Section 7.4 of the Agreement, for 2018 and 2019. As a result, PHR owes PLI nine million five hundred thousand dollars ($9,500,000.00).

2. By virtue of the June 12, 2019 letter from PLI and pursuant to Section 15.1.1 of the Agreement, the Agreement has been lawfully and fully terminated. PHR shall have no further rights or licenses under the Agreement and, pursuant to the Agreement, any and all sublicenses (or similar agreements or arrangements) entered into by PHR involving or relating to the use of the Paramount Pictures name and logo and associated branding (the "Paramount Brand") are and shall be deemed terminated. PHR (and Ghassan Al Aridi and any related, associated or controlled entities, including GAA Marta Consulting or any other company ever associated with Ghassan Al Aridi) is prohibited from representing that it has any rights in connection with the Paramount Brand or that it holds any rights or licenses under the Agreement.

3. PLI and PHR have stipulated that PHR shall convey, transfer, and assign to PLI any and all claims and causes of action that PHR may have against any and all actual or prospective sub-licensees or other entities that arise from or relate to the Paramount Brand, the Agreement, and/or any existing or planned projects or business related to Paramount Hotels and/or Residences to be provided by PHR. This conveyance, transfer, and assignment shall include, without limitation, all claims and causes of action that PHR may have against the following entities or projects, and all persons and entities associated therewith that were and/or are using or involving the Paramount Brand: Damac Star Properties LLC (UAE/Mideast hotels/residences); Target Investment Turizm Isletmeleri A.S. (Turkey/Bodrum hotel); Indonesia American Resorts Company Menara BCA (Lombok/Indonesia hotel development); Perusahaan Resort Indonesia American Resorts Company (Lombok/Indonesia); Asia PrimaCity Ventures Sdn. Bhd. (Malaysia); Riverside Group (China); Bin Faqeeh Real Estate Investment Co. S.P.C. (Bahrain residences); PT. Amorsk Indonesia (Indonesia); Al Asmakh Real Estate Development Company LLC (Doha/Qatar residences); and Artak Tovmasyan (Armenia) and Threepwood Investments Limited (Armenia). PHR is not conveying, transferring, or assigning any liabilities, obligations, or any assets other than the above claims and causes of action. Such conveyance, transfer, and assignment is made and shall be valid and enforceable under U.S. and/or any other applicable law.

4. PLI and PHR have stipulated to a mutual release of claims and causes of action between PHR and PLI (including between all members, managers, officers, directors, and employees) that arise from or relate to the Paramount Brand, the Agreement, and/or any existing or planned projects or business related to Paramount Hotels and/or Residences to be provided by PHR.

5. PLI and PHR have stipulated that PHR, having assigned all such claims and causes of action to PLI, will thereafter release any and all claims and causes of action PHR may have against any actual or prospective sub-licensees or other entities that arise from or relate to the Paramount Brand, the Agreement, and/or any existing or planned projects or business related to Paramount Hotels and/or Residences to be provided by PHR. This release shall include, without limitation, a release of any and all claims and causes of action that PHR may have against the following entities or projects, and all persons and entities associated therewith: Damac Star Properties LLC (UAE/Mideast hotels/residences); Target Investment Turizm Isletmeleri A.S. (Turkey/Bodrum); Indonesia American Resorts Company Menara BCA (Lombok/Indonesia); Perusahaan Resort Indonesia American Resorts Company (Lombok/Indonesia); Asia PrimaCity Ventures Sdn. Bhd. (Malaysia); Riverside Group (China); Bin Faqeeh Real Estate Investment Co. S.P.C. (Bahrain); PT. Amorsk Indonesia (Indonesia); Al Asmakh Real Estate Development Company LLC (Doha/Qatar); and Artak Tovmasyan (Armenia) and Threepwood Investments Limited (Armenia). Such release is made and shall be valid and enforceable under U.S. or any other law.

IT IS SO ORDERED.