Intervention in the U. S. Litigation (1) The Settling Defendants and other Releasees shall not oppose any application that may be brought by or on behalf of the Plaintiffs to intervene in the U.S. Litigation in order to gain access to discovery documents and other documents and information for use in connection with the prosecution of the Proceedings against the Non-Settling Defendants, subject to the agreement of Class Counsel and the Plaintiffs to abide by the terms of any confidentiality and/or protective order in the U.S. Litigation and to be subject to the recourses and remedies arising from any breach or violation of such confidentiality and/or protective order, that are relevant to the Proceedings and not otherwise inconsistent with the terms of this Settlement Agreement, including Section 4.1(11). It is understood and agreed that neither the Settling Defendants nor the other Releasees have any obligation to bring or otherwise participate in such an application.
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Sources: Settlement Agreement, Settlement Agreement