definiens: shall mean the expenses incurred by [COMPANY] or on its behalf that are attributable to [COMPANY] 's independent research or develop ment of a [COMPANY] Program, calculated [ * ] ( i.e., including [ * ] specifically attributable thereto ) . Without limiting the generality of the foregoing, shall mean amounts [ * ] involved in the research or development of a [COMPANY] Program, a nd all [ * ] costs ( calculated on an FTE basis at the rate of US [ * ] per FTE, subject to the penultimate sentence of this Section 1.80 ) incurred by [COMPANY] in connection with its independent research or development activities associated with a [COMPANY] Program . Sy rrx Program Expenses shall include, but are not limited to, the following costs incurred for the research or development of a [COMPANY] Program : ( a ) the costs of [ * ] from a [COMPANY] Program or a [COMPANY] Product, including its [ * ] and [ * ], to achieve product develop ment goals regarding efficacy, safety, dosing and route of administration ; ( b ) the cost of studies [ * ] of a prospective [COMPANY] Product conducted [ * ] necessary or desirable for the purpose of obtaining Regulatory Approval of a [COMPANY] Product ; ( c ) costs ( and related fees ) for [ * ] for the purpose of submission to a governmental authority to obtain Regulatory Approval of a [COMPANY] Product ; and ( d ) [ * ] for a [COMPANY] Product in [ * ] for purposes of conducting preclinical and clinical studies necessary to obtain and/or maintain Regulatory Approval of [COMPANY] Products . FTE rates shall be adjusted annually to reflect any increases in the Consumer Price Index for the U.S. In calculating [COMPANY] Program Expenses, [COMPANY] shall use standard activity -based project accounting methods, and such calculation shall be made using U.S. generally accepted accounting principles, consistently applied