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Full title: Certification of Counsel in Support of Entry of Order Approving Stipulation of Settlement Regarding (A) Emergency Motion of the Cred Inc. Liquidation Trust to (I) Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYa Investments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums and (B) All Potential Claims Between and Among UpgradeYa and the Debtors' Estates (related document(s)786, 802, 803, 809) Filed by Cred Inc. Liquidation Trust. (Attachments: # 1 Exhibit A) (Hurst, David) (Entered: 08/02/2021)

Document posted on Aug 1, 2021 in the bankruptcy, 4 pages and 0 tables.

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Liquidation Trust to (I) Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYa Investments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums [Docket No.Contemporaneously, the Trust filed the Motion to Shorten Time for Notice ofEmergency Motion of the Cred Inc. Liquidation Trust to (I) Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYa Investments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums [Docket No.On June 3, 2021, UpgradeYa filed the Objection of UpgradeYa Investments, LLCto the Interim Relief Requested in the Emergency Motion of the Cred Inc. Liquidation Trust to (I)Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYaInvestments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums [Docket No. 802]After the June 4 hearing, the Court entered the Interim Order GrantingEmergency Motion of the Cred Inc. Liquidation Trust to (I) Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYa Investments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums [Docket No. 809] (the “Interim Order”).As a result of these negotiations, the Trust and UpgradeYa have entered into thatcertain Stipulation of Settlement Regarding (A) Emergency Motion of the Cred Inc. Liquidation Trust to (I) Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYa Investments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums and (B)All Potential Claims Between and Among UpgradeYa and the Debtors’ Estates (the“Stipulation”), fully resolving all disputes between the parties.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) Chapter 11 In re: ) ) Case No. 20-12836 (JTD) CRED INC., et al., ) ) (Jointly Administered) Debtors.1 ) ) Related to Docket Nos. 786, 802, 803, 809 ) CERTIFICATION OF COUNSEL IN SUPPORT OF ENTRY OF ORDER APPROVING STIPULATION OF SETTLEMENT REGARDING (A) EMERGENCY MOTION OF THE CRED INC. LIQUIDATION TRUST TO (I) ENFORCE THE CHAPTER 11 PLAN AND CONFIRMATION ORDER AND (II) ENJOIN UPGRADEYA INVESTMENTS, LLC FROM PROSECUTING THE CIVIL ACTION AND SIMILAR CLAIMS IN OTHER FORUMS AND (B) ALL POTENTIAL CLAIMS BETWEEN AND AMONG UPGRADEYA AND THE DEBTORS’ ESTATES The undersigned, counsel to the Cred Inc. Liquidation Trust (the “Trust”) established in the above-captioned chapter 11 cases of Cred Inc. and its affiliated debtors (collectively, the “Debtors”), hereby certifies as follows: 1. On May 24, 2021, the Trust filed the Emergency Motion of the Cred Inc. Liquidation Trust to (I) Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYa Investments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums [Docket No. 786] (the “Motion to Enjoin”).2 Pursuant to the Motion to Enjoin, the Trust sought interim relief staying the Civil Action pending final adjudication of the Motion to Enjoin. 1 The Debtors in these Chapter 11 Cases, along with the last four digits of each Debtor’s tax identification number, as applicable, are as follows: Cred Inc. (8268), Cred (US) LLC (5799), Cred Capital, Inc. (4064), Cred Merchant Solutions LLC (3150), and Cred (Puerto Rico) LLC (3566). The Debtors’ mailing address is 3 East Third Avenue, Suite 200, San Mateo, California 94401. 2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Motion to Enjoin.

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2. Contemporaneously, the Trust filed the Motion to Shorten Time for Notice ofEmergency Motion of the Cred Inc. Liquidation Trust to (I) Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYa Investments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums [Docket No. 787] (the “Motion to Shorten”). On May 26, 2021, UpgradeYa Investments, LLC (“UpgradeYa”) objected to the Motion to Shorten. See Docket No. 791. 3. Notwithstanding UpgradeYa’s objection, on May 28, 2021, the Court entered anorder granting the Motion to Shorten and scheduled an interim hearing on the Motion to Enjoin for June 4, 2021. See Docket No. 795. 4. On June 3, 2021, UpgradeYa filed the Objection of UpgradeYa Investments, LLCto the Interim Relief Requested in the Emergency Motion of the Cred Inc. Liquidation Trust to (I)Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYaInvestments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums [Docket No. 802] (the “Interim Relief Objection”). On June 4, 2021, the Trust filed its reply to the Interim Relief Objection. See Docket No. 803. 5. After the June 4 hearing, the Court entered the Interim Order GrantingEmergency Motion of the Cred Inc. Liquidation Trust to (I) Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYa Investments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums [Docket No. 809] (the “Interim Order”). Pursuant to the Interim Order, the Civil Action was stayed pending a final hearing on the Motion to Enjoin, which was scheduled for June 17, 2021. 6. Since entry of the Interim Order, the Trust has been engaged in good-faithnegotiations with UpgradeYa Investments, LLC (“UpgradeYa”) in an effort to consensually

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resolve both the Motion to Enjoin and (ii) all potential claims between UpgradeYa and the Debtors’ estates. In connection with these negotiations, the parties agreed to adjourn the June 17 hearing to August 4, 2021. 7. As a result of these negotiations, the Trust and UpgradeYa have entered into thatcertain Stipulation of Settlement Regarding (A) Emergency Motion of the Cred Inc. Liquidation Trust to (I) Enforce the Chapter 11 Plan and Confirmation Order and (II) Enjoin UpgradeYa Investments, LLC from Prosecuting the Civil Action and Similar Claims in Other Forums and (B)All Potential Claims Between and Among UpgradeYa and the Debtors’ Estates (the“Stipulation”), fully resolving all disputes between the parties. 8. The Stipulation and the proposed order approving same have been reviewed andapproved by counsel for UpgradeYa. 9. Accordingly, the Trust respectfully requests that the Court enter the proposedorder, attached hereto as Exhibit A, approving the Stipulation. [Remainder of Page Intentionally Left Blank]

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Dated: Wilmington, Delaware MCDERMOTT WILL & EMERY LLP August 2, 2021 /s/ David R. Hurst David R. Hurst (I.D. No. 3743) 1007 North Orange Street, 10th Floor Wilmington, DE 19801 Telephone: (302) 485-3900 Facsimile: (302) 351-8711 -and - Darren Azman (admitted pro hac vice) 1 Vanderbilt Avenue New York, NY 10017 Telephone: (212) 547-5400 Facsimile: (212) 547-5444 Counsel to the Cred Inc. Liquidation Trust

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