The documentary evidence submitted by defendant established that FHU Holdco II, LLC (Holdco II) was not a Ulukaya Entity as defined in the parties' settlement agreement. It did not hold defendant's equity interest in FHU US Holdings, LLC (US Holdings), as required by the agreement. Rather, it held warrants that it had purchased from entities unrelated to defendant, which warrants were turned into preferred units of US Holdings.
In reply, plaintiff contends that Holdco...
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