Hearing Date: August 20, 2013 at 11:00 a.m. (Eastern Time) Objection Deadline: August 9, 2013 at 4:00 p.m.

(Eastern Time)

Name Address 1 Address 2 Telephone: Fax: Eastman Kodak Shareholder

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: EASTMAN KODAK COMPANY, et al., Debtors. ) ) ) ) ) )

Bankruptcy Case No. 12-10202

SHAREHOLDER OBJECTION TO DEBTORS FIRST AMENDED JOINT CHAPTER 11 PLAN OF REORGANIZATION Dear Honorable Judge Allan Gropper, I respectfully request the court to deny confirmation of Debtors First Amended Joint Chapter 11 Plan of Reorganization (the Plan), because it is based on an inaccurate and unacceptable valuation analysis prepared by Lazard Frres & Co. LLC (Lazard), the financial adviser of Debtors, and inaccurate and unacceptable liquidation value analysis prepared by AP Services LLC (APS). 1. Lazards Valuation Analysis is not admissible by the court as evidence for the estimate of $498M reorganization value of New Kodak, because Lazard did not provide a proper valuation analysis in the Plan, except for an estimated range of $800 to $1,250 million for the Enterprise Value of Reorganized Kodak, and based on this estimate a range of $208 to $658 million total equity value of Reorganized Kodak. The court should disregard the inadequate and inaccurate valuation analysis provided by Lazard, and order an independent valuation of New Kodak by a qualified and competent security valuation expert before considering confirmation of the Plan. (a) On Page 224 of the Plan (Docket 4175), Lazard states: Based on the projections and solely for purposes of the Plan, Lazard estimates that the Enterprise Value of Reorganized Kodak falls within a range of $800 to $1,250 million How did Lazard arrive at this estimate? Where is the financial analysis verifying this estimate? What valuation methods did Lazard use? What were the assumptions used by these methods? Lazard did not provide any information in the Plan about these important questions. Without this information, Lazards estimate of the Enterprise Value of New Kodak is unreliable and unacceptable. 1

(b) On Page 225 of the Plan, Lazard states: Lazard estimates that the total equity value of Reorganized Kodak falls within a range of $208 to $658 million, equating to $4.98 to $15.77 per share of the New Common Stock. Lazards estimate of the equity value of New Kodak is unacceptable, because it is based on the unacceptable estimate of the Enterprise Value of New Kodak. In addition, Lazards average estimate of New Kodaks equity value at $378M is less than the $498M book equity value as shown in the 09/30/2013 balance sheet of New Kodak. The book equity value grossly underestimates the fair market value of New Kodak as Kodaks assets are almost fully depreciated and do not include the substantial inflation in asset prices since the assets were purchased, while Kodaks liabilities are accounted at market values. Also, considering New Kodaks 35% EBITDA growth during the 2014-2017 projection period, as shown in the Income Sheet Projections of the Plan, Lazards estimate of NewKodaks equity value is inaccurate and should be dismissed by the court. (c) On Page 228 of the Plan, Lazard reports: In performing its Valuation Analysis for Reorganized Kodak, Lazard: (a) reviewed certain historical financial information of EKC and its subsidiaries for recent years; (b) reviewed certain internal financial and operating data of EKC and its subsidiaries, which data was prepared and provided to Lazard by the management of the Debtors and which relates to Reorganized Kodaks business and its prospects; (c) met with EKCs senior management team to discuss Reorganized Kodaks proposed operations and future prospects; (d) reviewed certain publicly available financial data for, and considered the market value of, public companies that Lazard deemed generally relevant in evaluating the operating business of Reorganized Kodak; (e) considered certain economic and industry information relevant to the operating business; and (f) conducted such other studies, analyses, inquiries and investigations as it deemed appropriate. Lazard assumed and relied on the accuracy and completeness of all financial and other information furnished to it by management of the Debtors as well as publicly available information Which public companies that Lazard deemed generally relevant in evaluating the operating business of Reorganized Kodak were analyzed by Lazard? Where are the comparative valuation analyses undertaken by Lazard. Which certain economic and industry information relevant to the operating business of New Kodak did Lazard consider? Where is this analysis in the Plan? What other studies, analyses, inquiries and investigations did Lazard conduct? They are not reported in the Plan. (d) On Page 229 of the Plan, Lazard adds: Lazards Valuation Analysis reflects the application of standard valuation techniques and does not purport to reflect or constitute appraisals, liquidation values or estimates of the actual market value that may be realized through the sale of any securities to be issued pursuant to the Plan, which may be significantly different than the amounts set forth herein. Which standard valuation techniques did Lazard use? And where are these valuation analyses using these techniques? Lazard did not provide any valuation analysis by any standard valuation technique in the Plan. 2

2. APSs Liquidation Analysis is not admissible as evidence for the Chapter 7 liquidation value of Kodak for the Best Interest Test, because it is inaccurate and grossly underestimates the liquidation recovery value of Kodaks assets, and it was not compiled or examined by any independent accountants. (a) On Page 252 of the Plan (Docket 4175), Debtors state: . Unless otherwise stated, the book values used in the Liquidation Analysis are the unaudited net book values of the Debtors as of December 31, 2012.62 These book values are assumed to be representative of the Debtors assets and liabilities as of the Liquidation Date. Debtors book values of assets grossly underestimate the fair market values and should not be used for the liquidation analysis, as the tangible long-term assets of Kodak have been almost fully depreciated and do not include the substantial inflation in asset prices since Kodak purchased them. The liquidation analysis already assumes up to 98% discount to the asset values during a Chapter 7 liquidation. Therefore, a 90% depreciated asset with a 98% discount assumption would result in a 0.2% recovery amount. APSs Liquidation Analysis is inaccurate and it should use the fair market values instead of the book values as the base asset value before the liquidation discount is applied to it. (b) On Page 259 of the Plan, in Exhibit-1, APS estimates: Intangible assets are comprised primarily of the Kodak brand and patents. The liquidation analysis of certain tangible and intangible assets report prepared by Ernst & Young LLP includes values for intangible assets of $174 million to $243 million The $174M-$243M range for the liquidation recovery value of the Kodak brand and its patents is grossly underestimated. Kodak has 7000 active patents , 2100 pending patents and a valuable brand name. Nortel sold 6000 patents in July, 2011 for $4.5B during its liquidation. (c) On Page 259 of the Plan, in Exhibit-1, APS estimates: Property, Plant and Equipment Book value: $459.172M; Estimated Recovery Rate: 9.9%; Estimated Recovery Amount: $45.428M $45.4M estimated recovery amount is evidently inaccurate, because it uses the book value of these assets, instead of the fair market values before the recovery rates are applied to this value. For example, the 177 acre Harrow land asset in London city center has a book value of less than $15M (2012 10-K report shows $41M book value for Kodaks total land assets). APS liquidity analysis values Harrow land asset at $1.5M recovery value. On the other hand, Harrow land asset can easily be liquidated at $50M or more, a 3400%+ of the estimated recovery amount. (d) On Page 259 of the Plan, in Exhibit-1, APS estimates: Intercompany Receivables Book value: $1,918M; Estimated Recovery Rate: 3.2%; Estimated Recovery Amount: $62.328M 3

APS assumes a 3.2% recovery rate for Intercompany Receivables, while a 67.5% recovery rate is assumed for Trade Receivables. Although, it is understood that Debtor receivables would not be available for distribution to unsecured creditors, APS provides no details on what portion of Intercompany Receivables are from Debtor entities and what portion from non-Debtor entities, and what recovery rate is used for non-Debtor entity receivables and the justification for this rate. Without, these explanations, APSs estimate cannot be accepted as a reliable and accurate estimate, and cannot be used as evidence for the Chapter 7 Liquidation Value of Kodak. (e) On Page 259 of the Plan, in Exhibit-1, APS estimates: Intercompany Investments Book value: $2,931.488M; Estimated Recovery Rate: 2.1%; Estimated Recovery Amount: $61.661M Kodak has 37 fully owned companies around the world, which are not in bankruptcy proceedings. APS estimates zero liquidation recovery amount for 25 of these companies and only $61.661M recovery amount in total for the the remaining 12. APS provides no analysis or explanation for this gross undervaluation of Kodaks international assets. Without a detailed liquidation analysis of intercompany investments, APSs estimate is considered unreliable and cannot be accepted as evidence.

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