Relief Therapeutics Holding AG (RLFTF)

[PennyWorld]

Plaintiffs respectfully request relief as follows:
a. An award of damages in an amount exceeding $500,000 to be determined at trial;

b. An award of punitive damages;

c. An order compelling Defendants to perform under the Collaboration Agreement including, among other relief:
i. An order enforcing the territorial limits of the Collaboration Agreement and prohibiting Defendants from engaging in any commercialization efforts for aviptadil in any country other than the United States, Canada, or Israel;
ii. An order enforcing the territorial limits of the Collaboration Agreement and prohibiting Defendants from engaging in any commercialization efforts for BriLife;
iii. An order requiring Defendants to submit detailed budget proposals for any clinical trials related to the Collaboration Agreement to Relief's Board of Directors;
iv. An order prohibiting Defendants from entering into third party agreements without Relief's consent as required by Section 5 of the Collaboration Agreement;
v. An order compelling Defendants to allow Plaintiffs access to, and an audit of, Defendants' books and financial records as set forth in Exhibit D;
vi. An order compelling Defendants to share information and collaborate with Relief as required by Section 7 of the Collaboration Agreement;
vii. An order compelling Defendants to produce any and all information licensed from SUNY Stonybrook to Relief; and,
viii. An order specifically enforcing the exclusivity provisions of the Collaboration Agreement;

d. A declaration that the Collaboration Agreement provides Relief with the right to access any and all data related to clinical trials of aviptadil in the United States that have been conducted by, in collaboration with, or at the direction of, NeuroRx and/or its affiliates;

e. An accounting;

f. An award of Relief's costs and attorney's fees;

g. An award of pre-judgment and post-judgment interest on the foregoing sums at the highest rate permitted by law; and,

h. Any further and additional relief that the Court deems just and proper.

Jury Trial Demand
Plaintiffs request a jury trial on all issue so triable.

Dated: October 6, 2021
Respectfully submitted,
/s/ Frederick Andrew Braunstein
Craig Weiner
Frederick Andrew Braunstein
Alexander Newman
AKERMAN LLP

1251 Avenue of the Americas
Suite 3700
New York, NY 10020
Phone: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs