(11) COMMITMENTS AND CONTINGENCIES Development, Celebrity, League and Content Licenses: Payments and Commitments The products we produce in our studios are designed and created by our employee designers, artists, software programmers and by non-employee software developers (independent artists or third-party developers). We typically advance development funds to the independent artists and third-party developers during development of our games, usually in installment payments made upon the completion of specified development milestones. Contractually, these payments are generally considered advances against subsequent royalties on the sales of the products. These terms are set forth in written agreements entered into with the independent artists and third-party developers. In addition, we have certain celebrity, league and content license contracts that contain minimum guarantee payments and marketing commitments that may not be dependent on any deliverables. Celebrities and organizations with whom we have contracts include, but are not limited to: FIFA (Federation Internationale de Football Association), FIFPRO Foundation, FAPL (Football Association Premier League Limited), DFL Deutsche Fuball Liga E.V. (German Soccer League), and Liga Nacional De Futbol Profesional (professional soccer); National Basketball Association and National Basketball Players Association (professional basketball); National Hockey League and NHL Players Association (professional hockey); National Football League Properties and PLAYERS Inc. (professional football); William Morris Endeavor Entertainment LLC (professional mixed martial arts); ESPN (content in EA SPORTS games); Disney Interactive (Star Wars); and Fox Digital Entertainment, Inc. (The Simpsons). These developer and content license commitments represent the sum of (1) the cash payments due under non-royalty-bearing licenses and services agreements and (2) the minimum guaranteed payments and advances against royalties due under royalty-bearing licenses and services agreements, the majority of which are conditional upon performance by the counterparty. These minimum guarantee payments and any related marketing commitments are included in the table below. The following table summarizes our minimum contractual obligations as of September 30, 2020 (in millions): Fiscal Years Ending March 31, 2021 (Remaining Total six mos.) 2022 2023 2024 2025 2026 Thereafter Unrecognized commitments Developer/licensor commitments $ 1,895 $ 86 $ 340 $ 358 $ 349 $ 359 $ 271 $ 132 Marketing commitments 668 65 145 120 118 109 78 33 Senior Notes interest 112 17 20 19 19 19 18  Operating lease imputed interest 19 3 5 4 3 2 1 1 Operating leases not yet commenced (a) 180   4 13 14 14 135 Other purchase obligations 130 31 65 21 5 4 4  Total unrecognized commitments 3,004 202 575 526 507 507 386 301 Recognized commitments Senior Notes principal and interest 1,003 603     400  Operating leases 243 44 70 38 32 25 18 16 Transition Tax and other taxes 66 22 24 3 4 6 7  Licensing commitments 39 12 27      Total recognized commitments 1,351 681 121 41 36 31 425 16 Total Commitments $ 4,355 $ 883 $ 696 $ 567 $ 543 $ 538 $ 811 $ 317 (a) As of September 30, 2020, we have entered into three office leases that have not yet commenced with aggregate future lease payments of approximately $180 million. These office leases are expected to commence in fiscal year 2021 and 2023, and will have lease terms ranging from 7 to 15 years. The unrecognized amounts represented in the table above reflect our minimum cash obligations for the respective fiscal years, but do not necessarily represent the periods in which they will be recognized and expensed in our Condensed Consolidated Financial Statements. In addition, the amounts in the table above are presented based on the dates the amounts are contractually due as of September 30, 2020; however, certain payment obligations may be accelerated depending on the performance of our operating results. In addition to what is included in the table above, as of September 30, 2020, we had a liability for unrecognized tax benefits and an accrual for the payment of related interest totaling $279 million, of which we are unable to make a reasonably reliable estimate of when cash settlement with a taxing authority will occur. Legal Proceedings The Netherlands Gambling Authority (NGA) has asserted that the randomized selection of virtual items in the FIFA Ultimate Team mode of our FIFA franchise contravenes the Dutch Betting and Gaming Act. On October 15, 2020, the District Court of the Hague affirmed the NGAs decision. We intend to appeal the District Courts order, and request a suspension of the NGAs decision pending that appeal. We do not believe that the operational or financial consequences from these proceedings will have a material adverse effect on our consolidated financial statements. We do not believe that our products and services violate applicable gambling laws. We are also subject to claims and litigation arising in the ordinary course of business. We do not believe that any liability from any reasonably foreseeable disposition of such claims and litigation, individually or in the aggregate, would have a material adverse effect on our Condensed Consolidated Financial Statements.