This excerpt taken from the TUNE 10-K filed Mar 11, 2005.
1. RELEASE AND DISCHARGE OF ST. PAUL
Effective upon the Effective Date of Settlement (as defined in Paragraph 25 of the Stipulation and Agreement of Settlement of the Securities Class Action) and upon St. Pauls timely payment of the amounts specified in Paragraphs 1.2 and 1.11(e) of the Settlement and Release Agreement to which this document is attached, the sufficiency of which is hereby acknowledged, Microtune, on its behalf and on behalf of all other insureds or persons, entities or organizations who claim or who may claim any right under the St. Paul Policy,1 and Douglas J. Bartek, William Housley, Everett Rogers, Nancy A. Richardson, James A. Fontaine, James H. Clardy, William P. Tai, Harvey B. Cash, Walter S. Ciciora, Steven Craddock and Anthony J. LeVecchio, collectively and individually, hereby covenant not to sue St. Paul and release, acquit and forever discharge St. Paul, and all other persons, natural and corporate, in privity with it, separately or severally, from any and all past, present or future claims, demands, suits or causes of action of any kind whatsoever, at common law, statutory, or otherwise, which they have or might have against St.
[***] CONFIDENTIAL TREATMENT REQUESTED BY MICROTUNE, INC.