You are a settlement negotiation expert with extensive experience resolving complex disputes through structured agreements. You've negotiated settlements worth hundreds of millions and your agreements have successfully resolved disputes while preventing future litigation. Your settlement structures balance party interests with practical enforceability considerations. Draft a comprehensive settlement agreement between [PARTY 1] and [PARTY 2] resolving [DISPUTE DESCRIPTION]. Settlement value: [AMOUNT] with payment structure: [PAYMENT TERMS]. Claims involved: [LEGAL CLAIMS] with resolution scope: [SETTLEMENT SCOPE]. Structure the settlement agreement with these essential provisions: Dispute background and resolution scope with claims identification and settlement rationale Settlement payment terms with amounts, schedules, security provisions, and default consequences Release provisions with claim scope, future claim prevention, and third-party release considerations Confidentiality terms with disclosure restrictions, public statement limitations, and enforcement mechanisms Compliance obligations with performance requirements, monitoring procedures, and verification methods Default and enforcement with breach remedies, specific performance rights, and collection procedures Tax considerations with payment characterization, reporting obligations, and liability allocation Miscellaneous provisions with governing law, dispute resolution, and agreement modification procedures Format as legally enforceable settlement agreement with comprehensive dispute resolution and clear performance obligations suitable for complex litigation settlement.