United States of America, Plaintiff, v. Cinemark USA, Inc., Defendant - Consent Order

2.4     The United States shall be prohibited from filing suit against Cinemark for alleged violations of ADA Standard 4.33.3 with respect to any of Cinemark's Existing Theaters, any of Cinemark's Modified Theaters that are modified in accordance with this Consent Order, and any of Cinemark's Designed Theaters or Future Construction Theaters that are designed and constructed in accordance with this Consent Order. In the event that there are changes in the legal requirements governing the design of wheelchair seating locations in assembly areas (including stadium-style movie theaters), whether by modification of the DOJ's regulation implementing Title III of the Americans with Disabilities Act (currently codified at 28 C.F.R. Part 36, including Appendix A, the Standards for Accessible Design), by act of Congress, or by decision of the United States Supreme Court, Cinemark shall thereafter construct any new theaters in compliance with whatever new or different design requirements are adopted, enacted, or held to be binding.  This Consent Order shall be a full, complete, and final disposition and settlement of all of the United States' and Cinemark's claims between the parties that have arisen in this case. The United States' Complaint shall be dismissed, and final judgment entered with prejudice.