Internal Distribution

Internal Distribution. Means any transaction (or series of transactions) effected as part of the Internal Reorganization that is intended to qualify as a tax-free transaction under Section 355 and/or Section 368(a)(1)(D) of the Code. Each Internal Distribution, including the Ultra Subsidiaries that were a party thereto and the Ultra Subsidiaries and Delta Subsidiaries the stock of which was distributed therein, has been listed by Delta on Schedule II.