![]() (Merger Sub) with and into Seattle (the Merger), with Seattle continuing as the surviving corporation and a direct wholly owned subsidiary of Seattle Holdings, Inc. Following the Distribution, pursuant to the merger of Seattle MergerSub, Inc. federal income tax purposes (the ∽istribution). (Seattle), a wholly owned subsidiary of HPE that will hold, directly or indirectly, the assets and liabilities of HPEs software business segment (HPE Software) on a pro rata basis in a distribution that is intended to be tax-free to HPE and to HPE Stockholders (as defined below) for U.S. Hewlett Packard Enterprise Company (HPE) intends to distribute to its stockholders all of the outstanding shares of Class A common stock (the Seattle Shares) of Seattle SpinCo, Inc. ![]()
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