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DAMAGE REPORT CONCERNING ICC

ARBITRATION 20050/ASM

For the purposes of assessing damages resulting from a breach of contract

incurred by the firm IMS, we proceed to the presentation of our technical opinion in
relation to the damage caused. To that end, we rely on the factual circumstances alleged
in the Claimant's Memorial, the text of which I have had before me.
DAMAGE CAUSED BY IMS

Holding the IMS World Review 2013 and other acts developed by IMS, as alleged
by the claimant, has caused changes in respect of the terms and timing of negotiations on
all contracts involved in the Prescription Data business that have been renewed since
2013, mainly in Brazil. Billing data with their highs and lows - based on these contracts
serve as an objective basis for the assessment of damages.
In turn, attention was paid to the information provided by those companies
operating under the Close-Up brand in Brazil, because they were forced to enter the
Sales Data market as a commercial protection of sorts in the face of the IMS entering
the Prescription Data market.
This called for a sizeable investment by the companies operating under the CloseUp brand.
In addition, the investment became more burdensome than anticipated under
normal conditions of competition, because IMS, according to the claimant's arguments,
displayed a behavior that consisted in raising the prices of the sales data, as will be
discussed below. This caused an increase in the entry costs into the sales data market for
the firms operating under the Close-Up brand.
Increased costs, low prices, and the loss of contracts/trading accounts are the
result of the actions carried out by IMS, with losses that remain to date.
TECHNICAL CONSISTENCY OF THE INFORMATION CONSIDERED

For the purposes of quantifying the damages, we proceed to identify and evaluate
objective facts, which can be corroborated with rigor from legal documentation, as well
as subject to technical contextualization, in an economic injury.

Therefore, all data we will draw on to support our conclusions emerge from the
invoicing of the companies operating under the Close-Up brand. From the analysis of
contracts and account history of these accounts, differences stem that originate from the
date of the IMS World Review event.
TIME HORIZON OF QUANTUM OF DAMAGES

To arrive at the contingent amount, the following was established: 1) a time

horizon of five years, considering that period as reasonable and in conformity with
prevailing practices in financial/business analysis, and 2) the period between the
announcement by IMS and today.
This time frame was set in response to the consistency of the objective data
evaluated, leaving aside the analysis of damages to brand value or a longer time horizon
vis--vis the client life cycle, data that were also wronged as they are perfectly verifiable
from the commercial technical standpoint.
CONTINGENCY AREAS

Contingency estimation was developed by evaluating billing documents, contracts, and

projections provided by the claimant in considering the following points:
Decreased revenues in contract renewal, because of the threat of a launch of
service by IMS.
Investment in the Sales Data Business.
IMS interference in negotiations with information providers.
Cancellation or delays in commercial contract renewal 2015 with clients,
prompted by IMS actions.
DETAILS OF THE CONTINGENCY AREAS

Decreased revenues in contract renewal, because of the service launch date

by IMS:

The contracts renewed after the announcement by IMS experienced a price change from
the time the IMS World Review 2013 took place.
We have evaluated the historical growth of companies in Brazil that operate under the
CLOSE-UP INTERNATIONAL brand in the Prescription Audit market 20092012,
yielding an average of 11.75%. (See Annex 1).
We consider the period 20092012 as representative of the local business situation prior
to the effects that produced the foreseeable announcement of the launch of the
Prescription Audit service by IMS.

On the assumption that said average growth rate is the foundation for the annual growth
of companies in Brazil that operate under the CLOSE-UP INTERNATIONAL brand, and
including the effect of local inflation in the growth rate, we conducted an evaluation of all
client contracts renewed from June 2013 onwards, which did not attain, at least, the
average growth rate.
The effect of the evaluation made is recorded in US currency at current value for the
period where the loss is identified, with a breakdown per contract and client in Annex 2
of this report, which in brief allows determining that:

The loss caused for failing to achieve the average renewal rate in 2013 is
US$ 79,117.
The loss caused for failing to achieve the average renewal rate in 2014 is
US$ 89,577.

Notwithstanding the foregoing, one may note that these losses are not limited only to the
year in which they were generated, since their existence in a year carries over to the
following year because the value that should have been obtained in a negotiation, without
abnormal interference of third parties, cannot be used as a basis for contract renewal.
Based on this situation, under the premise of the bullet TIME HORIZON OF QUANTUM OF
DAMAGES, we projected and calculated both scenarios through 2019, yielding a quantified
value of US$ 7,965,760. (Net Present Value US$ 6,698,294), which is broken down in Annex 3
of this document.

For further clarification, we emphasize that the net present value results from discounting
the current value at a 10% rate.

Investment in the Sales Data Business:

According to documents that we have had before us, the companies that operate
under the CLOSE-UP INTERNATIONAL brand in Brazil decided in 2013 to enter
the Sales Data Business to protect the Prescription Data Business.
Thus, we had before us all the invoices relating to the investment made by the
companies that operate under the Close-Up brand for 2014 and 2015.
This investment amounted to US$ 13,430,847.
That sum revealed the financial cost that the companies operating under the CLOSEUP INTERNATIONAL brand in Brazil suffered to divert those resources into the
development of Sales Data Business.
There is no precedent to believe that CLOSE-UP INTERNATIONAL would have
ever considered incorporating the Sales Audit business into their products, as it had
always taken investment decisions in other lines.

Taking a conservative view, we believe that if the investment would have been
placed in a fixed-term deposit in Brazil during 2014 and reinvested in 2015,
considering a 9.04 APR obtained from Banco Bradesco's operations simulator (one
of the main Banks in Brazil,) a yield of US$ 1,878,123 could have been obtained as detailed in Annex 4.

IMS interference in negotiations with information providers.

Once CLOSE-UP INTERNATIONAL made the decision of investing in 2013 in the
Sales Audit market in Brazil, and initiated negotiations with data providers (main
raw material for creating products), sales were affected by the IMS action to hinder
their implementation, thus forcing the provider to increase the sale value.
This built an entry barrier much higher than envisaged for the companies that
operate under the CLOSE-UP INTERNATIONAL brand in Brazil, despite the
existence of pre-agreed contracts with information providers, contracts that were
significantly revised afterwards.
Upon review of these contracts, which we divide in agreements before the external action
in negotiating with suppliers and contracts concluded after the external action in
negotiating with suppliers. We identified that the variance in the values required by the
suppliers for the same information was US$ 3,534,632.

Given this situation, we understand that besides the monetary loss caused by the
extra payment that arose in the negotiation, there was the prospect of investing and
reinvesting this money from the time of its creation until 2015 when we are
conducting this analysis.
To evaluate this alternative again, we resort to the analysis of the fixed term detailed in the
bullet, DEFENSIVE MEASURES IN VIEW OF IMPENDING MOVEMENTS IN THE
PRESCRIPTION AUDIT MARKET, situation that yields a financial loss of US$ 523,326.

Cancellation or delays in commercial contract renewal 2015 with clients, prompted

by IMS actions.
As the claimant has informed us, after having spent 46 years in the pharmaceutical
market as a leader in the Prescription Audit segment, CLOSE-UP
INTERNATIONAL realizes that creating a competitive market for Prescription
Audits takes a development time of at least 24 months, necessary to prepare
building capacities, resources, software development, and pre-contracts with
suppliers.
The announcement by IMS at the World Review event on the beginning of the
marketing of Prescription Audits in 2013 implies the existence of data collection
tasks, software development, and pre-agreements with suppliers that violate the
master contract on a date prior to its maturity on March 31, 2014.
This situation has also caused difficulties in the process of renewal of 2015

contracts for companies in Brazil that operate under the CLOSE-UP

INTERNATIONAL brand, contracts that were measured by reviewing invoices and
projections following the methodology as explained in the paragraph, Decreased
revenues in contract renewal, because of the threat of a launch of service by IMS.
The analysis shows that the loss generated from January 2015 to April 30, 2015
annualized has been US$ 994,288 as detailed in Annex 6.
Based on this situation, under the premise of the bullet, TIME HORIZON OF
QUANTUM OF DAMAGES, we projected and calculated both scenarios through
2019, yielding a quantified value of US$ 7,661,586. (Net Present Value US$
6,390,477).
For further clarification, we emphasize that the net present value results from
discounting the current value at a 10% rate.
CONTINGENCY AMOUNTS

The amounts of the economic injury caused by IMS, assessed from the supporting
documentation and resulting from the assessment methodology described in the previous
section are as follows:
Decreased revenues in contract renewal, because of the threat of a launch of

service by IMS HEALTH: US$ 6,698,294. (Six million six hundred ninetyeight thousand two hundred ninety-four dollars).
Investment in the Sales Data Business: US$ 1,878,123. (One million eight
hundred seventy-eight thousand one hundred twenty-three dollars).
IMS interference in negotiations with information providers. US$ 4,057,958.
(Four million fifty-seven thousand nine hundred fifty-eight Dollars)
Cancellation or delays in commercial contract renewal 2015 with clients,
prompted by IMS actions. US$ 6,390,477.
The total amount of damages caused by IMS is US$ 19,024,852 (nineteen million
twenty-four thousand eight hundred fifty-two dollars).
See detail in Annex 7
CONCLUSIONS

The announcement and other measures carried out by IMS constituted

commercial acts and measures that have led to changes in the pricing of contracts
for the provision of services in the Prescription Data Business, causing companies
operating under the CLOSE-UP INTERNATIONAL brand in Brazil to begin
operations in the Sales Data Business with the financial consequences outlined
above.

In addition, the very foreseeable act of marketing a product that could not be
finished, if the deadlines set in the master contract were honored, has resulted in the
non-renewal of clients. The renewal would only have been possible if IMS indeed
had started to build capacities, resources, software development tasks, and precontracts with the proper suppliers to provide the service in a timely manner.
This illustrates that to the date of announcement of the launch, the IMS
service was in fact under development, and was then announced to the market at the
IMS World Review event.
Once assumed as certain the premises enunciated in the Claimant's Memorial,
one might conclude that the brands [sic] that operate under the CLOSE-UP
INTERNATIONAL brand have suffered the following losses:
Decreased revenues in contract renewal, because of the threat of a
launch of service by IMS, US$ 6,698,294.
Investment in the Sales Data Business, US$ 1,878,123.
IMS interference in negotiations with information providers, US$
4,057,958.
Cancellation or delays in commercial contract renewal 2015 with
clients, prompted by IMS actions, US$ 6,390,477.
All of which results in an amount of damages of US$ 19,024,852.

[Signature]
Guillermo de Vega
ID No. 17.925.060
[Signature]
Dr. Galli Carlos
ID No. 10126658
[Signature ]
Nancy Maltagliatti
ID No. 23236516