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IN THE COURT OF COMMON PLEAS FOR ALLEGHENY COUNTY,

PENNSYLVANIA

COMMONWEALTH OF PENNSYLVANIA, : CIVIL ACTION

OFFICE OF ATTORNEY GENERAL, :

ACTING BY ATTORNEY GENERAL JOSH :

SHAPIRO, :

Petitioner, :

v. : Case No. ___________________

MARRIOTT INTERNATIONAL, INC. :

Respondent. :

ASSURANCE OF VOLUNTARY

COMPLIANCE

Filed on Behalf of Plaintiff:

COMMONWEALTH OF

PENNSYLVANIA, OFFICE

OF ATTORNEY GENERAL

Counsel of Record for this Party:

Jill T. Ambrose

Senior Deputy Attorney General

PA Attorney No. 323549

PA Office of Attorney General

1251 Waterfront Place

Mezzanine Level

Pittsburgh, PA 15222

Telephone: 412-565-3050

Facsimile: 412-880-0196

IN THE COURT OF COMMON PLEAS FOR ALLEGHENY COUNTY,

PENNSYLVANIA

COMMONWEALTH OF PENNSYLVANIA, : CIVIL ACTION

OFFICE OF ATTORNEY GENERAL, :

ACTING BY ATTORNEY GENERAL JOSH :

SHAPIRO, :

Petitioner, :

v. : Case No. ___________________

MARRIOTT INTERNATIONAL, INC. :

Respondent. :

ASSURANCE OF VOLUNTARY COMPLIANCE

AND NOW, comes the Commonwealth of Pennsylvania, Office of Attorney General, by

Attorney General Josh Shapiro, through the Bureau of Consumer Protection (hereinafter

"Commonwealth" or “Petitioner”), which submits this Assurance of Voluntary Compliance

“Assurance”) pursuant to Section 201-5 of the Unfair Trade Practices and Consumer Protection

Law, 73 P.S. § 201-1, et seq. (hereinafter "Consumer Protection Law") and states the following:

WHEREAS, Petitioner is the Commonwealth of Pennsylvania, Office of Attorney

General, through the Bureau of Consumer Protection, with offices located at 1251 Waterfront

Place, Mezzanine Level, Pittsburgh, Pennsylvania 15222; and, 15th Floor, Strawberry Square,

Harrisburg, Pennsylvania 17120; and

WHEREAS, Respondent is Marriott International, Inc. (hereinafter “Marriott”), a

Delaware corporation headquartered in Bethesda, Maryland.

BACKGROUND

1. Marriott is a hospitality company that, directly and/or through its affiliates and

subsidiaries, advertises and offers lodging to consumers at Affiliated Hotels, and Marriott

operates Marriott US Websites. Marriott US Websites (a) advertise and offer reservations at

Affiliated Hotels throughout the world; and (b) allow consumers to search for and secure

reservations at Affiliated Hotels directly on Marriott US Websites.

2. Petitioner alleges that Marriott misrepresented Room Rates, Mandatory Fees, or

Total Price in its advertising to consumers by promoting room prices that did not include all

Mandatory Fees that would be charged to consumers for a stay at Affiliated Hotels, and that such

conduct constitutes unlawful, unfair, and/or deceptive trade practices prohibited by Section 201-3

of the Consumer Protection Law (“Covered Conduct”).

3. Marriott denies it and/or its employees, subsidiaries, operators, licensees,

franchisees, and/or owners of the Affiliated Hotels have violated any statute, regulation, decision,

or other source of law in connection with the practices described in paragraph 2. Marriott

maintains that it did not and does not misrepresent Room Rates, Mandatory Fees, or Total Price

and clearly disclosed all Mandatory Fees. Nothing contained herein may be taken as or

construed to be an admission or concession of any violation of law or regulation, or of any other

matter of fact or law, or of any liability or wrongdoing except as expressly required by state law.

DEFINITIONS

4. For the limited purposes of this Assurance, the following definitions shall apply:

a. “Affiliated Hotels” shall mean any Lodging Establishment operating under

Marriott’s brands that are owned, acquired, managed, leased, licensed,

and/or franchised by Marriott or its hotel lodging subsidiaries.

b. “Clear and Conspicuous” or “Clearly and Conspicuously” shall mean a

statement that, regardless of the medium in which it is made, is readily

understandable and presented in such size, color, contrast, duration and

location, compared to the other information with which it is presented, that

it is readily apparent, readable and understandable. An audio statement or

disclosure shall be delivered in a volume and cadence sufficient for a

consumer to hear and understand the entire statement or disclosure, and

not be obscured in any manner by, for instance, music or other background

noise. A statement may not contradict or be inconsistent with any other

information with which it is presented.

c. “Consumer Protection Law” shall mean the Unfair Trade Practices and

Consumer Protection Law, 73 P.S. § 201-1, et seq.

d. The “Effective Date” of this Assurance shall be the date on which it is

filed in the Allegheny County Court of Common Pleas.

e. “Implementation Date” shall be as soon as reasonable, but no later than

nine (9) months after the Effective Date, taking into account the

comprehensive efforts required by Marriott to update multiple platforms

and systems to ensure complete implementation.

f. “Lodging Establishment” shall mean an inn, hotel, motel, or other similar

establishment advertised on Marriott US Website(s) that offers

accommodations for a fee to transient guests for lodging or sleeping

purposes.

g. “Mandatory Fees” shall mean any fee, by any name, which consumers

must pay in addition to the Room Rate in order to stay at a Lodging

Establishment. For avoidance of doubt, this includes but is not limited to

resort fees, destination fees, facility fees, amenity fees, and service fees, so

long as they are mandatory, but does not include amounts required to be

collected and passed on to any governmental entity or quasi-governmental

entity, such as taxes or government imposed fees. Mandatory Fees also do

not include damage deposits, or optional fees for additional benefits or

services, including but not limited to parking fees.

h. “Parties” shall mean the Petitioner and Marriott, collectively, or

individually, as “Party.”

i. “Room Rate” shall mean the nightly price that consumers are required to

pay for lodging at a Lodging Establishment, exclusive of Mandatory Fees

and other amounts collected and passed on to any governmental entity,

such as taxes or excise payments or other optional fees.

j. “Total Price” shall mean the sum of at least (a) the Room Rate and (b) all

Mandatory Fees.

j. “Marriott US Website(s)” shall mean the website(s) Marriott operates to

advertise or offer reservations directed to consumers in the United States

and the corresponding mobile application Marriott uses to advertise and

offer reservations directed to consumers in the United States.

APPLICATION

5. The provisions of this Assurance apply to Marriott and its officers, directors,

employees, agents, successors, assignees, merged or acquired entities, parent or controlling

entities, and wholly owned subsidiaries in connection with offers of lodging at Affiliated Hotels

on Marriott US Websites. This Assurance shall not apply to negotiated, corporate or group Room

Rates provided there is a written contract, signed by all parties, that Clearly and Conspicuously

discloses all applicable Mandatory Fees to be paid by the contracting party.

ASSURANCE TERMS

6. GENERAL: Marriott shall not engage in any unlawful, unfair, and/or deceptive

trade practices in violation of the Consumer Protection Law with respect to the advertising or

offers of Room Rates, Mandatory Fees, or Total Price.

7. In connection with any advertisement or offer, whether written or oral, Marriott

shall:

a. not make any misrepresentations in connection with the advertising of

Room Rates, Mandatory Fees, or Total Price;

b. inform consumers of all material facts, the omission of which would be

likely to deceive or mislead consumers, in connection with the advertising

of Room Rates, Mandatory Fees, or Total Price; and

c. not mislead consumers regarding Room Rates, Mandatory Fees, or Total

Price they will need to pay to obtain lodging.

The Parties agree that this paragraph, for the purposes of interpreting and enforcing this

Assurance, shall be interpreted and applied in a manner consistent with the Consumer Protection

Law.

8. MOST PROMINENT DISPLAY: In any advertisement or offer for lodging at

Affiliated Hotels that includes a Room Rate that is created by or disseminated by Marriott,

Marriott shall Clearly and Conspicuously disclose all Mandatory Fees and the Total Price.

Additionally, in any written or electronic advertisement or offer that includes a Room Rate that is

created by or disseminated by Marriott, the Total Price shall be the most prominently displayed

price. Nothing contained in this paragraph shall prevent Marriott from providing only the Total

Price in any advertisement or offer, or separately stating or disclosing in such advertisement or

offer the Room Rate and any Mandatory Fees in addition to the Total Price.

9. Marriott shall incorporate into appropriate training and guidance materials a

requirement that, in any oral offer that includes a Room Rate, the Room Rate shall be

accompanied by a Clear and Conspicuous disclosure of all Mandatory Fees and the Total Price.

10. SORT DISPLAY: Whenever Marriott displays room reservation search results on

Marriott US Websites, and those results are sorted by price (e.g., lowest to highest price),

Marriott shall sort the results by the Total Price. For avoidance of doubt, nothing herein shall

require Marriott to sort room reservation search results by price as the default sort order on

Marriott US Websites.

11. TAXES DISPLAY: In any advertisement, price display, or offer that is created by

or disseminated by Marriott that includes separate line items reflecting the elements of the price

that a consumer will be asked to pay for lodging at an Affiliated Hotel, Marriott shall list any

Mandatory Fees separately from taxes or other government-imposed fees.

12. AMENITY DISPLAY: Before a consumer completes the process of booking a

room reservation at an Affiliated Hotel through Marriott US Websites, Marriott shall Clearly and

Conspicuously disclose some or all of the goods and services covered by any Mandatory Fee.

Such disclosure may be made, on a tablet or mobile device, via a hyperlink to such disclosure

that is in close proximity to the Mandatory Fee. In close proximity to this disclosure, Marriott

shall also provide the means, through either a telephone number, hyperlink, or other means,

where consumers can obtain information regarding the goods and services covered by any

Mandatory Fee.

13. If the Petitioner receives a consumer complaint related to the terms of this

Assurance, the Petitioner shall bring such complaint(s) to Marriott’s attention by forwarding the

complaint(s) to the person identified in paragraph 22. Marriott shall have 30 calendar days to

respond to the complaint, or such other period of time exceeding 30 calendar days as specified

by the Petitioner, and shall in good faith attempt to resolve any issue(s) identified in the

complaint, which shall include providing notice to the Petitioner of how the complaint was

explained or resolved.

14. Nothing contained herein shall prevent Marriott or its Affiliated Hotels from

charging Mandatory Fees or from providing only the Total Price in any offer.

Third Party Compliance

15. Marriott shall require that offers of lodging made by operators, licensees,

franchisees, and owners of the Affiliated Hotels be made in a manner that is consistent with

paragraphs 6 through 12 of this Assurance.

16. Marriott shall require that franchisees and licensees provide Marriott with

accurate pricing information including Room Rates, all Mandatory Fees, and descriptions of all

amenities and services covered by such Mandatory Fees.

17. When communicating Total Price, Room Rates, Mandatory Fees, or amenities and

services covered by Mandatory Fees, Marriott may rely on information provided by a franchisee

or licensee, unless Marriott knows the information provided is misleading or incorrect.

18. If Marriott learns that any operator, licensee, franchisee, or owner of its Affiliated

Hotels is violating a requirement in paragraphs 6 through 12 of this Assurance, Marriott shall

take appropriate action in its sole discretion against such operator, licensee, franchisee, or owner.

Appropriate action shall be determined by the nature and circumstances of the violation,

including, but not limited to, the pattern and/or severity of the conduct, and any corrective action

taken by the operator, licensee, franchisee, or owner.

19. Marriott shall provide accurate pricing information, including Room Rates, all

Mandatory Fees, and the description of some or all of the services and amenities covered by such

Mandatory Fees to online travel agencies and other third parties that have entered into an

agreement with Marriott to provide consumers the ability to make reservations for Affiliated

Hotels. When communicating Total Price, Room Rates, Mandatory Fees, or amenities and

services covered by Mandatory Fees to third parties, Marriott may rely on information provided

by a franchisee or licensee, unless Marriott knows the information provided is misleading or

incorrect.

20. Nothing contained herein shall impose liability on Marriott if an advertisement,

price display, or offer created by Marriott is modified or otherwise displayed, communicated, or

conveyed by a third party in a manner inconsistent with the terms of the Assurance, without

Marriott’s knowledge, direction, or control.

RELEASE

21. Upon the filing of a duly executed version of this Assurance in the Allegheny

County Court of Common Pleas, Petitioner shall release and discharge Marriott and each of its

respective officers, directors, employees, agents, merged or acquired entities, parent or

controlling entities, affiliates and subsidiaries, and their predecessors, successors, and assignees,

from any and all claims, civil causes of action, demands, damages, restitution, penalties, fines,

actions, and other causes of action that Petitioner could have brought under the Consumer

Protection Law relating to the Covered Conduct prior to the Effective Date of this Assurance.

Nothing contained in this paragraph shall be construed to limit the ability of the Petitioner to

enforce the obligations that Marriott has under this Assurance. Notwithstanding any term of this

Assurance, any and all of the following forms of liability are specifically reserved and excluded

from the release contained herein as to any entity or person:

a. Any criminal liability that any person or entity, including Marriott, has or

may have to the Commonwealth of Pennsylvania.

b. Any civil or administrative liability that any person or entity, including

Marriott, has or may have to the Commonwealth of Pennsylvania under

any statute, regulation or rule not expressly covered by the release

contained herein, including but not limited to, any and all of the following

claims:

i. State or federal antitrust violations;

ii. State or federal securities violations; or

iii. State or federal tax claims.

MEET AND CONFER

22. Within twenty (20) days of the Effective Date, Marriott shall designate a person or

persons who the Petitioner may contact regarding any concerns about disclosures or

representations regarding Total Price, Room Rates or Mandatory Fees. Consistent with

Marriott’s legal obligations to safeguard the confidential or proprietary information of consumers

and third parties, Marriott shall respond to any information or requests provided by the Petitioner

within a reasonable period of time and shall cooperate in good faith with the Petitioner, including

investigating any reports of alleged misleading representations regarding Total Price or

Mandatory Fees that it receives from the Petitioner.

23. If the Petitioner determines that Marriott has failed to comply with any of the

terms of this Assurance, and if in the Petitioner’s sole discretion the failure to comply does not

threaten the health or safety of the citizens of the Commonwealth of Pennsylvania and/or does

not create an emergency requiring immediate action, the Petitioner exercising such discretion

shall notify Marriott in writing of such failure to comply and Marriott shall then have thirty (30)

days from receipt of such written notice to provide a good faith written response to the Petitioner.

The response shall include, at a minimum, either:

a. a statement explaining why Marriott believes it is in full compliance with

this Assurance; or

b. a detailed explanation of how the alleged violation(s) occurred, and either

i. a statement that the alleged violation has been addressed and how,

ii. a statement that the alleged violation cannot be reasonably

addressed within thirty (30) days from receipt of the notice, but

1) Marriott has begun to take corrective action to address the

alleged violation,

2) Marriott is pursuing such corrective action with reasonable

diligence, and

3) Marriott has provided the Petitioner with a detailed and

reasonable timetable for addressing the alleged violation.

Nothing herein shall prevent the Petitioner from agreeing in writing to provide Marriott with

additional time beyond the thirty (30) day period to respond to the notice provided pursuant to

this paragraph.

24. Nothing herein shall be construed to exonerate any failure to comply with any

provision of this Assurance after the Effective Date, or to compromise the authority of the

Petitioner to initiate a proceeding for any failure to comply with this Assurance.

GENERAL PROVISIONS

25. The requirements of paragraphs 6 through 19 shall come into effect on the

Implementation Date, except that following a merger or acquisition by Marriott of another

lodging company or operation, Marriott shall have until the later of the Implementation Date or

six (6) months, subject to extension upon agreement of the Petitioner, which agreement shall not

be unreasonably withheld, following the date of closing of the merger or acquisition in which to

bring the newly acquired properties into compliance with the requirements of the aforementioned

paragraphs.

26. NO ADMISSION: This Assurance is a compromised settlement of disputed issues

and shall not be deemed or construed as: (a) an admission of the truth or falsity of any claims or

allegations heretofore made or any potential claims; (b) an admission by Marriott that it has

violated or breached any law, statute, regulation, term, provision, covenant or obligation of any

agreement, decision, or other source of law; or (c) an acknowledgment or admission by any of

the Parties of any duty, obligation, fault, or liability whatsoever to any other Party or to any third

party. This Assurance does not constitute a finding of law or fact, or any evidence supporting

any such finding, by any court or agency that Marriott has engaged in any act or practice

declared unlawful by any laws, rules, or regulations of any state. Marriott denies any liability or

violation of law and enters into this Assurance without any admission of liability. To the extent

that Marriott makes changes to its advertising or business acts, practices, policies, procedures, or

materials to achieve or to facilitate conformance with this Assurance, the changes shall not be

taken as or construed to be an admission by Marriott or its owners, franchisees, licensees, or any

entity affiliated with its Lodging Establishments and/or Affiliated Hotels, of any kind, and shall

not constitute or be used as evidence of the Petitioner’s allegations of facts, Marriott’s violation

of any law, rule or regulation, or liability or wrongdoing, including an admission by Marriott that

any of its advertising or business acts, practices, policies, procedures, or materials are or have

been in violation of state law or regulation. It is the intent of the Parties that this Assurance shall

not be used as evidence or precedent in any action or proceeding, except an action to enforce this

Assurance. This Assurance may only be enforced by the Parties hereto.

27. This Assurance does not supplant or in any way restrict Marriott’s legal rights and

ability to demand formal legal process to protect its consumers’ privacy rights and/or to protect

Marriott from potential liability for disclosing or sharing such information without legal process.

In all other respects, Marriott hereby accepts and expressly waives any defect in connection with

such service of process issued to Marriott by the Petitioner related to this Assurance.

28. This Assurance is entered into voluntarily by Marriott as its own free and

voluntary act, without trial or adjudication of any issue of fact or law or finding of liability of

any kind, and with full knowledge and understanding of the nature of the proceedings and the

obligations and duties imposed upon it by this Assurance, and Marriott consents to its entry

without further notice. Further, this Assurance is the result of good faith negotiations, and the

terms are fair and reasonable.

29. Marriott shall not cause or encourage third parties, or knowingly permit third

parties acting on its behalf, to engage in acts or practices from which Marriott is prohibited by

this Assurance. For the avoidance of doubt, Marriott would not violate this provision if it

provides information in the ordinary course of business to third parties, and such third parties, on

their own accord, display the information on their respective sites in a manner inconsistent with

this Assurance without Marriott’s knowledge, direction, or control.

30. This Assurance represents the full and complete terms of the settlement entered by

the Parties. In any action undertaken by the Parties, neither prior versions of this Assurance nor

prior versions of any of its terms that were not entered by a Court or agreed to by any Party to

this Assurance may be introduced for any purpose whatsoever.

31. To seek modification of this Assurance to account for changes in technology or in

the marketplace, or for any other reason, Marriott may send a written request for modification

with a detailed explanation to the Petitioner. The Petitioner shall give such written request

reasonable consideration and shall agree to meet and confer in good faith with Marriott within

thirty (30) days of receiving such request. A resolution of such meet and confer efforts may

include, but not be limited to, equitable modifications or suspension of certain terms in this

Assurance. At the conclusion of this thirty (30) day period, Marriott reserves all rights to pursue

any legal or equitable remedies that may be available to it. The Petitioner acknowledges that it is

not its intent to cause Marriott to be at a material economic disadvantage as compared with other

industry members whose business practices do not conform to the Petitioner’s expectations under

the terms of this Assurance.

a. No waiver, modification, or amendment of the terms of this Assurance

shall be valid or binding unless made in writing, signed by all Parties, and

then only to the extent set forth in such written waiver, modification, or

amendment. To the extent that state law requires a waiver, modification,

or amendment of this Assurance to be approved and entered by a Court,

the Petitioner and Marriott agree to use their best efforts to obtain Court

approval.

b. The Petitioner shall not take any action to enforce the terms of the

particular provision for which a modification is being requested, other

than for prior violations of said terms, with respect to such waiver,

modification, or amendment while the Parties are seeking Court approval

of the same, if required. In the event that Court approval and entry of a

waiver, modification or amendment of this Assurance is required under

state law and the Court does not approve such waiver, modification or

amendment, said waiver, modification, or amendment shall be null and

void as to the Commonwealth of Pennsylvania; provided, however,

nothing herein shall be construed to prohibit or otherwise restrict any

party’s right to seek reconsideration or review of, or to appeal a decision

not to approve, such waiver, modification, or amendment.

c. Nothing in this paragraph shall limit the Petitioner from pursuing any

action against Marriott for failure to comply with this Assurance, nor shall

it release liability for any violations prior to or during the waiver,

modification, or amendment period.

32. This Assurance may be executed in counterparts, and a facsimile or .pdf signature

shall be deemed to be, and shall have the same force and effect as, an original signature.

33. All notices sent pursuant to this Assurance should be sent via first class and

electronic mail as follows unless a different address is specified in writing by the party changing

such address:

a. For Marriott:

Theresa Coetzee

Vice President & Assistant General Counsel, Dispute Resolution

10400 Fernwood Road

Bethesda, Maryland 20817

Telephone: 301-380-6614

[email protected]

With a copy to:

Lori Kalani

Cozen O’Connor

1200 19th Street, NW

Washington, DC 20036

Telephone: 202-471-3407

[email protected]

b. For the Petitioner:

Jill Ambrose

Senior Deputy Attorney General

Pennsylvania Office of Attorney General

1251 Waterfront Place, Mezzanine Level

Pittsburgh, PA 15222

Telephone: 412-565-3050

[email protected]

With a copy to:

John Abel

Senior Deputy Attorney General

Pennsylvania Office of Attorney General

Floor, Strawberry Square

Harrisburg, PA 17120

Telephone: 717-783-1439

[email protected]

34. Any failure by any party to this Assurance to insist upon the strict performance by

any other party of any of the provisions of this Assurance shall not be deemed a waiver of any of

the provisions of this Assurance, and such party, notwithstanding such failure, shall have the

right thereafter to insist upon the specific performance of any and all of the provisions of this

Assurance.

35. If any clause, provision or section of this Assurance other than paragraph 21,

shall, for any reason, be held illegal, invalid, or unenforceable, such illegality, invalidity, or

unenforceability shall not affect any other clause, provision, or section of this Assurance and this

Assurance shall be construed and enforced as if such illegal, invalid, or unenforceable clause,

section, or other provision had not been contained herein. If any clause, provision, or section of

this Assurance shall, for any reason, be held illegal, invalid, or unenforceable against any party,

such clause, provision, or section of this Assurance shall be illegal, invalid, or unenforceable

against any other party that enters a substantively identical Assurance with the Petitioner.

36. Nothing in this Assurance shall be construed as relieving Marriott of the

obligation to comply with all local, state, and federal laws, regulations, or rules, nor shall any of

the provisions of this Assurance be deemed to be permission to engage in any acts or practices

prohibited by such laws, regulations, or rules.

37. Nothing in this Assurance shall be construed to confer or limit any private right of

action that a consumer, person, or entity, or any cause of action that a local, state, federal, or

other governmental entity, may hold against Marriott and/or its franchisees or licensees. Nothing

in this provision shall be interpreted to permit multiple recoveries for the same harm or conduct.

38. Marriott shall not participate, directly or indirectly, in any activity or practice, or

form a separate entity or corporation for the purpose of engaging in acts or practices in whole or

in part, that are prohibited in this Assurance or for any other purpose that would otherwise

circumvent any part of this Assurance or the spirit or purposes of this Assurance.

MONETARY RELIEF

39. Marriott hereby agrees to pay the amount of One Hundred Ten and 25/100 Dollars

($110.25) to the Commonwealth of Pennsylvania, Office of Attorney General, for the costs of

filing this Assurance, to be paid by certified check, cashier’s check, or money order, made

payable to the “Commonwealth of Pennsylvania, Office of Attorney General,” and forwarded to

Jill T. Ambrose, Senior Deputy Attorney General, Office of Attorney General, 1251 Waterfront

Place, Mezzanine Level, Pittsburgh, Pennsylvania 15222, upon Marriott’s execution of this

Assurance.

(SIGNATURES ON FOLLOWING PAGES)

WHEREFORE, intending to be legally bound, the Parties have hereto set their hands

and seals.

FOR THE PETITIONER:

COMMONWEALTH OF PENNSYLVANIA

OFFICE OF ATTORNEY GENERAL

JOSH SHAPIRO

ATTORNEY GENERAL

Date: ____________________ By: ___________________________________

Jill Ambrose

Senior Deputy Attorney General

PA Attorney I.D. No. 323549

Bureau of Consumer Protection

1251 Waterfront Place, Mezzanine Level

Pittsburgh, PA, 15222

Telephone: 412-565-3050

Facsimile: 412-880-0196

[email protected]

[REMAINDER OF PAGE INTENTIONALLY BLANK]

/s/ Jill T. Ambrose

November 16, 2021

CERTIFICATION OF COMPLIANCE

I certify that this filing complies with the provisions of the Public Access Policy of the

Unified Judicial System of Pennsylvania: Case Records of the Appellate and Trial Courts that

require filing confidential information and documents differently than non-confidential

information and documents.

Date: November 16, 2021 By: /s/ Jill T. Ambrose

Jill T. Ambrose

Senior Deputy Attorney General

PA Attorney I.D. No. 323549

PA Office of Attorney General

1251 Waterfront Place, Mezzanine Level

Pittsburgh, PA 15222

Telephone: 412-565-3050

[email protected]

CERTIFICATE OF SERVICE

I, Jill T. Ambrose, hereby certify that a true and correct copy of the foregoing Assurance of

Voluntary Compliance was served via electronic mail on November 16, 2021 upon the below:

Mira E. Baylson

Cozen O’Conner

One Liberty Place

Suite 2800

Philadelphia, PA 19103

[email protected]

Milton A. Marquis

Cozen O’Conner

1200 19

Street, NW

Washington, DC 20036

[email protected]

/s/ Jill T. Ambrose

Jill T. Ambrose

Senior Deputy Attorney General

PA Office of Attorney General

1251 Waterfront Place, Mezzanine Level

Pittsburgh, Pennsylvania 15222

(412) 565-3050