[Translation for Reference Purposes Only]

Tokyo District Court 2017 (sai) No. 35

Outline of the Draft Rehabilitation Plan (January 2021 version)

January 12, 2021

Rehabilitation Debtor: MTGOX Co., Ltd.

Rehabilitation Trustee: Nobuaki Kobayashi, Attorney-at-law

Introduction

The Rehabilitation Trustee (the “Trustee”) filed a draft rehabilitation plan (the “Draft
Rehabilitation Plan”) on December 15, 2020, to the Tokyo District Court (the “Court”). Set out
below is an outline of the Draft Rehabilitation Plan. Please note, however, that currently the
Court and the examiner appointed by the Court are reviewing the Draft Rehabilitation Plan and
any changes in all respects may be made.

1. Policy for Disposing of Debtor’s Assets (i.e., Distribution Source)

1.1. Overview
Given that the proceedings are substantially liquidation-type proceedings, the only distribution
source will be the Rehabilitation Debtor’s (the “Debtor”) Japanese yen (“yen”) currency holdings,
cryptocurrency holdings and other such assets less various expenses anticipated to be incurred to
conclude these proceedings. In this regard, yen currency holdings, Bitcoin (“BTC”) and Bitcoin
Cash (“BCH”) holdings will be the source for distribution while all other assets such as
cryptocurrencies other than BTC and BCH will be liquidated into cash to the extent possible.
For the BTC and BCH conversion-to-cash policy, please see 1.3. below.
Further, in the course of implementing the Draft Rehabilitation Plan, the New Assets 1 might
be added to the source for distribution, including the possibility of the lost BTC being returned.
However, since the Trustee cannot wait indefinitely for the acquisition of the New Assets, after
all disputed rehabilitation claims have been determined, the Trustee has the policy that, unless
there is a high probability that the New Assets can be acquired within a reasonable period of time,
to promptly make distribution of the Final Payment (as defined below) 2 and conclude the

1
The “New Assets” mean the Debtor’s assets managed by the Trustee after December 15, 2020; hereinafter
the same.
2
See 3.2.2. below.

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rehabilitation proceedings. If the Trustee acquires the New Assets after the Final Payment and
will make exceptional additional payments, the Trustee will pay to rehabilitation creditors the
difference 3 between (i) the payment amount assuming that such New Assets had existed at the
time of the Final Payment and (ii) the amount actually paid.

1.2. Valuation of BTC and/or BCH as Distribution Source

As discussed in 4.2. below, the Trustee has the policy that, subject to the satisfaction of certain
requirements, to make distributions to BTC creditors in BTC (“BTC Payment(s)”) and
distributions to BCH creditors in BCH (“BCH Payment(s)”) (hereinafter, BTC Payment and/or
BCH Payment are referred to collectively as “BTC/BCH Payment(s)”).
The BTC and BCH constituting the Debtor’s assets (i.e., source for distribution) (hereinafter,
BTC and/or BCH are collectively referred to as “BTC/BCH”), regardless of their respective
market value at the time of distributions, will be valuated at the BTC/BCH to yen conversion rate
as of the time of commencement of the rehabilitation proceedings. 4 This valuation will be the
basis for calculation of distribution amounts (see 3. below).

1.3. Sale of BTC/BCH; Change in Source for Distribution Resulting from Sale of BTC/BCH
(1) The Trustee plans to pay all fiat currency claims in cash. Consequently, a sufficient amount
of cash must be secured as the source for distribution for payment of fiat currency claims.
For reasons including this, the Trustee may, with the permission of the Court, sell all or part
of the BTC/BCH constituting the Debtor’s assets.
(2) If the Trustee sells BTC/BCH then BTC/BCH holdings will decrease accordingly. As a result
of the sale proceeds being added to the Debtor’s assets, the total valuation amount of the
source for distribution will change. 5
For example, assuming the Debtor’s assets consist only of 1,000,000 yen and 100 BTC, the
total valuation of such assets will be 75,931,883 yen in accordance with 1.2. above. 6 If the
Trustee sells 50 BTC of the 100 BTC at “1 BTC = 1,000,000 yen,” the total valuation of the

3
Namely, the difference equals (i) minus (ii).
4
(i) 749,318.83 yen/BTC (the “BTC Rate”), (ii) 97,481.19 yen/BCH (the “BCH Rate”); hereinafter (i)
and/or (ii) are collectively referred to as the “BTC/BCH Rate”.
The foregoing are the same yen conversion rates used at the time of the Trustee’s approval/disapproval of
proofs of rehabilitation claims in the rehabilitation proceedings.
5
If the Trustee sells BTC/BCH at a yen conversion rate that exceeds or is less than the BTC/BCH Rate,
the total valuation amount of the source for distribution will increase or decrease from the amount before
the sale, accordingly.
6
100 BTC converted to yen at the BTC Rate equals 74,931,883 yen. The total will be 75,931,883 yen by
adding 1,000,000 yen.

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Debtor’s assets (i.e., source for distribution) will increase to 88,465,941 yen after the sale. 7

1.4. No Additional Purchases of BTC/BCH

The Trustee will not purchase additional BTC/BCH. As a result, the BTC/BCH holdings may
not be sufficient as a source for BTC/BCH Payments; for the discussion of such case, refer to
4.2.2. below.

2. Valuation of Rehabilitation Claims Pursuant to the Draft Rehabilitation Plan

2.1. Fiat Currency Claims

Those fiat currency claims that are foreign currency-denominated claims are valued at the yen
conversion rate on the day preceding the date of the commencement order of the rehabilitation
proceedings. 8 Then, any distribution under the Draft Rehabilitation Plan to fiat currency claims
held by a single rehabilitation creditor is calculated based on the sum total of all fiat currency
claims, including both amounts of yen-denominated claims and amounts of foreign currency-
denominated claims that are valued in accordance with the foregoing, held by such creditor. 9
For example, if a certain rehabilitation creditor has fiat currency claims in the amounts of
10,000 yen and 100 US dollars, the payments under the Draft Rehabilitation Plan are calculated
on the basis of 21,143 yen, which is the sum total of 10,000 yen and 11,143 yen (i.e., 100 US
dollars valued at the yen conversion rate on the day preceding the date of the commencement
order of the rehabilitation proceedings (i.e., 111.43 yen/US dollar)).

2.2. BTC/BCH Claims

For BTC Claims and/or BCH Claims (“BTC/BCH Claim(s)”), any payment under the Draft
Rehabilitation Plan is calculated on the basis of amounts converted to yen based on the BTC/BCH
Rate.

3. Distribution Amounts and Distribution Dates

The Trustee makes (i) priority payment to secure the interests of fiat currency claims, (ii) small
sum payment (these two payments are referred to collectively as the “Base Payment”; the sum
total of the payment amounts for (i) priority payment to secure the interests of fiat currency claim

7
The sale of 50 BTC will add 50,000,000 yen cash to the Debtor’s assets. The valuation of the Debtor’s
assets will be a total of 88,465,941 yen, consisting of 37,465,941 yen, which represents the remaining 50
BTC converted to yen at the BTC Rate, plus 51,000,000 yen cash.
8
The same as the yen conversion rate used at the time of the Trustee’s approval/disapproval of proofs of
rehabilitation claims in the rehabilitation proceedings.
9
The number of rehabilitation creditors who are of the Debtor’s BTC exchange (the “Exchange User(s)”)
is determined by counting the number of user accounts at such exchange; hereinafter the same.

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and (ii) small sum payment is referred to as the “Base Payment Amount”), and (iii) prorated
payments.

3.1. Base Payment

The Trustee implements first, among all the distributions to be made, the Base Payment
stipulated in 3.1.1. and 3.1.2. below.

3.1.1. Priority Payment to Secure the Interests of Certain Fiat Currency Claims
The Trustee gives priority in payment to the fiat currency claims allowed in the rehabilitation
proceedings that meet certain requirements including those under the bankruptcy proceedings of
MtGox (currently the Debtor) 10 11
, to secure the interests of such fiat currency claims, in the
amounts equal to those amounts that would have been received in the Bankruptcy Proceedings
had the Bankruptcy Proceedings continued.
Specifically, the payment amount for the fiat currency claims that benefits from the priority
payment, which need to meet certain requirements including those under the Bankruptcy
Proceedings, is the sum total of the claims in the rehabilitation proceedings converted into yen at
the yen conversion rate 12 on the day preceding the date of the commencement order of the
Bankruptcy Proceedings.

3.1.2. Small Sum Payment

The Trustee makes small sum payment of up to 200,000 yen for each single rehabilitation
creditor. 13 14

Further, if a single rehabilitation creditor has both fiat currency claims and BTC/BCH Claims,
the small sum payment first applies to fiat currency claims and if there is any balance after such
application then the remaining small sum payment applies to BTC/BCH Claims. 15

3.2. Prorated Payments

10
Tokyo District Court 2014 (fu) No. 3830 (the “Bankruptcy Proceedings”)
11
For instance, one of the requirements is that proofs of fiat currency claims were also filed in the
Bankruptcy Proceedings.
12
The same as the yen conversion rate used at the time of the Bankruptcy Trustee’s approval/disapproval
of proofs of bankruptcy claims in the Bankruptcy Proceedings.
13
Consequently, as discussed in 2.1. above, the Exchange Users will receive a small sum payment of up
to 200,000 yen for each user account.
14
Small sum payment of up to 200,000 yen means payment of the lower of either 200,000 yen or the
rehabilitation claim balance.
15
For the avoidance of doubt, if a single rehabilitation creditor holds only BTC/BCH Claims, a small sum
payment of up to 200,000 yen only applies to the BTC/BCH Claims.

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Prorated payments are payments implemented in accordance with the size of the balance
remaining after the Base Payment Amount is deducted from the rehabilitation claim valuation
amount (calculated pursuant to 2. above) (such balance, “Post-Base Payment Balance(s)”). 16
In this regard, as set out in 3.2.1. and 3.2.2. below, the Trustee plans to implement two types
of prorated payments, depending on the election of each rehabilitation creditor: (a) the “Early
Lump-Sum Payment” and (b) the “Final Payment” (including the “Intermediate Payments”).
More specifically, rehabilitation creditors who do not receive full payments from the Base
Payment, may, by a reference date to be designated separately (a date during the period from the
time of the confirmation order of the Draft Rehabilitation Plan becoming final and binding until
the Base Payment (see 3.1. above); the “Early Lump-Sum Payment Reference Date”), elect either
(a) the Early Lump-Sum Payment or (b) the Final Payment (including the Intermediate Payments).
This election can be made only once during the rehabilitation proceedings, and no subsequent
changes will be allowed.
It should be noted that the opportunity to elect the Early Lump-Sum Payment is granted to
rehabilitation creditors as an option, and the principle prorated payment under the Draft
Rehabilitation Plan is the Final Payment (including the Intermediate Payments). Accordingly, a
rehabilitation creditor who does not elect either of them will be deemed to have elected the Final
Payment (including the Intermediate Payments).

3.2.1. Early Lump-Sum Payment

A rehabilitation creditor who elects the Early Lump-Sum Payment can receive distribution of a
sum equivalent to 21% of each Post-Base Payment Balance (such payment amount, the “Early
Lump-Sum Payment Amount”) at the same time as the Base Payment (see 3.1. above). However,
for rehabilitation creditors who receive the Early Lump-Sum Payment, in principle, distributions
under the Draft Rehabilitation Plan will be completed at the point in time of the Early Lump-Sum
Payment, and such rehabilitation creditors cannot also receive the Final Payment or the
Intermediate Payments (see 3.2.2. below).

3.2.2. Final Payment (including Intermediate Payments)

(1) The Final Payment is the distribution of the amount obtained by prorating the valuation
amount of the Debtor’s assets comprised of yen holdings and BTC/BCH holdings (calculated
pursuant to 1. above) in accordance with a rehabilitation creditor’s Post-Base Payment
Balance (such payment amount, the “Final Payment Amount”).

16
Accordingly, rehabilitation claims that are fully paid through the Base Payment will not be the subject
of prorated payments.

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Distribution Source Valuation Amount (see 1.

Final
Post-Base Payment Balance above)
Payment = ×
for each rehabilitation claim
Amount Sum Total of Post-Base Payment Balances for All
the Rehabilitation Claims

Further, the distribution date for the Final Payment, as the name suggests, will be after the
day on which all the disputed rehabilitation claims have been determined and the disposal (i.e.,
liquidation into cash) has been completed of those Debtor’s assets determined by the Trustee
to be suitable for liquidation into cash that not yet been liquidated into cash.
(2) In this regard, as set forth in 3.2.1. above, since the Early Lump-Sum Payment is implemented
concurrently with the Base Payment, the Early Lump-Sum Payment will be carried out prior
to the Final Payment. Nevertheless, the Final Payment Amount is calculated on the basis of
the financial circumstances (i.e., valuation amount of distribution source and rehabilitation
claims) of the Debtor assuming that the Early Lump-Sum Payment had not been implemented.
In other words, calculation is made not of payment amounts under the actual financial
circumstances immediately prior to the Final Payment, but of payment amounts under the
above hypothetical financial circumstances.
Therefore, the “Distribution Source Valuation Amount” of (1) above is calculated assuming
that the Debtor’s assets that were used for the Early Lump-Sum Payment still existed as of the
time of the Final Payment. Also, the “Sum Total of Post-Base Payment Balances for All the
Rehabilitation Claims” of (1) above includes the Post-Base Payment Balances of rehabilitation
claims which claimholders elect the Early Lump-Sum Payment 17 (the rate obtained by
dividing the Distribution Source Valuation Amount of (1) above by the Sum Total of Post-
Base Payment Balances for all the rehabilitation claims is referred to as the “Final Payment
Rate”).
Consequently, rehabilitation creditors electing the Final Payment suffer no disadvantage
from the implementation of the Early Lump-Sum Payment.
(3) As set forth in 1.2. above, the BTC/BCH included in the source for distribution will be valuated
at the BTC/BCH Rate, regardless of its respective market value at the time of distributions
(as set forth in 1.3. above, if the Trustee sells BTC/BCH then the sales proceeds will be added
to the source for distribution). For example, assuming that the Distribution Source

17
In other words, the balance prior to the Early Lump-Sum Payment (Post-Base Payment Balance) of
rehabilitation claims receiving the Early Lump-Sum Payment is included in the calculation of the Sum Total
of Post-Base Payment Balances for All the Rehabilitation Claims.

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Valuation Amount is 1,000,000 yen and 1 BTC while the Sum Total of Post-Base Payment
Balances for All the Rehabilitation Claims comprise a fiat currency claim in the amount of
10,000,000 yen and a BTC Claim in the amount of 10,000,000 yen, the Final Payment is
calculated as 874,659 yen for each of the fiat current claim and the BTC Claim. 18
(4) While it depends on the status of disposal of the Debtor’s assets and of the disputed
rehabilitation claims, the Trustee has the policy that prorated payments of a certain portion of
the Final Payment Amount for rehabilitation creditors who elect the Final Payment will be
made prior to the Final Payment (i.e., the Intermediate Payments). 19 While this may change
depending on the foregoing, it is planned for now to implement the initial Intermediate
Payment concurrently with the Base Payment. The Trustee plans to present to the
rehabilitation creditors the amount of the initial Intermediate Payment by the Early Lump-
Sum Payment Reference Date for electing between the Early Lump-Sum Payment or the Final
Payment (including the Intermediate Payments). 20

3.3. Risk Compensation and Subordination of Specific Rehabilitation Claims

(1) Given the size of the Debtor’s assets and rehabilitation claims (including disputed
rehabilitation claims) as of now, it is expected that unless large disputed rehabilitation claims
are subsequently allowed 21, the Final Payment Rate (see 3.2.2. above) will be greater than the

18
= 10,000,000 yen x{1,000,000 yen + 1 BTC x the BTC Rate (749,318.83 yen)} /20,000,000 yen
19
The number of the Intermediate Payments is not limited to one and there may be multiple Intermediate
Payments.
20
The source for distribution that can be used for the initial Intermediate Payment will be affected by the
status of determination of disputed rehabilitation claims. This is because, if there remain large disputed
rehabilitation claims, it is necessary to set aside a large portion of the Debtor’s assets considering the
possibility of disputed rehabilitation claims subsequently being allowed. If the amount of disputed
rehabilitation claims decreases then a larger portion of the source for distribution can be allotted to the
initial Intermediate Payment.
21
CoinLab, Inc. (“CoinLab”) filed proofs of their rehabilitation claims of roughly 1,700,000,000,000 yen;
the Trustee rejected the entire amount of such claims. The Court made a claim assessment order in respect
to such filed claims, approving only 1,063,347,070 yen (composed of principal and delay damages prior to
the commencement of the rehabilitation proceedings) and delay damages following the commencement of
the rehabilitation proceedings. Under the Civil Rehabilitation Act, parties with objections to a claim
assessment order may file motions to oppose within an unextendable deadline of one month from service
of the order (Civil Rehabilitation Act, Article 106, Paragraph 1). Accordingly, following such claim
assessment order, both the Trustee and CoinLab filed motions opposing the order prior to the elapse of the
unextendable period.
In regards to this point, in its complaint for such motion, CoinLab explicitly stated that the claimed
amount sought in its motion (49,482,274,345 yen and delay damages thereon following the commencement
of the rehabilitation proceedings) is partial, asserting that it is nonetheless entitled to subsequently expand
its claims to include the remaining unapproved amount of over 1,600,000,000,000 yen. The Trustee
believes, however, that given that the opposition filing period for a claim assessment order is statutorily
limited, it is impermissible under the Civil Rehabilitation Act to expand a claim in a motion to oppose a
claim assessment order after the elapse of the opposition filing period. In the rehabilitation proceedings,

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Early Lump-Sum Payment rate of 21% (see 3.2.1. above).

If the Final Payment Rate is greater than the Early Lump-Sum Payment rate of 21%, then
the actual payment amount received by rehabilitation creditors electing the Early Lump-Sum
Payment (i.e., the Early Lump-Sum Payment Amount) will be lower than the amount they
would have received had they elected the Final Payment (i.e., the Final Payment Amount).
Nevertheless, rehabilitation creditors electing the Early Lump-Sum Payment cannot receive
the Final Payment (see 3.2.1. above). As a result, the Debtor’s assets will have a surplus to
the extent that the actual payment amount made to rehabilitation creditors electing the Early
Lump-Sum Payment was lower. The surplus of the Debtor’s assets will become fees (the
“Risk Compensation”) paid to Mt Gox Investment Fund LP (“MGIF LP”). In other words,
the difference between the payment amount rehabilitation creditors electing the Early Lump-
Sum Payment would have received had they elected the Final Payment (i.e., the Final Payment
Amount) and the Early Lump-Sum Payment Amount they actually receive will be the Risk
Compensation.
More specifically, MGIF LP, with a view towards realizing the Early Lump-Sum Payment,
(a) reached agreement with CoinLab, which has potentially large disputed rehabilitation
claims (as explained above), that in exchange for cooperation payments to CoinLab of
11,000,000 US dollars at a maximum 22, any disputed rehabilitation claims of CoinLab that are
subsequently allowed will be treated as subordinate to other allowed rehabilitation claims 23,
and (b) reached agreement with the Trustee that, among other things, MGIF LP’s allowed
rehabilitation claims will be treated as subordinate to other allowed rehabilitation claims or
that MGIF LP will separately provide a cash collateral or its equivalent (see (2) below). The
purpose of these agreements is as set forth below. The Risk Compensation is payment to
MGIF LP as consideration for providing rehabilitation creditors with the opportunity for the
Early Lump-Sum Payment in accordance with (a) and (b) above.
For the avoidance of doubt, rehabilitation creditors electing the Final Payment are assured
of payment based on the financial circumstances of the Debtor assuming that the Early Lump-
Sum Payment had not been implemented (see 3.2.2.(2) above). Accordingly, rehabilitation
creditors electing the Final Payment will not be forced to bear the Risk Compensation.

whether CoinLab is allowed to subsequently expand its claims by over 1,600,000,000,000 yen —in other
words, whether the expanded portion of its claims can also be subject to disputed rehabilitation claims—is
a major issue.
22
These cooperation payments to CoinLab will be paid from the funds MGIF LP itself will procure, and
will not be paid from the Debtor’s assets; nor will they be treated as payments of CoinLab’s rehabilitation
claims.
23
Based on its agreement with MGIF LP, CoinLab submitted to the Trustee its declaration letter (dated
December 14, 2020) to the effect that it had agreed that in the event that CoinLab’s disputed rehabilitation
claims are subsequently recognized as allowed rehabilitation claims, such claims will be treated as
subordinate to other allowed rehabilitation claims as long as the Early Lump-Sum Payment is implemented.

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(2) On the other hand, if a large amount of disputed rehabilitation claims are to be subsequently
allowed and the Final Payment Rate falls below the Early Lump-Sum Payment rate of 21%,
no Risk Compensation will be paid to MGIF LP (because there will be no resource for the
Risk Compensation).
Further, in the event that the Final Payment Rate falls below the Early Lump-Sum Payment
Rate of 21%, the actual payment amount for rehabilitation creditors electing the Early Lump-
Sum Payment (i.e., the Early Lump-Sum Payment Amount) will be greater than the amount
they would have received had they elected the Final Payment (i.e., the Final Payment Amount).
However, the Early Lump-Sum Payment will have already been implemented, and cannot be
revoked. As a result, the Debtor’s assets will have a deficit to the extent that the actual
payment amount to rehabilitation creditors electing the Early Lump-Sum Payment was higher
(excessive distribution of the Debtor’s assets in the Early Lump-Sum Payment).
In such case, in order to make up for the deficit in the Debtor’s assets, MGIF LP’s allowed
rehabilitation claims will be treated as subordinate to other allowed rehabilitation claims, or
MGIF LP will separately provide a cash collateral or its equivalent (see (1)(b) above).
Further, in the event that an extremely large amount of disputed rehabilitation claims are
subsequently allowed and the subordination of MGIF LP’s allowed rehabilitation claims or
the cash collateral (or its equivalent) is not sufficient to make up for the deficit in the Debtor’s
assets, CoinLab’s rehabilitation claims will be treated as subordinate (see (1)(a) above).
CoinLab has agreed to such treatment following the agreement on cooperation payments from
MGIF LP.
(3) The Trustee plans to explain to rehabilitation creditors, by the Early Lump-Sum Payment
Reference Date for electing either the Early Lump-Sum Payment or the Final Payment, among
other things, the status of the Debtor’s assets and disputed rehabilitation claims as of such
reference date and the amount of the initial Intermediate Payment to be implemented
concurrently with the Base Payment (see 3.2.2.(4) above). Therefore, it will be possible for
rehabilitation creditors to consider such explanation when deciding between the Early Lump-
Sum Payment and the Final Payment. However, as the prorated payment in the rehabilitation
proceedings are in principle the Final Payment, the Trustee will bear no liability whatsoever
regarding any disadvantage 24 arising from a rehabilitation creditor’s having elected the Early
Lump-Sum Payment.

24
For example, including, without limitation, disadvantage in the form of the actual payment amount made
to a rehabilitation creditor’s electing the Early Lump-Sum Payment being lower than the amount it would
have received had it elected the Final Payment, as a result of only a low amount of disputed rehabilitation
claims being subsequently recognized as allowed and the Final Payment Rate being greater than the Early
Lump-Sum Payment Rate of 21% (see (1) above).

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4. Payment Methods
Amounts of payments for each rehabilitation claim will be calculated in yen in accordance with
3. above. Set out below are the planned payment methods.

4.1. Payment Methods for Fiat Currency Claims

In principle, payment of fiat currency claims will be made by the Trustee receiving bank
account information from each rehabilitation creditor and remitting payments to such accounts
from the Trustee’s bank account. International remittances are planned, and in such cases, the
Trustee’s policy is that the legal currencies that will be used when making payments from the
Trustee bank account will be any of yen, US dollars, or euros, as requested by a rehabilitation
creditor. The conversion rates into foreign currencies at such time will be decided by referring
to the rates on the respective payment dates. Remittance fees, foreign currency exchange fees,
and other expenses shall be borne by each rehabilitation creditor.
If bank remittance cannot be made because a rehabilitation creditor fails to provide account
information or for any other reasons, payment will be made in yen at the Debtor’s head office.
If a rehabilitation creditor does not come to collect payment, the amount will be deposited with
the Legal Affairs Bureau of Japan.
In addition to the foregoing, the Trustee is currently in negotiations to make available payment
methods through funds transfer service providers with lower fees than bank remittance fees.

4.2. Payment Methods for BTC/BCH Claims

4.2.1. Overview
(1) The cryptocurrency payments that the Trustee adopts are limited to BTC/BCH Payment. The
Trustee sells to the extent possible all cryptocurrencies other than BTC/BCH (see 1.1. above),
with no intention of making distribution in any cryptocurrencies other than BTC/BCH.
(2) On the method for BTC/BCH Payment, the Trustee does not directly transfer to BTC/BCH
creditors but make indirect payment to them through exchanges (including custodians) that
handle BTC/BCH.
First, a BTC/BCH creditor must, by a designated reference date (a date during the period
from the time of the confirmation order of the Draft Rehabilitation Plan becoming final and
binding until the Base Payment (see 3.1. above); the “Cryptocurrency Payment Reference
Date”), request either BTC/BCH Payment or cash only payment. Such request can be made
only once through the rehabilitation proceedings and no subsequent changes will be allowed.
A BTC/BCH creditor who does not make a request for either payment will be deemed to have
requested cash only payment. As explained in 4.2.2. and 4.2.4. below, regardless of whether

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BTC/BCH Payment or cash only payment is requested, the Trustee provisionally decides with
respect to all BTC/BCH Claims the percentage of the payment amount that will be BTC/BCH
and the percentage that will be cash 25; the Trustee’s policy is to make effort so that, to the
extent possible, such percentages are fair and impartial for all BTC/BCH Claims. 26
BTC/BCH creditors requesting BTC/BCH Payment must complete user account
registration no later than the Cryptocurrency Reference Date at any one of the cryptocurrency
exchanges or custodians to be designated separately by the Trustee (each, a “Designated
Exchange”). The BTC/BCH creditors thereafter must reach with the Designated Exchanges
at which they have registered an agreement that allows such Designated Exchanges to serve
as their agents for receiving BTC/BCH Payments. The Trustee then uses blockchain
technology to transfer to a Designated Exchange BTC/BCH in lump-sum matching the total
amount of BTC/BCH that BTC/BCH creditors who registered at such Designated Exchange
are to receive. For example, if there are a total of 10,000 BTC creditors who registered at a
certain Designated Exchange and the total number of BTC that such 10,000 creditors are to
be paid is 30,000 BTC, the Trustee transfers to such Designated Exchange 30,000 BTC in
lump-sum using blockchain technology.
(3) At the point in time that the Trustee completes transfers of BTC/BCH to the Designated
Exchanges using blockchain technology, the Trustee’s payment to BTC/BCH creditors under
the Draft Rehabilitation Plan shall be regarded to have completed. Following completion of
such transfers to the Designated Exchanges, the terms of use and/or other rules of the relevant
Designated Exchange provide for how the BTC/BCH transferred from the Trustee will be
treated between the BTC/BCH creditors and the Designated Exchanges, while the Trustee will
have no involvement and bear no liability in regards thereto.

25
However, for BTC/BCH Claims for which cash only payment is requested (“BTC/BCH Claim(s)
Requesting Cash Payment”), while the number of BTC/BCH to be allotted will be provisionally determined
based on the percentage of the payment amount represented by BTC/BCH, payments will be made in cash
only, not in BTC/BCH (see 4.2.4. below).
26
Assuming that the Early Lump-Sum Payment (see 3.2.1. above) is implemented, there will be two types
of BTC/BCH Claims: those that are subject to the Final Payment (see 3.2.2. above) and those that are
subject to the Early Lump-Sum Payment. In this regard, the Trustee cannot forecast the exact content of
the Final Payment, such as the Final Payment Amount and the Final Amount Rate, at the time of the Early
Lump-Sum Payment. Accordingly, the Trustee will not be able to make the percentage of the payment
amount represented by BTC/BHC and the percentage of the payment amount represented by cash be the
same for all BTC/BCH Claims. In other words, the percentage of the Early Lump-Sum Payment Amount
represented by BTC/BCH cannot be the same as the percentage of the Final Payment Amount represented
by BTC/BCH. However, the Trustee’s policy is to make effort so that such percentages are fair and
impartial to the extent possible.

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Designated
Lump-sum transfer of BTC/BCH Exchanges
Trustee
(receipt agent)

Request for BTC/BCH User registration;

Payment Receipt agency

BTC/BCH
agreement
creditors

4.2.2. Amount of BTC/BCH to be paid in BTC/BCH Payment; What happens if there is

Insufficient BTC/BCH?
The maximum BTC/BCH that will be paid to BTC/BCH Claims for which BTC/BCH Payment
is requested (“Claim(s) Requesting BTC/BCH Payment”) is, for each Claim Requesting
BTC/BCH Payment, the payment amount calculated in accordance with 3. above (yen) using the
BTC/BCH Rate. This calculation is not affected by the BTC/BCH market price on the
respective payment dates.
As discussed in 1.4. above, because the Trustee does not make additional purchase of
BTC/BCH, it is possible that there will be an insufficient amount of BTC/BCH as the source for
distribution. In such case, Claims Requesting BTC/BCH Payment will receive partial payment
in cash, in accordance with the method set out in 4.1. above. For example, if the payment
amount for a certain BTC Claim is 1,000,000 yen and BTC Payment of only 1 BTC is made, the
remaining payment amount of 250,682 yen 27 will be paid in cash in the same manner as fiat
currency claims will be.

4.2.3. What happens if BTC/BCH Payment cannot be made to Claims Requesting

BTC/BCH Payment?
In a case where, for example, a BTC/BCH creditor who has a Claim Requesting BTC/BCH
Payment was unable to complete user account registration at a Designated Exchange, the Trustee
will be unable to transfer the BTC/BCH allocable to such creditor to the Designated Exchange.
In addition, in a case where a BTC/BCH creditor who has a Claim Requesting BTC/BCH Payment
was a user of a Designated Exchange at the time of the first payment but is no longer a user at the
time of subsequent payments, BTC/BCH Payment cannot be made to such creditor at the time of

27
250,682 yen = 1,000,000 yen – 1 BTC x the BTC Rate (749,318.83 yen)

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the subsequent payments.

In these cases where BTC/BCH Payment cannot be made to Claims Requesting BTC/BCH
Payment, with the permission of the Court, the Trustee sells on the market the BTC/BCH that had
been planned for distribution for such claims and will make payments in accordance with 4.1.
above with the sale proceeds (i.e., cash). 28 Given that such sale proceeds will be nothing more
than a substitute for the BTC/BCH that had been planned for distribution for such claims,
regardless of the amount of such proceeds, the payment with such sales proceeds to such claims
has the effect of payment in the amount that would have been paid if payment to such claims had
been made in BTC/BCH.
For example, assume that the payment amount pursuant to 3. above for a certain BTC Claim is
1,000,000 yen and as illustrated in 4.2.2. above a payment of 1 BTC and 250,682 yen had been
planned, but that 1 BTC is sold for 1,000,000 yen on the market because BTC Payment could not
be made. In this case, a total of 1,250,682 yen will be paid out to such BTC Claim, but such
payment amount will be deemed under the Draft Rehabilitation Plan to be the same amount as the
payment amount comprising 1 BTC and 250,682 yen in cash, namely, 1,000,000 yen. Likewise,
if the value of BTC suddenly drops and BTC cannot be sold on the market, thereby only 250,682
yen in cash being paid, the payment amount under the Draft Rehabilitation Plan will be deemed
1,000,000 yen.

4.2.4. Payment Methods for BTC/BCH Claims Requesting Cash Payment

With regards to BTC/BCH Claims Requesting Cash Payment, too, the Trustee, in the same
manner as Claims Requesting BTC/BCH Payment, decides the number of BTC/BCH of the
Debtor’s Assets (source for distribution) to allot, with an upper limit of the number obtained by
using the BTC/BHC Rate to convert each payment amount (yen) calculated in accordance with 3.
above for each BTC/BCH Claim Requesting Cash Payment. In other words, in regards to
BTC/BCH Claims Requesting Cash Payment, even though in the end payment will be made in
cash only, the Trustee provisionally decides the percentage of the payment amount represented by
BTC/BCH. It is the Trustee’s policy that when deciding such percentage and numbers to allot,
to make effort such that the percentage equal to the percentage of the payment amount for Claims
Requesting BTC/BCH Payment represented by BTC/BCH. 29

28
Fees and expenses required for the sale will be deducted.
29
For example, let us assume that the Final Payment Amount for a certain BTC Claim requesting BTC
Payment is 1,000,000 yen and that the payment amount to be paid in BTC for the BTC claim is 1 BTC, the
percentage of the BTC Payment in the Final Payment Amount for the BTC Claim is approximately 75%.

 1 BTC x the BTC Rate (749,318.83 yen) ÷ 1,000,000 yen = 0.75 (approximately)

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Then, the Trustee, with the Court’s permission, sells on the market the BTC/BCH allotted to
BTC/BCH Claims Requesting Cash Payment and makes payments with the sale proceeds (i.e.,
cash) 30 for such claims in accordance with 4.1. above. Because such sale proceeds will be
nothing more than a substitute for the provisionally allotted BTC/BCH, regardless of the amount
of such proceeds, the payment with such sales proceeds to BTC/BCH Claims Requesting Cash
Payment will have the effect of payment in the amount that would have been paid if payment to
such claims had been made in BTC/BCH. This means that, with respect to payment of
BTC/BCH Claims Requesting Cash Payment, the same processing will be carried as in a case
where BTC/BHC payment cannot be implemented for Claims Requesting BTC/BCH Payment
(see 4.2.3. above).
For example, assume that in relation to a certain BTC Claim regarding which cash only
payment is requested, the payment amount based on 3. above is 1,000,000 yen and the number of
BTC provisionally allotted for such claim decided pursuant to the above policy is 1 BTC. First,
31
the portion of the payment amount that cannot be covered with 1 BTC, of 250,682 yen , will
naturally be paid in cash. In addition, because for such BTC Claim requesting cash only
payment, payment in BTC cannot be made, let us assume that such 1 BTC is sold on the market
for 1,000,000 yen. In this case, a total of 1,250,682 yen will be provided with respect to such
BTC claim, but such payment amount will be deemed under the Draft Rehabilitation Plan to be
the same amount as the payment amount comprising 1 BTC and 250,682 yen in cash, namely,
1,000,000 yen. In the event that the value of BTC suddenly falls and BTC cannot be sold on the
market, even if the amount delivered with respect to such BTC claim is only 250,682, the payment
amount under the Draft Rehabilitation Plan will still be deemed to be 1,000,000 yen.

5. Discharge of Rehabilitation Claims under the Draft Rehabilitation Plan

Any interest and delay damages arising on allowed rehabilitation claims that have accrued since
the date of the commencement order of the rehabilitation proceedings shall be discharged in full

In such case, the percentage of BTC Payment in the Final Payment Amount for other BTC Claims
requesting BTC Payment is also approximately 75%.
Furthermore, the Trustee’s policy is to make the percentage that BTC represents of the Final Payment
Amount for BTC Claims requesting cash only payment be the same (approximately 75%). In the example
of a certain BTC Claim requesting cash only payment for which the Final Payment Amount is 2,000,000
yen, the Trustee provisionally decides that the number allotted to the BTC Claim requesting cash only
payment is 2 BTC.

 2,000,000 yen x 0.75 (approximately) ÷ the BTC Rate (749,318.83 yen) = 2 BTC
30
Fees and expenses required for the sale will be deducted.
31
250,682 yen = 1,000,000 yen – 1 BTC x the BTC Rate (749,318.83 yen)

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at the time a confirmation order of the Draft Rehabilitation Plan becomes final and binding.
Any balance of the principal of allowed rehabilitation claims as well as any interest and delay
damages thereon in the period up to the day before the date of the commencement order of the
rehabilitation proceedings with the total payment amount of 3. above deducted shall, in principle,
when the Final Payment has been completed, be discharged 32; provided, however, that if a new
asset (if any), if acquired after the Final Payment, enables further payments, the amount of the
discharge shall be reduced retroactively by the amount of such further payments.

6. Disputed Rehabilitation Claims

(1) If a single rehabilitation creditor 33 has both allowed and disputed rehabilitation claims, the
stipulations of 2. through 5. above apply only when all the rehabilitation claims held by such
creditor are determined. In other words, to the extent that a single rehabilitation creditor has
disputed rehabilitation claims, the stipulations of 2. through 5. above do not apply to such
creditor’s rehabilitation claims; not only disputed rehabilitation claims but also such creditor’s
allowed rehabilitation claims. Regardless of whether such creditor possesses allowed
rehabilitation claims, a rehabilitation creditor with disputed rehabilitation claims is referred
to as “Creditor(s) with Disputed Rehabilitation Claims” for the purpose of the Draft
Rehabilitation Plan.
(2) If the day on which all the rehabilitation claims held by a Creditor with Disputed
Rehabilitation Claims are determined is a day on or after the day six months prior to the
distribution deadlines pursuant to 3. above to creditors with allowed rehabilitation claims only,
the Trustee makes catch-up payments to the Creditor with Disputed Rehabilitation Claims by
the final day of the month including the day marking the elapse of one year from such
determination.
(3) The Trustee requests a Creditor with Disputed Rehabilitation Claims 34 to elect, in relation to
the prorated payment that such Creditor with Disputed Rehabilitation Claims can receive if
all the rehabilitation claims held by such Creditor with Disputed Rehabilitation Claims are
determined, either the Early Lump-Sum Payment or the Final Payment (including the
Intermediate Payments) by the Early Lump-Sum Payment Reference Date. 35 In other words,
even before the point in time that all the rehabilitation claims of a Creditor with Disputed
Rehabilitation Claims are determined, such Creditor with Disputed Rehabilitation Claims will

32
While allowed rehabilitation claims selecting the Early Lump-Sum Payment cannot receive the Final
Payment (see 3.2.1. above), any remaining balance of principal of such allowed rehabilitation claims and
their interest and delay damages thereon up to the day prior to the date of the rehabilitation proceedings
commencement order will also be discharged at the time of completion of the Final Payment.
33
See 2.1. above.
34
Excluding CoinLab. In other words, CoinLab cannot select the Early Lump-Sum Payment.
35
See 3.2. above.

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be requested to elect either the Early Lump-Sum Payment or the Final Payment (including the
Intermediate Payments) by the Early Lump-Sum Payment Reference Date.
If a Creditor with Disputed Rehabilitation Claims elects the Early Lump-Sum Payment, the
Trustee makes the distribution of 3.2.1. above only after all the rehabilitation claims of such
Creditor with Disputed Rehabilitation Claims are determined. On the other hand, if a
Creditor with Disputed Rehabilitation Claims elects the Final Payment (including the
Intermediate Payments) (including a case where it is deemed to have made such election), the
Trustee will make the distribution of 3.2.2. above after all the rehabilitation claims of such
Creditor with Disputed Rehabilitation Claims are determined. For both the Early Lump-Sum
Payment and the Intermediate Payments, see (2) above in regards to their respective
distribution dates.
(4) If a Creditor with Disputed Rehabilitation Claims possesses BTC/BCH Claims (regardless of
whether allowed or disputed; hereinafter the same in this paragraph), the Trustee requests such
Creditor with Disputed Rehabilitation Claims to elect, by the Cryptocurrency Reference
Date 36, in regards to payments that such BTC/BCH Claims can receive if all the rehabilitation
claims held by such Creditor with Disputed Rehabilitation Claims are determined, whether to
request BTC/BCH Payment or cash only payment. In other words, even before the point in
time that all the rehabilitation claims of a Creditor with Disputed Rehabilitation Claims are
determined, such Creditor with Disputed Rehabilitation Claims will be requested to elect by
the Cryptocurrency Reference Date whether to choose BTC/BCH Payment or cash only
payment.
If a Creditor with Disputed Rehabilitation Claims requests cash only payment, the Trustee
makes cash payment pursuant to 4.2.4. above, after all the rehabilitation claims of such
Creditor with Disputed Rehabilitation Claims are determined.
If a Creditor with Disputed Rehabilitation Claims requests BTC/BCH Payment, such
Creditor must, by the Cryptocurrency Reference Date, complete user account registration at
any one of the Designated Exchanges and reach agreement with the relevant Designated
Exchange to the effect that it will act as such person’s agent for receipt of BTC/BCH Payment.
The Trustee makes payment in accordance with 4.2.1. through 4.2.3. above, after all the
rehabilitation claims of such Creditor with Disputed Rehabilitation Claims are determined.

End

36
See 4.2.1.(2) above.

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