United States of America, Plaintiff, v. Cinemark USA, Inc., Defendant - Consent Order

2.1     The United States and Cinemark agree to stipulation of the terms set forth herein and to entry of this Consent Order as a binding resolution of this litigation.  The parties further agree that this Consent Order shall extinguish all claims for relief and all counterclaims between the United States and Cinemark in the aforementioned litigation.  Nothing in this Consent Order shall prohibit Cinemark from using the arguments that form the basis of Cinemark's denials, affirmative defenses, and counterclaims to defend itself in future litigation.  Entry of this Consent Order brings certainty regarding Cinemark's obligation concerning the placement and location of wheelchair spaces, and the depth of the cross-aisles, at all of Cinemark's Existing Theaters, Designed Theaters, and Future Construction Theaters, as defined in this Consent Order.