Aledade

1.1 Identity and operating model

Aledade was founded in 2014, and 2023 funding coverage located its headquarters in Bethesda, Maryland. Its operating model is a physician-enablement platform rather than a practice roll-up: independent practices, clinics, community health centers, and systems retain their autonomy while Aledade supplies analytics, EHR-integrated workflows, policy expertise, coaching, patient-engagement tools, and contract management. The company says its revenue is tied primarily to shared-savings performance, while current disclosures describe programs spanning MSSP, Medicare Advantage, Medicaid, and commercial contracts. This combination creates a distributed operating footprint and aligns the platform with primary-care outcomes, but it also leaves execution dependent on payer rules, practice adoption, and the quality of data flowing through many heterogeneous EHR workflows.[CO001, CO002, CO003, CO004, CO016]

1.2 Leadership, governance, and key-person dependence

Farzad Mostashari and Mat Kendall are identified as co-founders, with Mostashari serving as chief executive and Kendall as president. Their public commentary spans product, implementation, policy, and network strategy, making their operating experience a material asset but also a potential concentration point for a private company whose public disclosures provide limited detail on board composition, voting control, succession planning, or executive turnover. The 2023 funding coverage reported two new board members and an experienced senior executive hire, but the assigned evidence does not establish the current full board or the rights attached to investor ownership. A diligence process should therefore request the current cap table, board roster, delegated authorities, succession plan, and retention arrangements for the founders and other critical operators.[CO005, CO006, CO007]

1.3 Capital, scale, and milestone trajectory

Aledade reported a sharp increase in operating scale: more than 3,000 primary care partners caring for more than 3 million patients across 46 states and the District of Columbia for the 2026 performance year, after adding more than 700 organizations. Fierce Healthcare reported $1 billion of 2025 revenue and profitability in 2025, while the same report described a $500 million senior secured credit facility that can expand to $650 million. Earlier reporting described $660 million of cumulative equity raised and a $3.5 billion valuation in the 2023 Series F context, but those figures are historical markers rather than a current valuation or cash balance. CMS data confirms the underlying policy market is expanding, yet its description that accountable organizations may share in losses underscores that scale does not remove performance and policy risk. Current cash, debt draw, covenants, exact revenue mix, and a refreshed valuation remain gaps.[CO008, CO009, CO010, CO011, CO012]

1.4 Diligence implications

The strongest verified positives are network breadth, multi-payer coverage, evidence of recent practice additions, and a stated transition from growth toward profitability. The principal underwriting limitations are private-company disclosure and the operating risk of scaling a service-heavy, risk-bearing model across independent practices. Neither the assigned evidence nor the public descriptions establish current ARR, net retention, churn, gross margin, cash flow, debt draw, covenant headroom, liquidation preferences, option dilution, or a current third-party clearing valuation. Aledade's public-benefit status and physician-led positioning may support partner trust, but they do not substitute for legal, financial, and governance diligence. Treat the historical $3.5 billion valuation and $660 million raised as dated reported figures, not as current marks or available cash.[CO013, CO014, CO015]

1.5 Exhibits

2.1 Market boundary and status-quo substitutes

The investable category is value-based-care enablement for independent primary-care organizations: data aggregation, workflow support, payer contracting, coaching, quality reporting, and the operating infrastructure needed to participate in accountable-care arrangements. It should not be confused with total Medicare spending, the premium pool of Medicare Advantage, or all medical claims managed by an ACO. Aledade says it does not own or manage partner practices, so practice revenue and care-delivery assets sit outside this boundary. The status quo is fee-for-service operation supported by an EHR and internal staff; adjacent alternatives include health-system or corporate ownership and payer-supplied enablement. An ACO is the contracting and accountability vehicle, while Aledade's addressable product is the enablement and shared-savings layer around that vehicle.[CM001, CM002, CM010]

2.2 Evidence-constrained sizing and adoption

Public data establishes adoption scale but not vendor revenue opportunity. CMS reports 511 MSSP ACOs with 12.6 million assigned beneficiaries for 2026, versus 476 ACOs and 11.2 million beneficiaries in 2025. Broader CMS accountable-care initiatives coordinate care for an estimated 14.3 million Medicare beneficiaries, while Medicare Advantage enrolls 35.2 million of 64.2 million eligible beneficiaries. These populations overlap or use different payment systems, so they are sizing lenses rather than additive TAM layers. Company-reported Aledade scale rose from 1,500 practices and more than 2 million patients in 2023 to over 3,000 partners and more than 3 million patients in 2026. Its claim of serving nearly 20% of total MSSP participation indicates material penetration, but the disclosed denominator does not translate into software revenue, shared-savings revenue, or a reliable SOM.[CM003, CM004, CM005, CM006, CM007]

2.3 Buyer, user, payer, and budget ownership

The operational buyer is typically an independent practice, clinic, or community health center seeking scale without surrendering ownership; users are physicians, care teams, and administrative staff. The economic payer is different: CMS funds MSSP economics, while Medicare Advantage, Medicaid, and commercial insurers fund other value-based contracts. Aledade therefore needs both practice adoption and payer-contract access. Its Elevance partnership illustrates a payer-channel route that can expose affiliated independent providers to Aledade's tools and in-person services. For smaller organizations, joining an ACO can substitute for building contracting, analytics, and support capabilities internally. Adoption is triggered when expected shared savings, workflow assistance, and preserved autonomy exceed switching, reporting, and downside-risk costs; the source set does not reveal contract pricing or the exact split of value among payer, practice, and enablement vendor.[CM001, CM002, CM009, CM010]

2.4 Growth drivers, constraints, and valuation relevance

Growth is supported by larger MSSP participation, broad Medicare Advantage enrollment, and policy mechanisms that reward quality and total-cost performance. Constraints are equally structural. In 2026, 82.8% of MSSP ACOs were in tracks that meet advanced alternative-payment-model criteria, exposing participants to more demanding risk arrangements. Aledade also described a natural timing gap in Medicare payments that requires working capital, showing that scale can increase financing needs before distributions arrive. Medicare Advantage is concentrated, with UnitedHealth and Humana representing 46% of enrollment, and payments remain under policy scrutiny because KFF estimates 2026 payments at 14% above comparable traditional Medicare spending. Finally, Aledade published incompatible 2024 avoided-utilization figures of more than 260,000 and more than 171,000 events. Without definitions, cohort reconciliation, pricing, retention, and audited unit economics, market growth should support demand confidence but not a precise valuation multiple or revenue TAM.[CM008, CM011, CM012, CM013, CM014, CM015, CM016]

2.5 Exhibits

3.1 Landscape and competitive set

The relevant competitive set is broader than software vendors. Aledade is positioned against health-system-led ACOs, payer-led enablement, other physician-aggregation platforms, internal practice builds, and the fee-for-service status quo. CMS reported 511 Shared Savings Program ACOs serving 12.6 million traditional Medicare beneficiaries in 2026, so the policy infrastructure is a large platform on which multiple operating models can compete. Aledade's 2026 company announcement says it served more than 3,000 primary care partners and nearly 20% of total MSSP; those figures are company-issued and should not be read as independent market share verification. The competitor profile below therefore separates named counterparties from structural alternatives and marks missing public data rather than filling it with assumptions.[CP001, CP002, CP003, CP004]

3.2 Capability, distribution, and trust

Aledade's stated differentiation is an integrated operating model rather than a single application: analytics, guided workflows, regulatory expertise, payer relationships, and local support. An Ohio Academy of Family Physicians article describes the offer as data analytics, guided workflows, regulatory expertise, payer relationships, and hands-on local support, while the Elevance partnership shows a distribution route into independent practices in plans serving 47 million members. Aledade's own materials also emphasize that it does not own or manage practices and that partners retain clinical and operational autonomy. These are meaningful buying criteria for independent physicians, but the sources do not provide a controlled comparison of implementation time, product performance, or retention against competitors. The matrix consequently uses unknown where the pool does not support a fair comparison.[CP005, CP006, CP007, CP008]

3.3 Pricing, packaging, and switching

Public evidence does not disclose a comparable list price or realized take-rate for Aledade, Elevance's arrangement, health-system programs, or internal builds. The older Ohio physician-facing description says 90% of Aledade revenue came from helping practices achieve shared savings, but that is a historical company-facing statement rather than a current audited revenue mix. It does clarify the economic design: the platform participates in outcome-linked upside instead of charging a transparent per-seat price. The resulting switching cost is likely operational and contractual—data integration, workflows, ACO participation, payer relationships, and practice trust—but the retained sources do not quantify migration cost, exclusivity, contract duration, or multi-homing. Those gaps matter because a broad network can be a moat only if partners stay, savings are repeatable, and competing channels cannot reproduce the service bundle.[CP009, CP010, CP011]

3.4 Moat durability and displacement risk

Aledade has evidence of scale and partner distribution, but durability remains conditional. Fierce Healthcare reported that the company used financing and acquisitions to add capabilities and described its differentiation as growth, multi-payer contracting, and repeatable savings; that is third-party reporting of management's position, not a benchmark. The company's 2026 release reports that 93% of its ACOs achieved savings in the most recent MSSP performance year and that more than $1 billion in savings was generated, while CMS independently reports $4.1 billion of total MSSP shared savings in performance year 2024. The figures use different populations and issuers, so they cannot establish a relative win rate. The principal displacement risks are payer or health system ownership of distribution, direct internal analytics investment, regulatory redesign, and commoditization of workflow tooling. No retained source supplies competitor churn, pricing pressure, or a failed Aledade deployment; these remain explicit diligence gaps rather than negative conclusions.[CP012, CP013, CP014]

3.5 Exhibits

4.1 Revenue model and monetization

Aledade's older partner-facing description says 90% of revenue came from helping practices achieve shared savings, while Multiples labels the model "subscription" without publishing a price, unit, or revenue mix. The company also provides analytics, guided workflows, regulatory expertise, payer relationships, and care solutions. Current disclosures show exposure across MSSP, Medicare Advantage, Medicaid, and commercial contracts, but do not disclose the split between recurring technology fees, shared-savings participation, care-delivery revenue, or other streams. Revenue should therefore be treated as outcome-dependent and timing-sensitive rather than equated with ARR.[CI001, CI002, CI003, CI004]

4.2 Public traction versus private financial gaps

Public operating indicators show substantial scale: Aledade says it supports more than 3,000 primary-care partners and over 3 million patients in 2026, while a 2023 independent trade report cited $475 million of 2022 revenue and more than 50% growth. A 2022 Elevance partnership also exposed affiliated-plan providers in networks serving 47 million members to Aledade's offering, illustrating a payer-channel GTM route rather than its economics. These figures use different periods and denominators, and company savings figures are not Aledade revenue. The record still lacks audited revenue mix, gross margin, CAC or payback, retention, concentration, cash flow, and net debt.[CI004, CI005, CI006, CI007, CI008]

4.3 Cost structure, working capital, and policy exposure

Aledade's delivery model requires technology, regulatory expertise, local support, clinical interfaces, and shared-savings distributions to physician partners. Its CMS comments identify data-access fees and reporting burdens as material ACO costs, including an example where vendor fees could consume 20% of MSSP revenue for an ACO with extensive specialty participation. A joint lender announcement says Medicare payment timing creates a working-capital gap, while Aledade separately cautions that shared savings are not guaranteed. Risk-based arrangements can require downside payments when spending rises, and KFF's 2026 Medicare Advantage analysis highlights payment scrutiny around the segment. No source establishes Aledade's own burn or gross margin.[CI009, CI010, CI011, CI012, CI013]

4.4 Capital adequacy and financial verdict

Aledade announced a $500 million senior secured Ares facility with capacity to expand to $650 million and said it doubles committed financing capacity; the stated use is working-capital flexibility, including bridging Medicare-payment timing and accelerating partner distributions. This is financing capacity, not cash on hand, and the public materials do not state drawn balance, interest cost, covenants, maturity, collateral, or runway. Historical funding and valuation markers provide context but do not prove current liquidity. The financial case is attractive on operating scale and policy tailwinds, yet underwriting should remain research-more until unit economics, cash conversion, debt terms, and contract-level concentration are disclosed.[CI009, CI014, CI015, CI017]

4.5 Exhibits

5.1 Customer workflow and product surface

Aledade's customer is an independent primary-care organization that wants to participate in accountable care without surrendering clinical or operational autonomy. The documented workflow starts with access to EHR, hospital-event, laboratory, pharmacy, practice-generated, and payer-claims data, then uses patient prioritization, risk suggestions, and preventive-care opportunities to direct outreach and point-of-care action. Aledade's public materials describe both software and a hands-on operating layer: guided ACO initiatives, regulatory expertise, payer relationships, EHR optimization, workflow redesign, and local practice-transformation specialists. This makes the product closer to a technology-enabled service and risk-sharing operating model than a standalone SaaS application. The strongest recent integration proof is Aledade Assist, an embedded EHR overlay described as using AI-enabled computer vision to place patient insights inside an existing clinician workflow. That reduces context switching, but public sources do not establish supported EHR coverage, latency, model evaluation, or error-handling standards.[CE001, CE002, CE003, CE004]

5.2 Operating architecture and dependencies

The observable architecture has four layers: heterogeneous clinical and claims inputs; analytics and prioritization; an EHR-facing workflow surface; and human implementation and care-transformation support. The model depends on timely, interoperable data from EHRs, hospitals, laboratories, pharmacies, and payers, as well as contracts that define attribution, quality measurement, and shared-savings economics. Aledade's 2022 partner announcement described a suite of technology plus local in-person services available to practices in Elevance-affiliated plans, while its own 2026 materials describe service across 46 states and the District of Columbia through 68 ACOs. External descriptions support the existence of the model, but not its APIs, hosting design, data-governance controls, uptime, or integration economics. The resulting diligence issue is execution at scale: the workflow must make correct, timely data actionable across varied practice environments while preserving physician independence.[CE006, CE007, CE008, CE009]

5.3 Maturity, differentiation, and proof

Aledade has operated since 2014 and public evidence indicates a mature commercial footprint: more than 3,000 primary-care partners and more than 3 million patients in value-based programs for the 2026 performance year, with work across 46 states and the District of Columbia. Its differentiation is a coordinated combination of physician-led governance, payer and regulatory expertise, local delivery, proprietary analytics, and distribution into value-based contracts. Fierce Healthcare reported a build-and-buy roadmap through acquisitions of analytics provider Curia and patient-care provider Iris Healthcare. Recent company-reported outcomes include 93% of its accountable care organizations achieving savings in the most recent MSSP performance year and more than $1 billion in total savings, while a healthcare-IT article describes Aledade Assist in a named physician workflow. These remain a mix of company claims, partner material, and reported interviews rather than an independent technical benchmark. The GitHub search surface returned a generic repository-results page whose visible entries did not establish an official Aledade public developer platform.[CE005, CE010, CE011, CE012, CE013]

5.4 Trust, safety, and implementation risks

The product operates in a high-consequence clinical and regulated reimbursement context. Public materials emphasize regulatory expertise, quality reporting, and proactive care, but the assigned evidence does not document a security certification, breach history, model card, clinical validation protocol, audit-log design, role-based access controls, or incident-response commitments. Aledade Assist's use of AI-enabled computer vision creates a specific diligence need around missed or misclassified information, human review, explainability, and safe fallback when source records are incomplete. The delivery model also inherits payer-policy and data-availability risk: Medicare Advantage enrollment and ACO participation are large and growing markets, but payment and attribution rules can change. A buyer or investor should therefore request integration references, supported-EHR and data-source inventories, service-level metrics, security attestations, AI governance materials, and customer-level evidence that reported savings and workflow benefits are reproducible.[CE014, CE015, CE016]

5.5 Exhibits

6.1 Customer segments and buying model

Aledade's disclosed customer base centers on independent primary care organizations: practices, clinics, community health centers, and systems entering value-based contracts without selling their practices to the platform. The clinician and care team are the daily users, while Medicare programs, Medicare Advantage plans, Medicaid programs, and commercial payers fund the underlying care arrangements. Aledade reported more than 370 community health centers in its 2026 network and said more than 60% of partner practices were in federally designated health professional shortage areas, indicating meaningful safety-net penetration. A historical Ohio Academy of Family Physicians promotional article said 90% of Aledade's revenue came from helping practices achieve shared savings. That issuer relationship makes the statement directional rather than independently verified, but it clarifies that customer value and Aledade's monetization have been linked to care-cost performance.[CU001, CU002, CU003, CU009]

6.2 Adoption trajectory and operating proof

The strongest current adoption marker is Aledade's February 2026 announcement that it added more than 700 primary care organizations for the performance year, bringing the network to more than 3,000 partners and over 3 million patients. Aledade also said it served one in five new Medicare Shared Savings Program participants and nearly 20% of the total program. The trajectory is directionally consistent with earlier snapshots: an independent 2016 article described 400 physicians across 11 states; Elevance and Baidu materials described more than 1,000 practices and 1.7 million patient lives in 2022; and Fierce Healthcare reported more than 1,500 practices and over 2 million patients in 2023. These vintages use different units and issuers, so they demonstrate expansion but do not form a clean retention cohort or a like-for-like annual customer series.[CU001, CU002, CU004, CU005, CU010, CU011, CU012]

6.3 Production outcomes and named channel proof

Aledade's reported outcomes indicate operating activity beyond a logo list. It said 93% of its accountable care organizations achieved savings in the most recent MSSP performance year and that those organizations generated more than $1 billion in total savings; it separately reported more than 800,000 annual wellness visits by MSSP partners in 2024. These are company-issued program metrics rather than audited customer retention measures, and the relevant denominators and distribution across practices are not public. Named commercial evidence is primarily channel evidence: Elevance announced access to Aledade technology and local services for independent providers in affiliated-plan networks, while Fierce Healthcare reported partnerships with Humana, CareFirst BlueCross BlueShield, and Cigna. The disclosures establish routes to production adoption, but they do not reveal conversion, active deployment, renewal, exclusivity, or customer-level economics.[CU006, CU007, CU008, CU013, CU014]

6.4 Durability, expansion, and concentration risks

Publicly disclosed scale should not be read as retention. The assigned evidence does not provide NRR, GRR, churn, renewal rates, contract duration, average customer value, or top-payer, top-practice, top-region, and top-customer concentration. The external market is large: Becker's reported 511 MSSP ACOs serving 12.6 million traditional Medicare beneficiaries in 2026. It is also concentrated in an adjacent payer channel: KFF found that UnitedHealth Group and Humana together represented 46% of nationwide Medicare Advantage enrollment in 2026. That statistic is not Aledade-specific concentration, but it illustrates why payer-level exposure and contract dependency must be tested rather than inferred from the broad practice count. Diligence should reconcile signed, live, renewed, expanded, and terminated practices to revenue, shared-savings receipts, and attributed patients by payer and cohort.[CU015, CU016]

6.5 Exhibits

7.1 Ranked risk posture and investment implications

The highest residual risk is coding and program-integrity exposure. Independent reporting documented allegations that Aledade's software and guidance encouraged unsupported diagnoses; Aledade denied those allegations. The private action later ended in a $300,000 judgment and dismissal of the parties' claims and counterclaims with prejudice, but the judgment states that it did not affect the earlier dismissal without prejudice of the United States' False Claims Act claims. That is not evidence of a current government claim, yet it prevents treating the private resolution as a complete regulatory release. Medicare-policy exposure ranks next because the business operates at meaningful MSSP scale while 2026 rules shorten the upside-only runway and alter quality scoring. Operational exposure is lower in immediate severity but broad in reach: public evidence shows useful program-level mitigations, not enterprise-wide control testing. Investment approval should therefore require legal, compliance, security, insurance, and covenant evidence rather than rely on the absence of another publicly recorded incident.[CR001, CR002, CR003, CR015, CR016]

7.2 Regulatory and legal exposure

Medicare rules are both the demand engine and the principal external control surface. CMS's TEAM model is mandatory in selected geographies for 2026 through 2030, permits beneficiaries to be in both TEAM and ACO initiatives, and requires participating hospitals to refer patients to primary care. This creates coordination opportunity but also more interfaces, attribution questions, and accountability across organizations. Separately, the AMA reports that CMS will reduce the maximum upside-only MSSP period from seven to five years for agreement periods beginning in 2027 and removed the health-equity adjustment from ACO quality scores beginning with performance year 2025. These are enacted policy changes, not company-specific failures, but their economics should be modeled against Aledade's actual contract cohorts. The legal diligence path is similarly concrete: reconcile the 2025 judgment, any government reservation, coding-audit results, and insurance coverage before underwriting residual exposure.[CR001, CR004, CR005, CR007, CR008, CR016]

7.3 Operational, quality, and security risk

A supplier case study demonstrates both a control weakness and a mitigation pattern. Aledade reported reliance on payer claims that lagged by two to three months; a pilot used pharmacy history data to reduce false-positive medication-adherence outreach by 585 of 2,235 identified opportunities. The same case study says the pilot initially required a three-person team and manual integration work, showing that data quality can be improved but may introduce supplier, workflow, and scaling dependencies. Those historical results should not be generalized to the current network without fresh control evidence. None of the retained sources provides enterprise-wide proof of security testing, incident response, data-reconciliation coverage, recovery objectives, or third-party risk controls. These are gaps, not evidence of a breach. A material control deficiency, sustained data latency, or inability to reconcile payer and clinical records should be a thesis-break trigger.[CR011, CR012, CR013, CR015]

7.4 Partner, network, and financial-model dependencies

The model depends on counterparties at several layers: CMS and commercial payers define economic rules, independent practices execute workflows, and data suppliers improve the timeliness and accuracy of interventions. Aledade says it serves more than 3,000 primary-care partners and more than 3 million patients, and nearly 20% of the total MSSP. Those company-issued figures indicate reach, not verified concentration or retention. An older partner-hosted promotional page stated that 90% of revenue came from helping practices achieve shared savings, but no retained current source provides audited revenue mix, payer concentration, contract duration, downside-risk exposure, or practice churn. Meanwhile, third-party analysis of TEAM projects losses for many mandatory hospital participants under current criteria, illustrating how policy design can redistribute economics even when value-based care demand persists. Underwriting should require cohort-level economics and counterparty concentration before crediting scale as resilience.[CR004, CR005, CR006, CR009, CR010, CR011, CR014]

7.5 Exhibits

8.1 Investment case and anti-thesis

The positive case is operating scale in a structurally supported market. Aledade says it serves more than 3,000 primary care partners and more than 3 million patients in 2026, while its 2024 MSSP results included more than $1 billion of savings and 93% of its accountable care organizations achieving savings. Elevance previously described more than 1,000 practices, 1.7 million lives, and more than 140 contracts in 2022, providing independent partner evidence that the model had commercial reach before the latest expansion. The anti-thesis is that these operating metrics are not revenue, ARR, margin, cash flow, or investor returns. Aledade's model depends on payer programs, shared-savings realization, and execution across heterogeneous practices; CMS's 2026 policy changes show that reimbursement and payment accuracy rules can change the economics of provider participation. The company therefore merits a scalable-platform thesis, but not a buy call without audited financials and transaction terms.[CV001, CV002, CV003, CV004, CV005, CV006]

8.2 Price discipline and scenario framework

The latest public financing evidence is historical and incomplete. Fierce Healthcare reported a $260 million Series F in 2023, a $3.5 billion valuation attributed to Bloomberg sources, and $660 million raised to date; Dealroom's 2026 profile maps 15 investors but labels its ownership data estimated and says some investors are hidden. Neither source supplies a current primary transaction, fully diluted capitalization, liquidation preferences, debt, or secondary-market depth. For a private, value-based-care enablement company, the first-pass method should be a revenue or gross-profit multiple only after audited revenue composition and margin are obtained; using a public provider-enablement comparator as a directional market check is more defensible than importing a software ARR multiple. Agilon Health's market capitalization was $1.50 billion on October 23, 2026, while CVS completed the Oak Street acquisition at approximately $10.6 billion enterprise value in 2023. Those are not apples-to-apples valuations, but they provide directional public-market and strategic-transaction context.[CV007, CV008, CV009, CV010, CV011, CV012]

8.3 Recommendation, downside triggers, and exit readiness

The recommendation is research-more with medium confidence and high risk: the business has credible adoption signals, but the price-sensitive inputs remain private. The base case should assume continued partner growth but no automatic conversion of reported savings or patient coverage into company revenue. A bull case requires audited growth, durable shared-savings economics, improving contribution margin, and a financing or secondary reference inside the indicated range. A bear case is triggered by a down round, materially lower realized savings, payer-policy changes that reduce contract economics, rising losses, or evidence that growth requires disproportionate capital. CMS's rulemaking and Aledade's reliance on multiple contract types make policy and execution diligence central. Exit readiness is plausible through strategic healthcare buyers or a public-market path, but Aledade's 2023 CEO comments explicitly said an IPO was a possible means rather than a destination; no current timetable is public. Request the cap table, preference waterfall, debt covenants, audited statements, revenue-recognition bridge, cohort retention, payer concentration, and latest financing documents before committing.[CV013, CV014, CV015, CV016]

8.4 Exhibits