Fifteen InvestCo SPVs, each raising up to $5,000,000, buy 99% of HoldCo SPVs that hold contract rights to about 140,000 single-user, 12-month subscriptions to the Workforce Wellness Platform, a SaaS benefits app for frontline workers developed by Refresh Software, Inc. After closing, Investors vote by majority to (1) sell the subscriptions to retail buyers for profit or (2) donate them to a public charity for a potential charitable deduction based on appraised fair market value. All of the Sponsor's prior similar programs elected to donate.