definiens: means a private equity firm, investment fund, pension fund or venture capital fund that in each casedoes not, directly or indirectly, except through a passive investment interest, operate a business other than the investment or portfoliomanagement business including any venture capital arm of a pharmaceutical or biotechnology company or group provided that such venturecapital arm of a pharmaceutical or biotechnology company or group has implemented and continues to maintain and comply with writtenprocedures to prevent disclosure to and use by those parts of the pharmaceutical or biotechnology company or group which are active in theresearch, development, manufacture or commercialization of Pharmaceutical Products of : ( a ) Collaboration Product Clinical Study Data,(b ) the GDP ( other than a high level summary of status and results ), ( c ) the Neoepitope Prediction Algorithm, ( d ) any Confidential Informationof [COMPANY], or ( e ) [COMPANY] Know - How