Section 162(m) Reliance Period

Section 162(m) Reliance Period. The period beginning on the Effective Date and ending on the earlier to occur of: (i) the material modification of the Plan within the meaning of Treas. Reg. §1.162-27(b)(1)(iii) or any successor provision; or (ii) the first meeting of the Company's shareholders at which directors are to be elected that occurs after the close of the third calendar year following the calendar year in which the Company's initial public offering occurs