SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND THE CAVALIERS OPERATING COMPANY, LLC

III. JURISDICTION

4. Patrons with Disabilities are individuals with a disability as defined in 42 U.S.C. § 12102(2) and 28 C.F.R. § 36.104.

5. Quicken Loans Arena is a place of public accommodation within the meaning of 42 U.S.C. § 12181 and 28 C.F.R. § 36.104 because its operations affect commerce, and because it is a place of exhibition or entertainment.  The Cavs are a public accommodation as defined in 42 U.S.C. § 12181 and 28 C.F.R. § 36.104 because they operate a place of public accommodation.