The Film-Rx System...
"The Prescription for Entertainment Success!"
Copyright 2005. By Film-Rx Partners. All Rights Reserved.
PHASE 1
Future Impact Leveraged Marketing (FILM)
The Film-Rx "team" has created a highly effective, proprietary process for
exposing and exploiting key marketing elements ("impactors") contained in
every Intellectual Property (IP). By identifying and analyzing these key
impactors, we can determine the commercial viability of any script, book or
story.
Producers! Ask about our Free preliminary evaluation for your project!
The information and marketing opportunities revealed by this process
empowers and enables producers to establish a primary point of engagement
for advanced development of their marketing base. The information is collated
and compiled into a Script Development Profile (SDP). Drawn from an analytical
"grid" that cross-references over 200 variables, compiled from broad-based
consumer interest data over the past three decades, this profile will expose a
clear picture of the potential market for any film, book, play or other Intellectual
property.
Our market specific, F.I.L.M.* research has been more than 15 years in
development. It objectively evaluates market bound product from consumer
extracted criteria. These are used to leverage the greatest development,
marketing and merchandising opportunities for any project, potentially
providing a revenue boost with significant 'pre-release' income.
Vertically Integrated Marketing and Merchandising (VIMM)
Subsequent to the completion of the profile, a comprehensive developmental
marketing plan is presented for producers to review for possible
implementation. From information generated for the Profile, marketing and
merchandising 'programs' and surveys are designed.
Based on the interests and concerns (both creative and commercial) of the
producers, these programs and surveys present unique opportunities for
public participation in the process of development and production. Film-Rx will
also manage this new relationship that is intended to generate major
PRE-RELEASE CASH FLOW and project specific MARKETING INFORMATION
for the Producer.
NOTE: While the profile may suggest a vision of the most viable commercial
development of the project from a consumer standpoint, it is in no way intended
to control, dominate or manipulate the creative process.
Our surveys and programs are integral to supporting the creator's and
producer's intentions and entirely subject to their approval at every step along
the way to success. Film-Rx's purpose is to build the market and enhance each
project's sources of revenue and information vital to 'narrow casting' and
'highly leveraged platform' distribution, marketing and merchandising.
The marketing information and projections will also provide significant leverage
for negotiating and securing a more cost effective PRINTS & ADVERTISING
(P&A) CAMPAIGN and a STRONGER NEGOTIATING POSITION FOR ANCILLARY
MARKET REVENUES WITH FOREIGN DISTRIBUTORS.
PHASE 2:
Interactive Multimedia Programming (IMP)
THE CABLE/Internet PROGRAMS:
Once the Profile and developmental plan have been completed and the
producers have fully committed to the Film-Rx System, they are incorporated in
the body of one of three possible formats (i.e. "Hollywood Today", "In the
House", "From the Balcony") each a 30-60 minute "infotainment", CATV/Internet
program with a true interactive multimedia interface.
A segment or series of segments is formatted and a "leader" segment taken
from the actual content of the film itself is produced (i.e. "Blair Witch Project") to
promote open participation. Like all of the critical leveraging elements, this
"leader" is impactor identified and driven.
The producers use the available impactor information to select the most
appealing "leader" to promote. It may be a test scene for casting, critical plot
point or sequence in the script (dramatic, suspenseful, provocative), a crew
test, or a director test (perhaps it is a scene with one of the 'name' principals
who have already contracted for the film).
NOTE: This scene must be produced with 'feature quality' and representative of
the final product. It is the first "hook" to initiate audience engagement and
advance public interest in the project. It will offer the audience a special
opportunity to participate in some unique manner.
These ("leader") may be presented in an 'Ebert & Roeper' type program. Our
duo is a male/female, good guy/bad girl 'team'(i.e.Michael J. Fox and Courtney
Love ). They will present, argue and moderate a discussion of the premise, plot,
style and quality along with many developmental possibilities for the project.
Ultimately, they will offer participation in a "Film Club" opportunity that will
ensure that their voices will be heard and can make a difference in how the
project proceeds.
They will:
* preview several (2-3) film concepts (from the 'Film Club' roster).
* each will voice their evaluation of the projects.
* then, pose a series of questions chosen by the producer from a
poll designed from profile "impactors".
* finally, provide an opportunity for the viewing audience to 'interact'
and be rewarded for their participation.
Interaction, the new open architecture
The audience will be given the chance to "interact" via an 800 telephone
number or online. In so doing, they will receive an exclusive 'limited'
opportunity related to the project, (i.e. CALL NOW and the first 50 callers in your
area will receive FREE membership to the Producers FIlm Club and be entered
in a special drawing or sweepstakes to win a role in a film, a free trip to a film
location for a week, a weekend in Hollywood, a screen test, etc.)
Initially, these direct response calls will be handled and processed by a
subcontracted service provider whose personnel are trained and managed by
Film-Rx. Later, we will process and handle all communications through our
telecommunications link at www.Film-Rx.com
Film-Rx will provide a fully interactive multimedia interface that will take
incoming calls, offer information, redirect operator assisted calls and Internet
inquiries and place orders. This will further expedite the collection of revenue
and project specific information. All of the confidential information will assist in
reducing the cost and time of processing and delivery of goods and services.
Each film's exposure through Film-Rx programming will cover a NINETY (90)
DAY pre-production, production period as follows:
Month One (30 days): Preview. During this month the audience will be prepared
for forthcoming opportunities.
Month Two (60 days): Feature. During this month films previewed the month
before will now be featured.
Month Three (90 days): Update. During this month updates will be given on
films featured the month before. It is during this segment that the audience
begins to see the results of their contributions.
Members participating in specific projects will continue to be updated through
the ensuing production period (30-90 days) as to their projects progress via
Film-Rx online services at home or in a Film-Rx Kiosk at a local theater.
THE CALL: Interactive
When viewers DIAL 1- 800 or go online
They will be provided with three options:
1. They can log on to the website at whatever URL is used for their project.
2. They can stay on the line and become eligible for:
a. a free membership in the PFC
b. a Sweepstakes entry for a chance to participate in a PFC film project
(on camera or behind the scenes)
c. a Prize (classic video, PFC tee-shirt, etc.)
3. They can enroll in PFC and,
a. get an immediate bonus (classic video, PFC tee-shirt, etc.)
b. begin to take advantage of all membership opportunities (contests,
sweepstakes, trips, etc).
In any case, through caller I.D., all three choices will produce a 'hot lead' that
may be pursued (at a later date) through follow-up call (to "hang-ups") or direct
mail.
There will be three such opportunities for viewers to 'interact' presented in each
half-hour program.
The other two segments of "Hollywood Today" will involve:
* Producer panel/live audience 'interactive' in a studio with a commentator
and "live" call-in line.
Samples of project logo, poster artwork and music will be presented as
opportunities to expand audience inclusion in their selection are developed as
part of VIMM.
* "Woman in the street"/producer/celebrity (talent) 'interactive' interview
with our 'roving reporter' channeling questions about AFPA and projects.
Promotes additional membership participation opportunities, (i.e. travel,
merchandise, etc.)
These will be 'Live' (taped) segments. The questions asked will be mixed,
'spontaneous' and 'skewed'. All of the questions asked will be matched to
Film-Rx project producers' interests and concerns. They will be "framed" to
conform to the program format and subject to member producer approval.
From time to time we will go outside the "Hollywood Today" standard format
and involve "live", "remote", "up to the minute" coverage of production from
behind the scenes. These will be PFC 'exclusives' that will add "sizzle" to the
show.
All of the above offer opportunities related to membership (games, contests,
freebies, etc.). They will also provide 'unsolicited' public testimonial to support
PFC and project enrollment.
MERCHANDISING
Film-Rx will also work with the production designers from the earliest stages of
pre-production, to identify and select specific merchandise to be offered for
sale to membership. They will be video catalogued (also hard copied in a
membership kit) as 'limited editions', available exclusively through Film-Rx and
the Producers Film Club.
This video catalogue will also present "leader" clips and "freeze frames" from
the film featuring the merchandise. This 'shoppers' segment will be moderated
by our 'live' segment host and will have an 800 call number and Internet website
for ordering from the hard copy, on-air and online catalogues.
The DVDs, CDs and tapes will be one half-hour (a full 30 minutes) in length.
They will be offered to our paid CATV carriers and Internet streamers as quality
programming. They will be included in every CLUB membership kit FREE OF
CHARGE as well. Members will be able to use their membership IDs to
download and updates at will.
(Film-Rx provides this supplemental 'shopper's programming' to Cable
companies for 'spot' airing in selected markets. We will negotiate special rates
based on frequency and availability of their 'downtime' slots.)
There will be a complete line of general merchandise items that are related to
the PFC and the licensed film. (Hats, tee-shirts, jackets, etc.) There will also be
'limited editions' of items that appear in the films themselves. These may be
anything from earrings to automobiles.
Film-Rx, working with the designers and producers, will select a 'feature line' to
be highlighted in programming and exhibited in online video, cable and hard
copy catalogues. The basic idea is to, "sell the props", all of which will be made
available exclusively to the 'club' membership first. The merchandise will be
'limited edition' by special arrangement between producers and manufacturers.
Deepening Involvemant
The more involved the audience/member is with the Producers Film Club, the
more 'exclusive' the merchandise and other opportunities become.
For instance,
* General Members of the association have access to general merchandise
(Hats, tees, jackets, etc.) and some project specific merchandise and services.
* Member Producer Associates involved in a specific film project, have
access to that films 'limited editions' and select travel opportunities that put
them at the heart of the action.
The principle piece of merchandise is...
THE "MEMBERSHIP KIT"
The Membersip Kit will include:
* Rules, regulations and restrictions for participation as a member (also,
money back guarantee).
* Membership card (PIN) that entitles members access to all opportunities.
* Fifteen (15) minute video ("leader", catalogue, etc.)
* Film-Rx Magazine (feature articles, catalogue, survey, newsletter)
* Discount coupon book (i.e. Entertainment 2005 - $2000 value) for
amusements and entertainment savings at nationally franchised theaters,
restaurants, parks, etc.
In addition to the above tangible goods and services, there are also, secondary
benefits for producers. These include
* increased leverage in P&A negotiations
* more attractive product placement potential
* "hard number" support to obtain additional funding (should that be
required).
PRODUCER QUALIFICATIONS
The requirements for Producer participation are:
* The Production must be completely funded (below the line). There must
be sufficient cash to cover the Film-Rx deposit requirements.
* There is a first draft script (complete) made immediately available to
Film-Rx.
* There must be certain 'above the line' attachments or financing
agreements in place (producer, writer, director, talent), lines of credit, bank
accounts, studio or distributor funding letters in place, that allow the use of
their name and image in developing a plan.
(OPTIONAL) In most cases distribution guarantees and P&A are not required,
but they are a plus, provided the producers have retained their right to
managing their own marketing and merchandising.
PROGRAM COST
The cost of Phase 1 (SDP) is One Percent (1%) of the projected 'below the line'
budget of the project development budget (minimum $10k). A Ten Percent
(10%) deposit (min. $1,000.00) is required to initiate this phase. It will take thirty
(30) days to prepare a complete Script Development Profile. The balance of
payment is due upon submission of the SDP and VIMM Plan.
The cost of Phase 2 is equal to Five Percent (5%) of the Total Adjusted Budget
(TAB) of the entire project. The TAB includes the 'Above' and 'Below-the-Line'
expenses for production, once a vetted budget has been approved and the
capital committed.
All costs for the Phase 2 operations would come from these fees. They may
include the total cost of programming for Cable, the Internet and marketing &
merchandising. (Any additional costs are TBN.)
[For example, a film with a TAB of Five Million Dollar ($5,000,000)
have a Phase 2 cost of $250,000.00].
A Ten Percent (10%) deposit is required prior to initiating Phase 2 operations
(not less than $10,000.00).
FILM-RX RETURN ON INVESTMENT (ROI)
Film-Rx receives for its investment and services, a percentage (TBN) of all
'prerelease' revenue received from the programs and processes initiated and
managed by Film-Rx, as well as from the subsequent sale of the programming
and bulk merchandising rights.
Film-Rx PRODUCER'S WARRANTY
Film-Rx warrants to Producers that:
Within thirty (30) days of contract closure and payment of deposit, they will
submit a complete Script Development Profile (SDP) that will offer a clearly
visible way for producers to significantly reduce their cost of development and
production, and expose the optimum marketing and merchandising
opportunities for their project.
Furthermore, Film-Rx will provide a viable and affordable developmental plan,
designed to generate significant 'pre-release' revenue from the marketing and
merchandising of their project during that same period (30 days) or we will
return all fees paid by the Producer for Film-Rx services, less hard costs (not to
exceed 10% of total fees paid).
Future Impact Leveraged Marketing (FILM)
The Film-Rx "team" has created a highly effective, proprietary process for
exposing and exploiting key marketing elements ("impactors") contained in
every Intellectual Property (IP). By identifying and analyzing these key
impactors, we can determine the commercial viability of any script, book or
story.
Producers! Ask about our Free preliminary evaluation for your project!
The information and marketing opportunities revealed by this process
empowers and enables producers to establish a primary point of engagement
for advanced development of their marketing base. The information is collated
and compiled into a Script Development Profile (SDP). Drawn from an analytical
"grid" that cross-references over 200 variables, compiled from broad-based
consumer interest data over the past three decades, this profile will expose a
clear picture of the potential market for any film, book, play or other Intellectual
property.
Our market specific, F.I.L.M.* research has been more than 15 years in
development. It objectively evaluates market bound product from consumer
extracted criteria. These are used to leverage the greatest development,
marketing and merchandising opportunities for any project, potentially
providing a revenue boost with significant 'pre-release' income.
Vertically Integrated Marketing and Merchandising (VIMM)
Subsequent to the completion of the profile, a comprehensive developmental
marketing plan is presented for producers to review for possible
implementation. From information generated for the Profile, marketing and
merchandising 'programs' and surveys are designed.
Based on the interests and concerns (both creative and commercial) of the
producers, these programs and surveys present unique opportunities for
public participation in the process of development and production. Film-Rx will
also manage this new relationship that is intended to generate major
PRE-RELEASE CASH FLOW and project specific MARKETING INFORMATION
for the Producer.
NOTE: While the profile may suggest a vision of the most viable commercial
development of the project from a consumer standpoint, it is in no way intended
to control, dominate or manipulate the creative process.
Our surveys and programs are integral to supporting the creator's and
producer's intentions and entirely subject to their approval at every step along
the way to success. Film-Rx's purpose is to build the market and enhance each
project's sources of revenue and information vital to 'narrow casting' and
'highly leveraged platform' distribution, marketing and merchandising.
The marketing information and projections will also provide significant leverage
for negotiating and securing a more cost effective PRINTS & ADVERTISING
(P&A) CAMPAIGN and a STRONGER NEGOTIATING POSITION FOR ANCILLARY
MARKET REVENUES WITH FOREIGN DISTRIBUTORS.
PHASE 2:
Interactive Multimedia Programming (IMP)
THE CABLE/Internet PROGRAMS:
Once the Profile and developmental plan have been completed and the
producers have fully committed to the Film-Rx System, they are incorporated in
the body of one of three possible formats (i.e. "Hollywood Today", "In the
House", "From the Balcony") each a 30-60 minute "infotainment", CATV/Internet
program with a true interactive multimedia interface.
A segment or series of segments is formatted and a "leader" segment taken
from the actual content of the film itself is produced (i.e. "Blair Witch Project") to
promote open participation. Like all of the critical leveraging elements, this
"leader" is impactor identified and driven.
The producers use the available impactor information to select the most
appealing "leader" to promote. It may be a test scene for casting, critical plot
point or sequence in the script (dramatic, suspenseful, provocative), a crew
test, or a director test (perhaps it is a scene with one of the 'name' principals
who have already contracted for the film).
NOTE: This scene must be produced with 'feature quality' and representative of
the final product. It is the first "hook" to initiate audience engagement and
advance public interest in the project. It will offer the audience a special
opportunity to participate in some unique manner.
These ("leader") may be presented in an 'Ebert & Roeper' type program. Our
duo is a male/female, good guy/bad girl 'team'(i.e.Michael J. Fox and Courtney
Love ). They will present, argue and moderate a discussion of the premise, plot,
style and quality along with many developmental possibilities for the project.
Ultimately, they will offer participation in a "Film Club" opportunity that will
ensure that their voices will be heard and can make a difference in how the
project proceeds.
They will:
* preview several (2-3) film concepts (from the 'Film Club' roster).
* each will voice their evaluation of the projects.
* then, pose a series of questions chosen by the producer from a
poll designed from profile "impactors".
* finally, provide an opportunity for the viewing audience to 'interact'
and be rewarded for their participation.
Interaction, the new open architecture
The audience will be given the chance to "interact" via an 800 telephone
number or online. In so doing, they will receive an exclusive 'limited'
opportunity related to the project, (i.e. CALL NOW and the first 50 callers in your
area will receive FREE membership to the Producers FIlm Club and be entered
in a special drawing or sweepstakes to win a role in a film, a free trip to a film
location for a week, a weekend in Hollywood, a screen test, etc.)
Initially, these direct response calls will be handled and processed by a
subcontracted service provider whose personnel are trained and managed by
Film-Rx. Later, we will process and handle all communications through our
telecommunications link at www.Film-Rx.com
Film-Rx will provide a fully interactive multimedia interface that will take
incoming calls, offer information, redirect operator assisted calls and Internet
inquiries and place orders. This will further expedite the collection of revenue
and project specific information. All of the confidential information will assist in
reducing the cost and time of processing and delivery of goods and services.
Each film's exposure through Film-Rx programming will cover a NINETY (90)
DAY pre-production, production period as follows:
Month One (30 days): Preview. During this month the audience will be prepared
for forthcoming opportunities.
Month Two (60 days): Feature. During this month films previewed the month
before will now be featured.
Month Three (90 days): Update. During this month updates will be given on
films featured the month before. It is during this segment that the audience
begins to see the results of their contributions.
Members participating in specific projects will continue to be updated through
the ensuing production period (30-90 days) as to their projects progress via
Film-Rx online services at home or in a Film-Rx Kiosk at a local theater.
THE CALL: Interactive
When viewers DIAL 1- 800 or go online
They will be provided with three options:
1. They can log on to the website at whatever URL is used for their project.
2. They can stay on the line and become eligible for:
a. a free membership in the PFC
b. a Sweepstakes entry for a chance to participate in a PFC film project
(on camera or behind the scenes)
c. a Prize (classic video, PFC tee-shirt, etc.)
3. They can enroll in PFC and,
a. get an immediate bonus (classic video, PFC tee-shirt, etc.)
b. begin to take advantage of all membership opportunities (contests,
sweepstakes, trips, etc).
In any case, through caller I.D., all three choices will produce a 'hot lead' that
may be pursued (at a later date) through follow-up call (to "hang-ups") or direct
mail.
There will be three such opportunities for viewers to 'interact' presented in each
half-hour program.
The other two segments of "Hollywood Today" will involve:
* Producer panel/live audience 'interactive' in a studio with a commentator
and "live" call-in line.
Samples of project logo, poster artwork and music will be presented as
opportunities to expand audience inclusion in their selection are developed as
part of VIMM.
* "Woman in the street"/producer/celebrity (talent) 'interactive' interview
with our 'roving reporter' channeling questions about AFPA and projects.
Promotes additional membership participation opportunities, (i.e. travel,
merchandise, etc.)
These will be 'Live' (taped) segments. The questions asked will be mixed,
'spontaneous' and 'skewed'. All of the questions asked will be matched to
Film-Rx project producers' interests and concerns. They will be "framed" to
conform to the program format and subject to member producer approval.
From time to time we will go outside the "Hollywood Today" standard format
and involve "live", "remote", "up to the minute" coverage of production from
behind the scenes. These will be PFC 'exclusives' that will add "sizzle" to the
show.
All of the above offer opportunities related to membership (games, contests,
freebies, etc.). They will also provide 'unsolicited' public testimonial to support
PFC and project enrollment.
MERCHANDISING
Film-Rx will also work with the production designers from the earliest stages of
pre-production, to identify and select specific merchandise to be offered for
sale to membership. They will be video catalogued (also hard copied in a
membership kit) as 'limited editions', available exclusively through Film-Rx and
the Producers Film Club.
This video catalogue will also present "leader" clips and "freeze frames" from
the film featuring the merchandise. This 'shoppers' segment will be moderated
by our 'live' segment host and will have an 800 call number and Internet website
for ordering from the hard copy, on-air and online catalogues.
The DVDs, CDs and tapes will be one half-hour (a full 30 minutes) in length.
They will be offered to our paid CATV carriers and Internet streamers as quality
programming. They will be included in every CLUB membership kit FREE OF
CHARGE as well. Members will be able to use their membership IDs to
download and updates at will.
(Film-Rx provides this supplemental 'shopper's programming' to Cable
companies for 'spot' airing in selected markets. We will negotiate special rates
based on frequency and availability of their 'downtime' slots.)
There will be a complete line of general merchandise items that are related to
the PFC and the licensed film. (Hats, tee-shirts, jackets, etc.) There will also be
'limited editions' of items that appear in the films themselves. These may be
anything from earrings to automobiles.
Film-Rx, working with the designers and producers, will select a 'feature line' to
be highlighted in programming and exhibited in online video, cable and hard
copy catalogues. The basic idea is to, "sell the props", all of which will be made
available exclusively to the 'club' membership first. The merchandise will be
'limited edition' by special arrangement between producers and manufacturers.
Deepening Involvemant
The more involved the audience/member is with the Producers Film Club, the
more 'exclusive' the merchandise and other opportunities become.
For instance,
* General Members of the association have access to general merchandise
(Hats, tees, jackets, etc.) and some project specific merchandise and services.
* Member Producer Associates involved in a specific film project, have
access to that films 'limited editions' and select travel opportunities that put
them at the heart of the action.
The principle piece of merchandise is...
THE "MEMBERSHIP KIT"
The Membersip Kit will include:
* Rules, regulations and restrictions for participation as a member (also,
money back guarantee).
* Membership card (PIN) that entitles members access to all opportunities.
* Fifteen (15) minute video ("leader", catalogue, etc.)
* Film-Rx Magazine (feature articles, catalogue, survey, newsletter)
* Discount coupon book (i.e. Entertainment 2005 - $2000 value) for
amusements and entertainment savings at nationally franchised theaters,
restaurants, parks, etc.
In addition to the above tangible goods and services, there are also, secondary
benefits for producers. These include
* increased leverage in P&A negotiations
* more attractive product placement potential
* "hard number" support to obtain additional funding (should that be
required).
PRODUCER QUALIFICATIONS
The requirements for Producer participation are:
* The Production must be completely funded (below the line). There must
be sufficient cash to cover the Film-Rx deposit requirements.
* There is a first draft script (complete) made immediately available to
Film-Rx.
* There must be certain 'above the line' attachments or financing
agreements in place (producer, writer, director, talent), lines of credit, bank
accounts, studio or distributor funding letters in place, that allow the use of
their name and image in developing a plan.
(OPTIONAL) In most cases distribution guarantees and P&A are not required,
but they are a plus, provided the producers have retained their right to
managing their own marketing and merchandising.
PROGRAM COST
The cost of Phase 1 (SDP) is One Percent (1%) of the projected 'below the line'
budget of the project development budget (minimum $10k). A Ten Percent
(10%) deposit (min. $1,000.00) is required to initiate this phase. It will take thirty
(30) days to prepare a complete Script Development Profile. The balance of
payment is due upon submission of the SDP and VIMM Plan.
The cost of Phase 2 is equal to Five Percent (5%) of the Total Adjusted Budget
(TAB) of the entire project. The TAB includes the 'Above' and 'Below-the-Line'
expenses for production, once a vetted budget has been approved and the
capital committed.
All costs for the Phase 2 operations would come from these fees. They may
include the total cost of programming for Cable, the Internet and marketing &
merchandising. (Any additional costs are TBN.)
[For example, a film with a TAB of Five Million Dollar ($5,000,000)
have a Phase 2 cost of $250,000.00].
A Ten Percent (10%) deposit is required prior to initiating Phase 2 operations
(not less than $10,000.00).
FILM-RX RETURN ON INVESTMENT (ROI)
Film-Rx receives for its investment and services, a percentage (TBN) of all
'prerelease' revenue received from the programs and processes initiated and
managed by Film-Rx, as well as from the subsequent sale of the programming
and bulk merchandising rights.
Film-Rx PRODUCER'S WARRANTY
Film-Rx warrants to Producers that:
Within thirty (30) days of contract closure and payment of deposit, they will
submit a complete Script Development Profile (SDP) that will offer a clearly
visible way for producers to significantly reduce their cost of development and
production, and expose the optimum marketing and merchandising
opportunities for their project.
Furthermore, Film-Rx will provide a viable and affordable developmental plan,
designed to generate significant 'pre-release' revenue from the marketing and
merchandising of their project during that same period (30 days) or we will
return all fees paid by the Producer for Film-Rx services, less hard costs (not to
exceed 10% of total fees paid).
