SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND BLOCKBUSTER INC.DEPARTMENT OF JUSTICE COMPLAINT NUMBER 202-35-231

PARTIES

8. The parties to this Settlement Agreement ("Agreement") are the United States of America ("United States") and Blockbuster (collectively, "the Parties"). The Parties have determined and agreed that the Department of Justice complaint 202‑35-231 can be resolved without litigation pursuant to the terms of this Agreement.

9. Blockbuster expressly asserts that it already has policies and training in place regarding Title III of the ADA and seeks to enhance its policies and practices in the manner set forth below. The United States contends that the steps taken by Blockbuster were inadequate to achieve ADA compliance in connection with Complainant. Blockbuster affirms its commitment to maintain policies, practices, and procedures as outlined in this Agreement to ensure that individuals with disabilities have an opportunity equal to that of individuals without disabilities to enjoy the goods, services, facilities, privileges, advantages, and accommodations of its stores.

10. In consideration of the terms of this Agreement, the United States agrees to refrain from undertaking further investigation or filing a civil suit with respect to the Department of Justice complaint 202-35-231, except as provided in the Enforcement Section of the Agreement. This provision does not limit the United States´ ability to investigate or file a civil suit with respect to allegations not contained in the Department of Justice complaint 202-35-231.