definiens: shall mean, on a COVID Product - by - COVID Product and country- by - country basis, the ﬁrst sale of a COVID Productby or on behalf of [COMPANY] or its Aﬃliates or Sublicensees, or by [COMPANY] or its Aﬃliates or Sublicensees, such as but not limited to, sales to a ThirdParty wholesaler, pharmacy, outpatient clinic, inpatient clinic, hospital, dispensing physician or government agency in a given country afternecessary Regulatory Approval has been granted with respect to such COVID Product in such country, provided, however, that in the event of asale of a COVID Product prior to Regulatory Approval which is substantially comparable to a commercial sale eﬀected only after RegulatoryApproval is obtained, then the ﬁrst sale in any such arrangement shall also constitute a First Commercial Sale . For the avoidance of doubt,, and shall not be construed as a First Commercial Sale if the aggregate, annual Net Sales for all such programs are less than EUR [ * * * * * ] . For avoidance of doubt, any sale of a COVID Product by [COMPANY] to an Aﬃliate orSublicensee or subcontractor is not a First Commercial Sale