definiens: means thedistributions, transfers, conveyances, contributions, assignments and other transactions that are required to be accomplished, effected or consummated by [COMPANY], PDD or any of their respective Subsidiaries or Affiliates in order to separate anddivide, in a series of transactions that, to the extent possible, shall qualify for tax - free treatment under the Code, the existingbusiness of [COMPANY] so that, except as otherwise provided in this Agreement or the Ancillary Agreements, ( i ) thebusiness, assets and liabilities necessary for the continuing of the PDD Business shall be owned, directly or indirectly, byPDD, and ( ii ) the business, assets and liabilities of the [COMPANY] Group that remain after the separations and divisionsdescribed above, including, without limitation, the business, assets and liabilities necessary for the continuing operation ofthe [COMPANY] Business, are, after giving effect to the Distribution, owned, directly or indirectly, by [COMPANY]