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Monday, 02/04/2019 2:03:33 PM

Monday, February 04, 2019 2:03:33 PM

Post# of 37346

70.Emerging from Chapter 11 with a right-sized and flexible balance sheet, the Buyer will expand upon its aforementioned success through its increased capacity to appropriately invest capital in attractive new opportunities. Kamlani Decl. ¶ 41.

And, in recognition of the inevitable business risks associated with its efforts, the Buyer is planning responsibly, such that certain aspects of the Business Plan are even more conservative than the well-developed and realistic plan prepared by the Debtors. For example:

•Externalizing Kenmore beyond Sears and Amazon. Despite its previously constrained distribution, the Kenmore home appliances brand remains a leading brand with significant market share. By forming new external partnerships and selling to mass discounters, big box specialty stores, and online retailers, the Buyer will be able to generate additional revenue from Kenmore. Business Plan 21-22.

•The Business Plan expects Kenmore third-party revenue from Amazon customers to increase from $80 million in 2018 to $300 million by 2021, which is approximately 50% less than the Company Plan’s revenue expectation.

•Growing its relationships with third party customers including Amazon through expansion of Innovel logistics network. Business Plan 21-22. This third-party business can be expanded with minimal additional infrastructure investment. Business Plan at 33. Further, ESL expects the Buyer to forge strategic partnerships across Sears Home Services, Innovel and other key assets to fill in known or expected gaps and unlock opportunities that Buyer cannot access alone. Kamlani Ex. A. The Business Plan expects $300 million in Innovel revenue by 2021 while the Debtors’ plan expects $500 million by 2021. Id.

•Tailoring the Shop Your Way program in a non-capital-intensive way. Because the technological capabilities exist already, and the Buyer will continue to test marketing strategies as it gains an increasingly sophisticated understanding of its 18-23538-rdd Doc 2379 Filed 02/04/19 Entered 02/04/19 08:00:13 Main Document Pg 43 of 77


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