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Full title: Omnibus Objection to Claims [Third] (Non-Substantive) Pursuant to Section 502 of the Bankruptcy Code, Bankruptcy Rule 3007 and Local Rule 3007-1. Filed by Plan Administrator. Hearing scheduled for 9/27/2021 at 01:00 PM at US Bankruptcy Court, 824 Market St., 3rd Fl., Courtroom #7, Wilmington, Delaware. Objections due by 9/3/2021. (Attachments: # 1 Notice # 2 Exhibit 1 # 3 Exhibit 2) (Feldman, Betsy) (Entered: 08/20/2021)

Document posted on Aug 19, 2021 in the bankruptcy, 8 pages and 0 tables.

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(the “Bankruptcy Code”), Rule 3007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 3007-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), to each of the claims filed against the Debtor and its estate that are listed on Exhibit A (collectively, the “Disputed Claims”)2 to the proposed form of order attached 1 On April 28, 2020, the Court entered an order [Docket No. 125] (the “Bar Date Order”) providing that, except as otherwise provided therein, (i) each person or entity (including, without limitation, individuals, partnerships, corporations, joint ventures and trusts), other than governmental units, must file a proof of claim based on any asserted claims against the Debtor that arose prior to the Petition Date, including requests for allowance and payment of claims under section 503(b)(9) of the Bankruptcy Code for goods delivered and received by the Debtor in the 20 days prior to the Petition Date on or before 5:00 p.m. (prevailing Eastern Time) on July 6, 2020 (the “General Bar Date”), and (ii) any governmental unit, as defined in section 101(27) of the Bankruptcy Code, shall file a proof of any such claim so that it is actually received on or before 5:00 p.m. (prevailing Eastern Time) on August 24, 2020 (the “Government Bar Date”).The Bar Date Order also provides that if the Debtor amends or supplements the Schedules subsequent to the date of service of the Bar Date Notice (as defined in the Bar Date Order), then the Debtor shall give notice of any such amendment or supplement to the holders of claims affected thereby, and such holders shall be afforded the later of (i) the General Bar Date or Government Bar Date, as applicable, and (ii) 5:00 p.m. (prevailing Eastern Time) on the date that is twenty-one (21) days from the date on which such notice is given, to file proofs of claim in respect of their claims (the “Supplemental Schedules Bar Date”).Additionally, pursuant to the Bar Date Order, except as otherwise provided by another order of the Court, any person or entity that holds a claim (each, a “Rejection Damages Claim”) that arises from the rejection of an executory contract or unexpired lease must file a proof of claim based on such rejection on or before the later of (i) 5:00 p.m. (prevailing Eastern Time) on the date that is thirty-five (35) days following the entry of the order approving the rejection of the executory contract or unexpired lease pursuant to which the entity asserting the Rejection Damages Claim is a party, and (ii) the General Bar Date (collectively with the General Bar Date, the Government Bar Date, the Supplemental Schedules Bar Date and the Rejection Bar Date, the “Bar Dates”).The Bar Date Order also provides that the following parties, among others, need not file proofs of interest with respect to the ownership of equity interest in the D

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 SUITABLE TECHNOLOGIES, INC.,1 Case No. 20-10432 (CTG) Debtor. Hearing Date: September 27, 2021 at 1:00 p.m. (ET) Response Deadline: September 3, 2021 at 4:00 p.m. (ET) PLAN ADMINISTRATOR’S THIRD (3RD) OMNIBUS (NON-SUBSTANTIVE) OBJECTION TO CLAIMS PURSUANT TO SECTION 502 OF THE BANKRUPTCY CODE, BANKRUPTCY RULE 3007 AND LOCAL RULE 3007-1 PARTIES RECEIVING THIS OBJECTION SHOULD LOCATE THEIR NAMES AND THEIR DISPUTED CLAIMS IDENTIFIED ON EXHIBIT A TO THE PROPOSED ORDER Charles C. Reardon, as plan administrator (the “Plan Administrator”) for Suitable Technologies, Inc., the debtor in the above-captioned chapter 11 case (the “Post-Effective Date Debtor” and before the effective date of the chapter 11 plan confirmed by this Court, the “Debtor”), hereby files this objection (this “Objection”), pursuant to section 502 of title 11 of the United States Code, 11 U.S.C. §§ 101 et seq. (the “Bankruptcy Code”), Rule 3007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 3007-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), to each of the claims filed against the Debtor and its estate that are listed on Exhibit A (collectively, the “Disputed Claims”)2 to the proposed form of order attached 1 The last four digits of the Debtor’s United States federal tax identification number are 7816. The Debtor’s mailing address is 921 East Charleston Road, Palo Alto, CA 94303. 2 The Debtor does not object to any claims listed on Exhibit A to the Proposed Order that are identified under the heading titled “SURVIVING CLAIM” (the “Surviving Claim”), and the term “Disputed Claim,” as used herein, does not include any such Surviving Claim. 8452181.2

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hereto as Exhibit 2 (the “Proposed Order”), and requests the entry of the Proposed Order disallowing the Disputed Claims, as indicated in further detail below and on Exhibit A to the Proposed Order. In support of this Objection, the Plan Administrator relies on the declaration of Charles C. Reardon (the “Reardon Declaration”), a copy of which is attached hereto as Exhibit 1. In further support of this Objection, the Plan Administrator respectfully represents as follows: JURISDICTION AND VENUE 1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334, and the Amended Standing Order of Reference from the United States District Court for the District of Delaware, dated as of February 29, 2012 (the “Amended Standing Order”). This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2), and the Court may enter a final order consistent with Article III of the United States Constitution. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409. The statutory and legal predicates for the relief sought herein are section 502 of the Bankruptcy Code, Bankruptcy Rule 3007 and Local Rule 3007-1. GENERAL BACKGROUND 2. On February 26, 2020 (the “Petition Date”), the Debtor commenced a voluntary case (the “Chapter 11 Case”) under chapter 11 of title 11 of the United States Code, 11 U.S.C. §§ 101 et seq. (the “Bankruptcy Code”). From the Petition Date through the Effective Date of the Plan (each as defined below), the Debtor managed its financial affairs as a debtor in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 3. As set forth in the Declaration of Charles C. Reardon in Support of the Debtor’s Chapter 11 Petition and First Day Pleadings [Docket No. 7], the Debtor commenced the Chapter 11 Case to continue the process of winding down its business affairs and to conduct a sale process (the “Sale Process”) for substantially all of its assets pursuant to section 363 of the Bankruptcy Code. On April 20, 2020, the Court entered an order [Docket No. 110] (the “Bidding 8452181.2

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Procedures Order”) establishing, among other things, certain bidding and auction procedures in connection with the Sale Process. In accordance with the Bidding Procedures Order, the Debtor, in consultation with its professional advisors, conducted a thorough marketing and auction process for its assets. At the conclusion of the auction, the Debtor designated Blue Ocean Robotics ApS and Magicheart Investments LLC as the successful bidders for the assets contemplated to be purchased pursuant to their respective asset purchase agreements. On August 20, 2020, the Court entered orders [Docket Nos. 225 and 226] approving such sales (the “Sales”). The Sales closed on August 21, 2020. 4. On June 23, 2021, the Court entered the Findings of Fact, Conclusions of Law, and Order Confirming the Chapter 11 Plan of Liquidation of Suitable Technologies, Inc. [Docket No. 456] (the “Confirmation Order”), whereby the Chapter 11 Plan of Liquidation of Suitable Technologies, Inc. (including all exhibits and supplements thereto, and as amended, modified or supplemented from time to time, the “Plan”) was confirmed.3 On June 29, 2021, the Plan became effective (the “Effective Date”). Pursuant to Section 5.4 of the Plan and the Plan Administrator Agreement, the Plan Administrator was appointed as the sole representative of the Post-Effective Date Debtor. 5. Now that the Effective Date has occurred, the Plan Administrator is continuing to wind down the affairs of the Post-Effective Date Debtor in an orderly and efficient manner. DEBTOR’S SCHEDULES 6. On April 24, 2020, the Debtor filed its Schedules of Assets and Liabilities [Docket No. 120] (as may be amended, modified or supplemented, the “Schedules”). 3 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the Plan. 8452181.2

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PROOFS OF CLAIM AND BAR DATE ORDER 7. On March 23, 2020, the Court entered an order [Docket No. 13] appointing Donlin Recano & Company, Inc. (“DRC”) as claims and noticing agent in the Chapter 11 Case. Among other things, DRC is authorized to (a) receive, maintain, and record and otherwise administer the proofs of claim filed in the Chapter 11 Case and (b) maintain an official claims register for the Debtor. 8. On April 28, 2020, the Court entered an order [Docket No. 125] (the “Bar Date Order”) providing that, except as otherwise provided therein, (i) each person or entity (including, without limitation, individuals, partnerships, corporations, joint ventures and trusts), other than governmental units, must file a proof of claim based on any asserted claims against the Debtor that arose prior to the Petition Date, including requests for allowance and payment of claims under section 503(b)(9) of the Bankruptcy Code for goods delivered and received by the Debtor in the 20 days prior to the Petition Date on or before 5:00 p.m. (prevailing Eastern Time) on July 6, 2020 (the “General Bar Date”), and (ii) any governmental unit, as defined in section 101(27) of the Bankruptcy Code, shall file a proof of any such claim so that it is actually received on or before 5:00 p.m. (prevailing Eastern Time) on August 24, 2020 (the “Government Bar Date”). 9. The Bar Date Order also provides that if the Debtor amends or supplements the Schedules subsequent to the date of service of the Bar Date Notice (as defined in the Bar Date Order), then the Debtor shall give notice of any such amendment or supplement to the holders of claims affected thereby, and such holders shall be afforded the later of (i) the General Bar Date or Government Bar Date, as applicable, and (ii) 5:00 p.m. (prevailing Eastern Time) on the date that is twenty-one (21) days from the date on which such notice is given, to file proofs of claim in respect of their claims (the “Supplemental Schedules Bar Date”). 8452181.2

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10. Additionally, pursuant to the Bar Date Order, except as otherwise provided by another order of the Court, any person or entity that holds a claim (each, a “Rejection Damages Claim”) that arises from the rejection of an executory contract or unexpired lease must file a proof of claim based on such rejection on or before the later of (i) 5:00 p.m. (prevailing Eastern Time) on the date that is thirty-five (35) days following the entry of the order approving the rejection of the executory contract or unexpired lease pursuant to which the entity asserting the Rejection Damages Claim is a party, and (ii) the General Bar Date (collectively with the General Bar Date, the Government Bar Date, the Supplemental Schedules Bar Date and the Rejection Bar Date, the “Bar Dates”). 11. The Bar Date Order also provides that the following parties, among others, need not file proofs of interest with respect to the ownership of equity interest in the Debtor: any person or entity that holds a direct or indirect interest in the Debtor, which interest is based exclusively upon the ownership of equity interests, or rights to purchase, sell, or subscribe to such an interest; provided, however, that interest holders who wish to assert claims (as opposed to ownership interests) the Debtor, including, without limitation, claims that arise out of or relate to the ownership or purchase of an interest, or the sale, issuance, or distribution of the interest, must file [proofs of claims] on or before the applicable Bar Date unless another exception identified herein applies . . . 12. Notice of the Bar Dates was provided by mail and publication in accordance with the procedures outlined in the Bar Date Order. 13. In addition, the Confirmation Order and Plan established a deadline for filing Rejection Claims within 35 days of the Effective Date, which date was August 3, 2021. Conf. Order ¶ 19; Plan § 6.1. RELIEF REQUESTED 14. By this Objection, the Plan Administrator requests that the Court enter the Proposed Order, pursuant to section 502(b) of the Bankruptcy Code, Bankruptcy Rule 3007 and 8452181.2

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Local Rule 3007-1, disallowing the Disputed Claims, as indicated in further detail below and on Exhibit A to the Proposed Order. 15. In accordance with Local Rule 3007-1(e)(i)(E), the Plan Administrator believes that this Objection complies in all material respects with Local Rule 3007-1. OBJECTION TO DISPUTED CLAIMS 16. The Disputed Claims identified under the heading titled “DISPUTED CLAIM” on Exhibit A to the Proposed Order have been amended and superseded by subsequently filed proofs of claim identified under the heading titled “SURVIVING CLAIM” on Exhibit A to the Proposed Order. The Disputed Claims thus no longer represent a valid claim against the Debtor’s estate. Pursuant to Bankruptcy Rule 3007(d), a debtor may object to claims and seek their disallowance where such claims “have been amended by subsequently filed proofs of claim.” Fed. R. Bankr. P. 3007(d)(3). Any failure to disallow the Disputed Claims will result in the applicable claimant potentially receiving an unwarranted double recovery against the Debtor’s estate, to the detriment of other creditors in the Chapter 11 Case. 17. Accordingly, the Plan Administrator objects to the Disputed Claims, and requests entry of the Proposed Order disallowing the Disputed Claims. RESPONSES TO THIS OBJECTION 18. Any responses to this Objection must be filed on or before 4:00 p.m. (ET) on September 3, 2021, in accordance with the procedures set forth in the notice of this Objection. RESERVATION OF RIGHTS 19. The Plan Administrator reserves the right to adjourn the hearing on any Disputed Claim, and in the event that the Plan Administrator does so, the Plan Administrator will 8452181.2

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state the same in the agenda for the hearing on that Disputed Claim, which agenda will be served on the claimant. 20. The Plan Administrator reserve any and all rights to amend, supplement or otherwise modify this Objection, the Proposed Order or Exhibit A thereto, and to file additional objections to any and all claims filed in the Chapter 11 Case, including, without limitation, any and all of the Disputed Claims and the Surviving Claims. The Plan Administrator also reserve any and all rights, claims and defenses with respect to any and all of the Disputed Claims and the Surviving Claims, and nothing included in or omitted from this Objection, the Proposed Order or Exhibit A thereto is intended or shall be deemed to impair, prejudice, waive or otherwise affect any rights, claims, or defenses of the Plan Administrator, the Post-Effective Date Debtor and its estate with respect to the Disputed Claims and the Surviving Claims. NOTICE 21. Notice of this Objection has been provided to the following parties: (i) the Office of the United States Trustee for the District of Delaware; (ii) those creditors holding the largest unsecured claims against the Debtor’s estate (excluding insiders); (iii) claimants whose Disputed Claims are subject to the Objection; and (iv) all parties who, as of the filing of the Objection, have requested notice in the Chapter 11 Case pursuant to Bankruptcy Rule 2002. The Plan Administrator submits that, in light of the nature of the relief requested, no other or further notice need be given. CONCLUSION WHEREFORE, for the reasons set forth herein, the Plan Administrator respectfully requests that the Court (a) enter the Proposed Order, and (b) grant such other and further relief as may be just and proper. 8452181.2

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Dated: August 20, 2021 YOUNG CONAWAY STARGATT & TAYLOR, LLP Wilmington, Delaware /s/ Betsy L. Feldman Robert S. Brady (No. 2847) Robert F. Poppiti, Jr. (No. 5052) Betsy L. Feldman (No. 6410) 1000 North King Street Wilmington, Delaware 19801 Telephone: (302) 571-6600 Facsimile: (302) 571-1253 Emails: rbrady@ycst.com rpoppiti@ycst.com bfeldman@ycst.com Counsel to the Plan Administrator 8452181.2

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