Role in the network: The only entity that simultaneously invested in Formation Bio, bought its drugs, co-developed its AI platform with OpenAI, and uses Anthropic’s Claude daily — occupying all four sides of the pharma-AI-data transaction while also being the company Keya is using Claude to investigate.
Company Bio
Sanofi S.A. is a French multinational pharmaceutical and healthcare company headquartered in Paris. Founded in 1973 as a subsidiary of the oil company Elf Aquitaine, it grew through a series of mergers — with Synthélabo (1999), Aventis (2004, for €54.5 billion), and Genzyme (2011, for $20.1 billion) — to become the world’s fifth-largest pharmaceutical company by prescription drug sales. The company trades as SAN on Euronext Paris and SNY on Nasdaq, and is a component of the CAC 40 and Euro Stoxx 50 indices. [1] [2]
In 2024, Sanofi reported revenue of €41.08 billion, operating income of €7.25 billion, and employed approximately 82,878 people worldwide. Its blockbuster drug Dupixent (co-developed with Regeneron for atopic dermatitis, asthma, and COPD) exceeded €14 billion in annual sales. The company maintains a pipeline of 93 compounds in clinical development, including 26 in Phase 3 trials. [1] [3]
Paul Hudson served as CEO from September 2019 to February 2026. He previously led Novartis Pharmaceuticals and spent 28 years at major pharmaceutical companies including Schering-Plough, AstraZeneca, and Novartis. Under Hudson, Sanofi pursued a strategy of becoming “the first biopharma company powered by AI at scale.” In April 2025, Sanofi sold a 50% controlling stake of its consumer healthcare business (Opella) to CD&R for approximately €10 billion, pivoting to a “pure-play biopharma” focused on innovation. [3] [4] [5]
The Triple Relationship with Formation Bio
Sanofi’s relationship with Formation Bio operates across three simultaneous capacities, creating a closed loop that raises fundamental questions about arm’s-length dealing.
1. Investor (Series D, June 2024)
Sanofi was a named investor in Formation Bio’s $372 million Series D round led by a16z. CEO Paul Hudson was listed as a partner-level investor on Crunchbase. In a statement accompanying the investment, Hudson said Sanofi is “all in on AI” and “proud to partner with and invest in Formation Bio.” [6]
Formation Bio itself described this relationship in explicitly non-arm’s-length terms: Sanofi creates an “off balance sheet pathway for development, enabling a company to take more shots on goal in a P&L efficient way.” In other words, Formation Bio conducts drug development that Sanofi doesn’t have to report on its own financial statements. [6]
2. AI Partner (Muse, May 2024 → November 2024)
On May 21, 2024, Sanofi, Formation Bio, and OpenAI announced a “first-in-class AI collaboration” to build AI-powered software across the drug development lifecycle. Sanofi contributed “proprietary data to develop AI models.” OpenAI contributed model fine-tuning capabilities. Formation Bio provided engineering resources and its tech-driven development platform. [7] [8]
Six months later, on November 12, 2024, the three companies introduced Muse — an AI tool for clinical trial patient recruitment. Muse uses OpenAI models to generate recruitment strategies and materials, and was scheduled for initial deployment in Phase 3 trials of Sanofi’s multiple sclerosis drugs. Sanofi Chief Digital Officer Emmanuel Frenehard said Muse represents “another proof point in Sanofi’s journey to becoming the first pharma company powered by AI at scale.” [9] [10]
The conflict of interest is structural: OpenAI’s CEO Sam Altman has a personal $19 million stake in Formation Bio. The Muse announcement was attributed to OpenAI COO Brad Lightcap — Altman’s designated recusal proxy — who said “there is massive potential for AI to accelerate drug development.” Whether Altman formally recused from the deal is unconfirmed. [7]
3. Drug Buyer (Gusacitinib, June 2025)
On June 23, 2025, Formation Bio announced that its subsidiary Libertas Bio had licensed gusacitinib, an oral dual JAK/SYK inhibitor, to Sanofi. Gusacitinib was acquired by Formation Bio in late 2022 from Asana BioSciences. Sanofi will explore its potential in a new indication through a Phase 1 study. The deal value was reported elsewhere as up to €545 million. [11] [12]
Contract Pharma noted that “Formation Bio and Sanofi have several long-standing collaborations focused on identifying high-potential assets and co-developing AI tools that leverage shared data and technical expertise.” The Libertas/Sanofi transaction was described as “exemplifying Formation Bio’s differentiated business model: identifying and acquiring high-potential clinical-stage assets.” [13]
The Closed Loop
The three relationships form a self-reinforcing cycle:
- Sanofi invests in Formation Bio → Formation Bio uses investment to acquire drugs → Formation Bio sells those drugs back to Sanofi → Sanofi uses its proprietary patient data to train AI models through OpenAI → those AI models are deployed on Sanofi’s own clinical trials → which recruit patients for drugs Sanofi bought from Formation Bio
Sanofi is funding the company that acquires drugs, buying the drugs that company acquires, co-building the AI tools that recruit patients for those drugs, and providing its own patient data to train the AI. Every node in the transaction feeds back to Sanofi.
The Anthropic / Claude Relationship
🚨 ANTHROPIC CONFLICT FLAG 🚨
Sanofi is a documented client of Anthropic’s Claude for Life Sciences platform. In Anthropic’s official marketing materials, Sanofi’s testimonial states: “Claude is integral to Sanofi’s AI transformation and is used by most Sanofians daily.” Sanofi’s AI Product Lead Cyril Zaidan participated in Anthropic’s “Claude for Life Sciences” webinar alongside AbbVie, Novo Nordisk, Genmab, and AstraZeneca representatives. [14] [15]
This means Sanofi is simultaneously using:
- OpenAI (through the Formation Bio/Muse partnership) for drug development AI
- Anthropic/Claude (enterprise deployment) for daily operations across the company
And this investigation, which documents Sanofi’s triple relationship with Formation Bio and its connections to Sam Altman’s network, is being conducted using Claude — Anthropic’s product — by an investigator (Keya) who has flagged the Anthropic conflict and is documenting it transparently.
The PwC-Anthropic partnership (announced 2025) explicitly lists “Healthcare & Life Sciences” as a priority deployment sector, with Sanofi among the named enterprise clients. [16]
The “Off Balance Sheet” Framing
Formation Bio’s own press materials describe its role as providing Sanofi an “off balance sheet pathway for development, enabling a company to take more shots on goal in a P&L efficient way.” [6]
This framing deserves scrutiny. “Off balance sheet” is a specific financial term meaning assets, liabilities, or activities that don’t appear on a company’s financial statements. In the Enron era, “off balance sheet” became synonymous with hiding risk. In this context, it means:
- Sanofi invests in Formation Bio (appears as a portfolio investment, not R&D spending)
- Formation Bio acquires and develops drugs (appears on Formation Bio’s books, not Sanofi’s)
- Sanofi buys successful drugs back from Formation Bio (appears as a licensing deal, not sunk R&D cost)
- Failed drugs stay on Formation Bio’s books and never appear on Sanofi’s P&L
The result: Sanofi gets the upside of drug development (successful drugs licensed in) without the downside appearing on its financial statements (failed drugs stay with Formation Bio). This is legal but structurally designed to obscure the true cost and risk of Sanofi’s drug pipeline from Sanofi’s shareholders.
Key People (Network Connections)
| Person | Role | Network Connection |
|---|---|---|
| Paul Hudson | CEO (Sep 2019 – Feb 2026) | Named as Series D partner investor. “All in on AI.” Led Sanofi during Formation Bio partnership, Muse development, and gusacitinib purchase. Previously CEO Novartis Pharmaceuticals. British. Manchester Metropolitan University. |
| Emmanuel Frenehard | Chief Digital Officer | Quoted on Muse deployment. Driving “AI at scale” strategy. |
| Cyril Zaidan | AI Product Lead | Participated in Anthropic’s Claude for Life Sciences webinar (Oct 2025). Bridge between Claude and Muse usage. |
| Mikael Dolsten | (ex-Pfizer CSO) → Formation Bio Drug Picking Committee Chair | Pfizer’s former Chief Scientific Officer who led COVID vaccine development. Now chairs Formation Bio’s drug selection. Same PharmaVoice article featured both Dolsten and Siddhartha Mukherjee (Manas AI co-founder with Hoffman). |
The GSK Parallel
Sanofi’s relationship with Formation Bio structurally mirrors GSK’s relationship with 23andMe:
| Dimension | GSK ↔ 23andMe | Sanofi ↔ Formation Bio |
|---|---|---|
| Investment | $300M equity (2018) | Series D investor (2024) |
| Data access | 23andMe genetic database (5M+ opted-in customers) | Formation Bio clinical trial data + OpenAI models |
| Drug development | Joint drug target discovery (exclusive 4 years) | Muse AI tool + gusacitinib purchase |
| Outcome | One compound to Phase I. Partnership wound down. Drug program scrapped. | Ongoing. First drug licensed (gusacitinib). |
| Company fate | 23andMe → bankruptcy → nonprofit (TTAM) | Formation Bio → expanding (Series D, $372M) |
Both arrangements involve a major pharma company paying hundreds of millions to access a smaller company’s data platform for drug development. GSK’s bet on 23andMe’s genetic data failed spectacularly. Sanofi’s bet on Formation Bio’s AI-powered model is ongoing.
Regeneron: The $14 Billion Partnership Under Litigation
Sanofi’s most important commercial relationship — the Dupixent collaboration with Regeneron — is now the subject of active litigation that casts the Formation Bio relationship in a new light.
Sanofi and Regeneron’s Dupixent partnership began in 2007, when Sanofi paid $85 million upfront and committed up to $475 million in research funding. Dupixent was approved in 2017 for atopic dermatitis and has expanded into asthma, COPD, chronic spontaneous urticaria, and other indications. In 2024, the drug generated over $14.1 billion in global sales. Under the agreement, Sanofi records all sales and shares profits with Regeneron in the United States. [18] [19]
In November 2024, Regeneron sued Sanofi in the US District Court for the Southern District of New York, alleging that Sanofi breached the collaboration agreement by refusing to share material information about Dupixent’s commercial arrangements. Specifically, Regeneron alleged Sanofi withheld details about contracts with pharmacy benefit managers (PBMs) and was “bundling” Dupixent with other Sanofi drugs in ways that affected rebate calculations — and therefore Regeneron’s profit share. The complaint asked: “What are defendants trying to hide?” Regeneron stated that its audit had “already revealed inaccuracies in Sanofi’s and its Affiliates’ books.” [19] [20] [21]
Why this matters for the investigation: Sanofi is being sued by its Dupixent partner for financial opacity in the same period that it is building a parallel drug development pipeline through Formation Bio. Gusacitinib — the drug Sanofi licensed from Formation Bio’s Libertas Bio — targets the same therapeutic area (immunology/inflammation) as Dupixent. If the Regeneron partnership deteriorates, Sanofi has Formation Bio’s pipeline as a hedge. The Formation Bio relationship provides Sanofi with an alternative drug development pathway that doesn’t require Regeneron’s involvement or profit-sharing.
The Regeneron-23andMe connection: Regeneron was the competing bidder for 23andMe in bankruptcy ($256M vs TTAM’s $305M). Regeneron offered privacy protections that TTAM matched. Sanofi is simultaneously suing Regeneron over Dupixent and investing in Formation Bio — the company whose former partner (23andMe) Regeneron tried to acquire.
In March 2026, the Dupixent follow-up drug itepekimab failed Phase III trials for COPD, sending Regeneron shares down 18% and Sanofi down 6%. The failure narrows the long-term pipeline of the Sanofi-Regeneron collaboration and increases the strategic importance of Sanofi’s Formation Bio pathway as an alternative. [22]
Bribery, Developing Countries, and the Ethical Pattern
In September 2018, Sanofi paid $25 million to resolve SEC and DOJ allegations of bribery in the Middle East and Africa. The investigation covered “improper payments to healthcare professionals in connection with the sale of pharmaceutical products” across Kazakhstan, Jordan, Lebanon, Bahrain, Kuwait, Qatar, Yemen, Oman, the United Arab Emirates, and the Palestinian territories from 2007 to 2015. The SEC’s FCPA Unit Chief stated that “pharma bribes remain a significant problem despite numerous prior enforcement actions.” [23]
The bribery settlement is significant in context. The network’s clinical trial operations consistently target populations with limited regulatory oversight and limited capacity to refuse: nursing home residents in the US, low-income communities in rural and urban America, developing nations where Worldcoin collects iris scans, and countries where Watsi funds surgeries. Sanofi’s documented history of paying healthcare professionals in developing markets to sell pharmaceutical products fits this pattern — leveraging power imbalances to move product in markets where oversight is weakest.
Sanofi’s Global Health Unit, which the company highlights in its CSR reporting, specifically targets “low- and middle-income countries” — the same demographic targeted by Worldcoin, Watsi, and the UBI study’s RISE rural program. The framing is humanitarian; the commercial infrastructure is pharmaceutical distribution into markets with weak regulatory frameworks. [3]
The COVID Vaccine Failure
Sanofi’s attempt to develop a COVID-19 vaccine was notably delayed compared to mRNA competitors (Pfizer/BioNTech, Moderna). The company’s traditional protein-based approach suffered from “capacity gaps versus mRNA competitors,” and Sanofi did not receive FDA emergency use authorization for its COVID vaccine (VidPrevtyn Beta) until 2022 — over a year after Pfizer and Moderna. The failure was described as damaging to French national pride, with the Pasteur Institute also abandoning its COVID vaccine effort. [24]
This context matters because Formation Bio’s network includes resTORbio — the company that used Sam Altman’s Project Covalence platform to test a failed anti-aging drug (RTB-101) on elderly nursing home residents during COVID under an NIA grant, before merging into Adicet Bio 49 days later. Sanofi’s own COVID vaccine failure means it was not a major player in the pandemic vaccine space, but its partner (Formation Bio, through the TrialSpark/Covalence platform) was actively involved in COVID clinical trials targeting vulnerable elderly populations.
Sanofi Ventures: The $1.4 Billion Early-Stage Pipeline
Sanofi Ventures is the company’s corporate venture capital arm, active since 2012. In September 2025, Sanofi committed an additional $625 million, bringing total assets under management to over $1.4 billion. The fund has deployed over $800 million across more than 70 companies in biotech and digital health, with three exits in 2024 generating a combined acquisition value of $3.25 billion. [25] [26]
The fund invests from seed through IPO participation in immunology, rare diseases, neurology, vaccines, and AI/digital health — the same therapeutic and technology areas where Formation Bio, OpenAI, and the broader Altman network operate. Managing Director Jason P. Hafler leads the fund.
In August 2025, Sanofi completed a $470 million acquisition of Vigil Neuroscience — a company focused on restoring dysfunctional microglia (the brain’s immune cells) in neurodegenerative diseases. [27]
This is the same cellular target as Retro Biosciences (Sam Altman’s $180 million personal investment). Retro’s pipeline includes a cell therapy “aimed at rejuvenating the brain’s immune cells, microglia, which become chronically inflammatory with age.” Sanofi and Altman are both investing in microglia-targeting therapeutics through separate companies — Sanofi through a $470M acquisition (Vigil) and Altman through a $180M personal investment (Retro). The therapeutic thesis is identical. The commercial pathways converge.
The Complete Sanofi-Network Map
Sanofi touches the investigation at an unusual number of contact points:
SANOFI
│
├──→ Formation Bio (INVESTOR, Series D)
│ ├──→ Sam Altman ($19M stake)
│ ├──→ OpenAI (Muse partnership)
│ └──→ Libertas Bio → gusacitinib → SOLD BACK TO SANOFI (€545M)
│
├──→ OpenAI (Muse co-development, via Formation Bio)
│ └──→ Brad Lightcap (COO, recusal proxy for Altman)
│
├──→ Anthropic/Claude (enterprise client, "used by most Sanofians daily")
│ └──→ 🚨 CONFLICT: This investigation uses Claude
│
├──→ Regeneron (Dupixent profit-sharing, NOW IN LITIGATION)
│ └──→ Regeneron bid $256M for 23andMe (lost to TTAM's $305M)
│
├──→ Vigil Neuroscience ($470M acquisition, microglia)
│ └──→ SAME CELLULAR TARGET as Retro Biosciences (Altman's $180M)
│
├──→ Mikael Dolsten (ex-Pfizer CSO → Formation Bio Drug Picking Committee)
│ └──→ Same PharmaVoice article as Mukherjee (Manas AI / Hoffman)
│
└──→ Middle East/Africa ($25M bribery settlement, 2007-2015)
└──→ Same developing-market pattern as Worldcoin, Watsi, RISE study
Timeline
| Date | Event |
|---|---|
| 1973 | Sanofi founded as subsidiary of Elf Aquitaine |
| 1999 | Merged with Synthélabo |
| 2004 | Acquired Aventis for €54.5B |
| 2011 | Acquired Genzyme for $20.1B. Renamed from Sanofi-Aventis to Sanofi. |
| Sep 2019 | Paul Hudson becomes CEO (from Novartis Pharmaceuticals) |
| May 21, 2024 | Sanofi + Formation Bio + OpenAI announce “first-in-class AI collaboration” |
| Jun 2024 | Sanofi invests in Formation Bio’s $372M Series D. Hudson: “all in on AI.” |
| Nov 12, 2024 | Muse AI tool introduced — Formation Bio + OpenAI + Sanofi. Patient recruitment AI for clinical trials. |
| Apr 30, 2025 | Sanofi sells 50% controlling stake of Opella (consumer health) to CD&R for ~€10B. Becomes “pure-play biopharma.” |
| Jun 23, 2025 | Libertas Bio (Formation Bio subsidiary) licenses gusacitinib to Sanofi. Deal up to €545M. |
| Aug 2025 | Sanofi acquires Vigil Neuroscience for $470M — microglia therapeutics. Same cellular target as Altman’s Retro Biosciences. |
| Sep 2025 | Sanofi Ventures receives $625M additional commitment — total AUM now $1.4B+. 70+ portfolio companies in biotech and AI/digital health. |
| Feb 2026 | Paul Hudson departs as CEO. Olivier Charmeil named interim CEO. |
| Mar 2026 | itepekimab (Dupixent follow-up) fails Phase III for COPD. Regeneron -18%, Sanofi -6%. Narrowing of Regeneron pipeline increases strategic value of Formation Bio. |
Nodes and Open Questions
- The off-balance-sheet structure: How much of Sanofi’s effective drug development spending is hidden through the Formation Bio pathway? If Formation Bio acquires drugs, develops them, and licenses successes to Sanofi while absorbing failures, Sanofi’s reported R&D spending understates its true drug development activity.
- Altman recusal for Muse: The Sanofi-Formation Bio-OpenAI collaboration was announced by Brad Lightcap (OpenAI COO). Did Altman formally recuse? Lightcap now reports directly to Altman (“special projects,” April 2026). Recusal through a direct report is delegation, not separation.
- Claude AND OpenAI simultaneously: Sanofi uses Claude “daily” across the company while also co-developing Muse with OpenAI. This means Sanofi’s proprietary pharmaceutical data flows through BOTH major AI companies. What data governance separates what Claude sees from what OpenAI’s fine-tuned models see?
- Hudson’s departure (Feb 2026): Hudson left Sanofi during the investigation window. His successor (interim CEO Olivier Charmeil) inherits all three Formation Bio relationships. Did Hudson’s departure relate to the growing scrutiny of the Formation Bio/OpenAI conflicts?
- Gusacitinib “new indication”: Sanofi licensed gusacitinib “to explore its potential in a new indication not previously studied.” What indication? The drug was originally developed for eczema (atopic dermatitis). Sanofi already has Dupixent for atopic dermatitis. Why license a competing drug from a company you invested in?
- Sanofi Ventures evergreen fund: In 2025, Sanofi committed new capital to its venture fund specifically for “early-stage companies that align with Sanofi’s long-term growth ambitions.” Is Formation Bio (or its subsidiaries) eligible for this venture funding in addition to the Series D investment?
- Drug Picking Committee: Mikael Dolsten (ex-Pfizer CSO) chairs Formation Bio’s Drug Picking Committee. Dolsten previously led Pfizer’s COVID vaccine program. He now selects which drugs Formation Bio acquires — some of which are then sold to Sanofi. What is Dolsten’s relationship with Sanofi directly?
- The Regeneron parallel: Sanofi co-develops Dupixent with Regeneron (profit-sharing alliance worth billions annually). Regeneron was also the competing bidder for 23andMe ($256M vs TTAM’s $305M). Regeneron is now suing Sanofi over Dupixent transparency. Is Formation Bio’s pipeline Sanofi’s hedge against losing the Regeneron partnership?
- “What are defendants trying to hide?” — Regeneron’s complaint in SDNY alleges Sanofi withheld PBM contracts, bundled Dupixent with other drugs, and that audits “already revealed inaccuracies” in Sanofi’s books. The opacity Regeneron alleges in the Dupixent partnership echoes the opacity of the Formation Bio relationship (no Form D for $250M+ in fundraising, “off balance sheet” framing).
- Middle East/Africa bribery ($25M settlement): Sanofi paid healthcare professionals across 10 countries to sell pharmaceutical products (2007-2015). The same company that settled bribery charges for paying doctors in developing markets is now investing in a clinical trial company (Formation Bio) whose predecessor (TrialSpark) placed one-third of its trial sites in low-income communities.
- Sanofi Global Health Unit: Targets “low- and middle-income countries” — the same demographics targeted by Worldcoin (iris scans), Watsi (surgeries in 25 nations), and OpenResearch’s RISE rural study (West Virginia, North Carolina, Mississippi Delta). Humanitarian framing, pharmaceutical infrastructure.
- itepekimab failure (March 2026): The Dupixent follow-up drug failed Phase III, narrowing Sanofi’s pipeline with Regeneron. This increases the strategic value of Formation Bio’s pipeline as an alternative immunology/inflammation drug source — the timing aligns with the gusacitinib license (June 2025).
Sources
[1] [Archive] (https://en.wikipedia.org/wiki/Sanofi)
[2] [Archive] (https://pharmaphorum.com/articles/a_history_of-_sanofi)
[3] [Archive] (https://www.sec.gov/Archives/edgar/data/0001121404/000112140425000002/pressreleaseq42024english.htm)
[4] [Archive] (https://www.sec.gov/Archives/edgar/data/0001121404/000119312519167602/d760073dex991.htm)
[5] [Archive] (https://www.sec.gov/Archives/edgar/data/0001121404/000119312525106923/d935542dex991.htm)
[6] [Archive] (https://www.fiercebiotech.com/biotech/ai-focused-formation-secures-sanofi-backed-372m-series-d-license-more-drugs)
[7] [Archive] (https://www.sec.gov/Archives/edgar/data/0001121404/000119312524147826/d839421dex994.htm)
[8] [Archive] (https://www.sanofi.com/en/media-room/press-releases/2024/2024-05-21-05-30-00-2885244)
[10] [Archive] (https://www.fiercebiotech.com/cro/sanofi-formation-and-openai-design-ai-tool-slash-clinical-trial-timelines)
[11] [Archive] (https://finance.yahoo.com/news/libertas-bio-formation-bio-subsidiary-130000700.html)
[12] [Archive] (https://www.prnewswire.com/news-releases/libertas-bio-a-formation-bio-subsidiary-license-of-gusacitinib-a-dual-jaksyk-inhibitor-to-sanofi-302487403.html)
[13] [Archive] (https://www.contractpharma.com/breaking-news/formation-bio-licenses-gusacitinib-to-sanofi/)
[14] [Archive] (https://www.anthropic.com/news/healthcare-life-sciences)
[15] [Archive] (https://anthropic.com/webinars/claude-for-life-sciences)
[16] [Archive] (https://www.anthropic.com/news/pwc-expanded-partnership)
[17] [Archive] (https://en.wikipedia.org/wiki/Paul_Hudson_(businessman))
[18] [Archive] (https://www.biospace.com/business/regeneron-sues-sanofi-alleging-stonewalling-in-dupixent-pact)
[19] [Archive] (https://www.fiercepharma.com/pharma/regeneron-sues-partner-sanofi-over-commercial-transparency-long-running-dupixent)
[20] [Archive] (https://www.lexology.com/library/detail.aspx?g=6eee2a3b-657c-4417-870c-32eed7dd9581)
[21] [Archive] (https://www.pearceip.law/wp-content/uploads/2024/12/Regeneron-v-Sanofi-USDC-SDNY-Complaint-7-24-cv-08751.pdf)
[22] [Archive] (https://www.biospace.com/drug-development/sanofi-regeneron-shares-tumble-as-dupixent-follow-up-fails-phase-iii-copd-test)
[23] [Archive] (https://www.fiercepharma.com/pharma/sanofi-to-pay-25m-to-resolve-middle-east-bribery-allegations)
[24] [Archive] (https://matrixbcg.com/blogs/brief-history/sanofi)
[26] [Archive] (https://www.biopharmadive.com/news/sanofi-ventures-625-million-fund-biotech-digital-health-startups/760903/)
[27] [Archive] (https://www.sec.gov/Archives/edgar/data/0001121404/000119312525250744/d69958dex993.htm)