Common use of Class Certification Clause in Contracts

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” (the members of which are referred to as the “Class Members”): All individuals in California who, between March 2, 2016 and November 5, 2020, (i) enrolled in an automatic renewal or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged for an automatic renewal of such subscription. Excluded from the Class are the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. Solely for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇▇▇ and ▇▇▇▇▇ will be appointed as Class Representatives. D. Subject to Court approval, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing settlement checks to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs shall timely submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees and costs and class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California who, between March 2December 16, 2016 2015 and November 5September 16, 2020, (i) enrolled in , purchased software or another product from Defendants and to whom Defendants made an automatic renewal offer or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged for an automatic renewal of such subscriptionoffer. Excluded from the Class are all employees of Defendants, all employees of Plaintiff’s counsel, and the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, the Parties stipulate to the filing of a First Amended Complaint which identifies Bitdefender S.R.L. and Avangate B.V. as Defendants and sets forth the foregoing definition of the Class. As part of the motion for preliminary approval, the Parties will request that the Court grant leave for the filing of the First Amended Complaint. C. The Parties will request that the Defendants shall be deemed to have denied all material allegations of the First Amended Complaint without the necessity of Defendants filing an answer to the First Amended Complaint. If the Settlement is not granted final approval by the Court, the Parties stipulate and agree that (a) the First Amended Complaint shall be stricken and (b) the Parties will return to the status quo ante as if no Settlement had been entered into. Moreover, if the Settlement is not granted final approval by the Court, the Parties shall be deemed to have preserved all of their rights or defenses as of the date of this Agreement, and shall not be deemed to have waived any substantive or procedural rights of any kind. D. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. E. Solely for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇▇▇ and ▇▇▇▇▇ will be appointed as Class RepresentativesRepresentative. D. F. Subject to the Parties’ right to jointly propose a different service provider, and subject to Court approval, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the mailed Summary Class NoticeNotice as described in this Agreement; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims, as described in this Agreement; preparing a declaration regarding its due diligence; mailing settlement checks to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs G. Plaintiff shall timely submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees fees, reimbursement of litigation expenses, and costs and any class representative service paymentspayment, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California who, between March 2May 17, 2016 2012 and November 5October 8, 2020, (i) 2018, were enrolled by Synapse in an automatic renewal or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged for an automatic renewal of such magazine subscription. Excluded from the Class are all employees of Synapse, all employees of plaintiffs’ counsel, and the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, the Parties stipulate to the filing of a First Amended Complaint which, among other things, sets forth the foregoing definition of the Class, adds Price, Edgemon, Davenport, Bergeron, and ▇▇▇▇▇▇▇▇ as named plaintiffs in the ▇▇▇▇ action, and adds claims for monetary relief in the ▇▇▇▇ action. Promptly upon execution of this Agreement, plaintiff ▇▇▇▇ and defendants will submit to the Court a stipulation and proposed order for the filing of the First Amended Complaint. C. Within three (3) court days of the filing of said First Amended Complaint, defendants shall file an Answer without any pleading challenges to the First Amended Complaint. However, if the Settlement is not granted final approval by the Court, the Parties stipulate and agree that (a) the First Amended Complaint shall be stricken, (b) the Answer to the First Amended Complaint shall be withdrawn, and (c) the Parties will endeavor to return the litigation as nearly as practicable to the status quo ante. D. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. E. Solely for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇, Price, Edgemon, Davenport, Bergeron, and ▇▇ and ▇▇▇▇▇▇▇ will be appointed as Class Representatives. D. F. Subject to Court approval, the Parties parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing settlement checks to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs G. After the filing of the First Amended Complaint, plaintiffs shall timely promptly submit this Agreement to the Court along with a motion for (1) preliminary approval of class action settlement, conditional certification settlement (the proposed form of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are Preliminary Approval Order is attached hereto as Exhibits Exhibit A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees and costs and class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.,

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California residents who, between March 2July 30, 2016 2015 and November 5the Preliminary Approval Date, 2020, (i) were enrolled by Disney in an automatic renewal or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged for an automatic renewal of such subscriptionthe Disney Movie Club. Excluded from the Class are all employees of Disney, all employees of Plaintiffs’ counsel, and the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, the Parties stipulate to the filing of a Second Amended Complaint which sets forth the foregoing definition of the Class and adds De leon, Gonzalez, and Lanesey as additional named plaintiffs and class representatives. As part of the motion for preliminary approval, the Parties will request that the Court grant leave for the filing of the Second Amended Complaint (a copy of which will be lodged with the motion). C. Within five (5) court days after the filing and electronic service of the Second Amended Complaint, Defendant shall file an Answer without demurring or moving to strike the Second Amended Complaint. However, if the Settlement is not granted final approval by the Court, the Parties stipulate and agree that (a) the Second Amended Complaint shall be stricken, (b) the Answer to the Second Amended Complaint shall be withdrawn, and (c) the Parties will return to the status quo ante as if no Settlement had been entered into, including placing on the Court’s calendar hearing dates for Defendant’s Demurrer to the FAC and Motion to Strike Portions of the FAC and Plaintiffs’ Motions to Compel. Moreover, if the Settlement is not granted final approval by the Court, the Parties shall be deemed to have preserved all of their rights or defenses as of the date of this Agreement, and shall not be deemed to have waived any substantive or procedural rights of any kind. D. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. E. Solely for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇▇▇ and ▇, ▇▇▇▇▇ ▇-Ward, Peterson, De leon, Gonzalez, and Lanesey will be appointed as Class Representatives. D. F. Subject to Court approval, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing settlement checks to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. G. On statutory notice for the December 4, 2020 scheduled hearing, Plaintiffs shall timely submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees fees, reimbursement of litigation expenses, and costs and any class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Settlement Class (the members of which are referred to as the “Class Members”): All individuals in California who, between March 2January 1, 2016 2015 and November 5September 23, 2020, (i) 2021, enrolled in an automatic at least one automatic-renewal or continuous continuous-service program magazine subscription for a Hearst publication directly through Consumer Reports Defendants, paid for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Accessat least one renewal for a subscription, and (ii) were charged used a California street address as the shipping address for an automatic renewal of such that subscription. Excluded from the Class are all employees of Defendants, all employees of Plaintiffs’ counsel, and the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. Solely for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that Nakai, Arnold, and ▇▇▇▇▇▇ and ▇▇▇▇▇ will be appointed as Class Representatives. D. Subject to Court approval, and subject to the Parties’ right to propose a different administration firm, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing settlement checks to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs shall timely promptly submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees and costs and class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California who, between March 2January 31, 2016 and November 5December 2, 2020, 2021, were enrolled in a JustAnswer membership in connection with or at the conclusion of a trial period and whose account was created with a California zip code for billing purposes, excluding individuals who (i) were enrolled in an automatic renewal a membership after utilizing JustAnswer’s services on a pay-per-question basis or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged for an automatic renewal received a complete refund of such subscriptionall amounts paid to JustAnswer. Excluded from the Class are all employees of Plaintiffs’ counsel and the judicial officers officer(s) to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, the Parties stipulate to the filing of a First Amended Complaint which sets forth the foregoing definition of the Class. As part of the motion for preliminary approval, the Parties will request that the Court grant leave for the filing of the First Amended Complaint and that Defendant be deemed to have denied all material allegations of the First Amended Complaint without the necessity of filing an Answer. C. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. D. Solely for the purpose of effectuating this the Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇ ▇▇▇▇▇▇▇ and ▇▇▇▇ ▇’▇▇▇▇▇ will be appointed as Class Representatives. D. E. Subject to Court approval, and subject to the Parties’ right to propose a different administration firm, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing transmitting settlement checks payments to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. F. Plaintiffs shall timely submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the and Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, and C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees fees, reimbursement of litigation expenses, and costs and class representative any service payments, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California who, between July 26, 2015 and March 2, 2016 and November 5, 2020, (i) , were enrolled by, or on behalf of, Trusted Media Brands, Inc. or its affiliates in an automatic renewal or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged for an automatic renewal of such subscriptionprogram. Excluded from the Settlement Class are all employees of Trusted Media Brands, Inc., all employees of plaintiffs’ counsel, and the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. Solely for the purpose of effectuating this the Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇▇▇▇ and ▇▇▇▇▇ Tovey will be appointed as Class Representatives. D. Subject to Court approval, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing settlement checks to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs shall timely promptly submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees and costs and class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California who, between March 2May 17, 2016 2015 and November 5June 30, 2020, (i) 2019, were enrolled in an Defendants’ automatic renewal or continuous service program through Consumer Reports subscription for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Accessa product or offer, and (iidid not receive before June 30, 2019 a refund in the full amount(s) were charged for an automatic renewal of paid to Defendants in connection with such subscriptionsubscriptions. Excluded from the Class are all employees of Defendants, all employees of Plaintiff’s counsel, and the judicial officers officer to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, the parties stipulate to the filing of a Second Amended Complaint which sets forth the foregoing definition of the Class. Promptly upon entry of an order granting preliminary approval of the Settlement, the parties will submit to the Court a stipulation and proposed order for the filing of the Second Amended Complaint. C. Within three (3) court days after the filing of said Second Amended Complaint, Defendants shall file an Answer without any pleading challenges to the Second Amended Complaint. However, if the Settlement is not granted final approval by the Court, the parties stipulate and agree that (a) the Second Amended Complaint shall be stricken, (b) the Answer to the Second Amended Complaint shall be withdrawn, and (c) the parties will return to the status quo ante. D. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. E. Solely for the purpose of effectuating this Settlement, and subject to Court approval, the Parties parties stipulate that ▇▇▇▇▇▇ and ▇▇▇▇▇ will be appointed as Class RepresentativesRepresentative. D. F. Subject to Court approval, the Parties parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing settlement checks to Class Members; and doing such other things as the Parties parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs G. Plaintiff shall timely promptly submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees and costs and a class representative service paymentspayment, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely ▇. ▇▇▇▇▇▇ for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California residents who, between March 2June 10, 2016 and November 5February 15, 2020, 2022, were both (i) enrolled in an automatic renewal or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Accessany PGI VIP membership program, and (ii) were charged at least one membership fee for an automatic renewal of such subscriptionprogram. Excluded from the Class are all employees of Defendant, all employees of Plaintiff’s counsel, and the judicial officers to whom this case is assigned. B. Solely The Parties stipulate that, upon entry of an order granting preliminary approval, Plaintiff will file a Second Amended Complaint that defines the Class as set forth above. The term “PGI VIP membership program” consists of VIP programs relating to the following brands: Cuddledown, NorthStyle, The Pyramid Collection, Serengeti, In The Company Of Dogs, Magellan’s, Catalog Favorites, Young Explorers, Back In The Saddle, Whatever Works, Country Store, Potpourri, Expressions, Nature’s Jewelry, The Stitchery, SageFinds, TravelSmith, and Chadwicks. ▇. ▇▇▇▇▇▇ for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. Solely ▇. ▇▇▇▇▇▇ for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇▇▇ and ▇▇▇▇▇ will be appointed as the Class RepresentativesRepresentative. D. E. Subject to Court approval, and subject to the Parties’ right to jointly propose a different administration firm, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for, inter alia: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing transmitting settlement checks payments to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs F. Plaintiff shall timely promptly submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees and costs and class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”) (also referred to herein as the “Class Definition”): All individuals who, while residing in California whoand between February 14, between March 22019 and June 6, 2016 and November 52023, 2020, (i) enrolled in an automatic renewal or continuous service program inclusive, purchased a subscription through Consumer Reports for Consumer Reports magazinethe website ▇▇▇.▇▇▇▇▇▇▇▇.▇▇▇, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged for an automatic renewal of such subscriptionlimited to individuals who did not receive a full refund. Excluded from the Class are all employees of Defendant, all employees of Plaintiff’s counsel, and the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, the Parties stipulate to the filing of a Second Amended Complaint which sets forth the foregoing Class Definition. As part of the motion for preliminary approval, the Parties will request that the Court grant leave for the filing of the Second Amended Complaint and that Defendant be deemed to have denied all material allegations of the Second Amended Complaint without the necessity of filing an Answer. C. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. D. Solely for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇ ▇▇▇ and ▇▇▇▇▇ will be appointed as the Class RepresentativesRepresentative to represent the Class. D. E. Subject to Court approval, and subject to the Parties’ right to jointly propose a different administration firm, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for, inter alia: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence, if necessary; mailing transmitting settlement checks payments to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs F. Plaintiff shall timely promptly submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, Notice and the Long Form Class Notice, and the paper Claim Form Notice are attached hereto as Exhibits A, A and B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees fees, reimbursement of litigation expenses, and costs and class representative any service paymentspayment, should be finally approved as fair, reasonable, and adequate as to the Class. The Parties will cooperate to obtain preliminary approval as soon as feasible pursuant to the Court’s procedures, which may include an ex parte application to specially set a hearing date.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California residents who, between March 2July 30, 2016 2015 and November 5the Preliminary Approval Date, 2020, (i) were enrolled by Disney in an automatic renewal or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged for an automatic renewal of such subscriptionthe Disney Movie Club. Excluded from the Class are all employees of Disney, all employees of Plaintiffs’ counsel, and the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, the Parties stipulate to the filing of a Second Amended Complaint which sets forth the foregoing definition of the Class and adds ▇▇ ▇▇▇▇, ▇▇▇▇▇▇▇▇, and ▇▇▇▇▇▇▇ as additional named plaintiffs and class representatives. As part of the motion for preliminary approval, the Parties will request that the Court grant leave for the filing of the Second Amended Complaint (a copy of which will be lodged with the motion). C. Within five (5) court days after the filing and electronic service of the Second Amended Complaint, Defendant shall file an Answer without demurring or moving to strike the Second Amended Complaint. However, if the Settlement is not granted final approval by the Court, the Parties stipulate and agree that (a) the Second Amended Complaint shall be stricken, (b) the Answer to the Second Amended Complaint shall be withdrawn, and (c) the Parties will return to the status quo ante as if no Settlement had been entered into, including placing on the Court’s calendar hearing dates for Defendant’s Demurrer to the FAC and Motion to Strike Portions of the FAC and Plaintiffs’ Motions to Compel. Moreover, if the Settlement is not granted final approval by the Court, the Parties shall be deemed to have preserved all of their rights or defenses as of the date of this Agreement, and shall not be deemed to have waived any substantive or procedural rights of any kind. D. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. E. Solely for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇▇▇, ▇▇▇▇▇-Ward, ▇▇▇▇▇▇▇▇, ▇▇ ▇▇▇▇, ▇▇▇▇▇▇▇▇, and ▇▇▇▇▇▇▇ will be appointed as Class Representatives. D. F. Subject to Court approval, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing settlement checks to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. G. On statutory notice for the December 4, 2020 scheduled hearing, Plaintiffs shall timely submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees fees, reimbursement of litigation expenses, and costs and any class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Settlement Class (the members of which are referred to as the “Class Members”): All individuals California residents who were charged for a membership in California who, ID Sentinel Alert by AmeriMark Direct LLC or ▇▇. ▇▇▇▇▇▇▇’▇ Healthcare Corp. between March 2July 31, 2016 and November 523, 2020, (i) enrolled in an automatic renewal or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged for an automatic renewal of such subscription2021. Excluded from the Class are all employees of Defendants, all employees of Plaintiff’s counsel, and the judicial officers to whom this case is assigned. B. The Parties stipulate to the filing of a Second Amended Complaint that includes the foregoing Class definition. C. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. D. Solely for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇▇▇ and ▇▇▇▇▇ will be appointed as Class RepresentativesRepresentative. D. E. Subject to Court approval, and subject to the Parties’ right to propose a different administration firm, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing transmitting settlement checks payments to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs F. Plaintiff shall timely promptly submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees and costs and class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California who, between March 2November 12, 2016 and November 5, 2020, (i) enrolled in an automatic renewal or continuous service program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access2016, and March 10, 2021, entered into a rental-purchase agreement with Snap RTO LLC in the State of California that included provisions providing for payment of a Processing Fee and/or a Nonsufficient Funds Fee (ii) were charged for an automatic renewal of such subscription“NSF Fee”). Excluded from the Class are persons who have entered into an agreement with Snap that effects a release of claims that would otherwise be within the scope of this action. Also excluded from the Class are all employees of Defendants, all employees of Plaintiffs’ counsel, and the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP will be appointed as counsel for the Class (“Class Counsel”). C. Solely for the purpose of effectuating this the Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇▇▇ Jacquess, Spruell, Tisdale, Bolden, Sims, and ▇▇▇▇▇ will be appointed as the Class Representatives. D. Subject to Court approval, and subject to the Parties’ right to propose a different administration firm, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; receiving any requests for exclusion or objections; preparing a declaration regarding its due diligence; mailing settlement checks coordinating payments to qualifying Class Members, whether by check or otherwise; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. Plaintiffs shall timely promptly submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Long Form Notice are attached hereto as Exhibits A, B, and C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees and costs and class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.

Class Certification. A. Solely ▇. ▇▇▇▇▇▇ for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate to class certification of the following “Class” Class (the members of which are referred to as the “Class Members”): All individuals in California residents who, between March 2October 9, 2016 2018 and November 5April 26, 2020, 2022, were both (i) enrolled in an automatic renewal or continuous service the Collections Etc. Premier Savings program through Consumer Reports for Consumer Reports magazine, Consumer Reports On Health, Consumer Reports Online, and/or Consumer Reports All Access, and (ii) were charged at least one membership fee for an automatic renewal of such subscriptionprogram. Excluded from the Class are all employees of Winston Brands, all employees of Plaintiffs’ counsel, and the judicial officers to whom this case is assigned. B. Solely for the purpose of effectuating the Settlement, the Parties stipulate to the filing of a Second Amended Complaint which sets forth the foregoing definition of the Class. As part of the motion for preliminary approval, the Parties will request that the Court grant leave for the filing of the Second Amended Complaint and that Defendant be deemed to have denied all material allegations of the Second Amended Complaint without the necessity of filing an Answer. ▇. ▇▇▇▇▇▇ for the purpose of effectuating the Settlement, and subject to Court approval, the Parties stipulate that the law firm of Dostart ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ Hannink LLP will be appointed as counsel for the Class (“Class Counsel”). C. Solely ▇. ▇▇▇▇▇▇ for the purpose of effectuating this Settlement, and subject to Court approval, the Parties stipulate that ▇▇▇▇▇▇ ▇, ▇▇▇▇, ▇▇▇▇▇▇▇, and ▇▇▇▇▇ will be appointed as the Class Representatives. D. E. Subject to Court approval, and subject to the Parties’ right to jointly propose a different administration firm, the Parties agree that CPT Group, Inc. will be the “Settlement Administrator.” . The Settlement Administrator will be responsible for, inter alia: disseminating the Summary Class Notice; establishing and maintaining the Settlement Website; researching and updating addresses through skip-traces and similar means, if and to the extent necessary; receiving and validating claims; preparing a declaration regarding its due diligence; mailing transmitting settlement checks payments to Class Members; and doing such other things as the Parties or the Court may direct in order to effectuate the Settlement. E. F. Plaintiffs shall timely promptly submit this Agreement to the Court along with a motion for preliminary approval of class action settlement, conditional certification of the Class, and approval of class notice of the proposed settlement (proposed forms for the emailed Summary Class Notice, the mailed Summary Class Notice, the Long Form Class Notice, and the paper Claim Form are attached hereto as Exhibits A, B, C, and D, respectively). The Parties agree to cooperate in obtaining preliminary approval as soon as the Court’s calendar will permit. The preliminary approval motion will also ask the Court to schedule a fairness hearing on the question of whether the proposed settlement, including payment of attorneys’ fees and costs and class representative service payments, should be finally approved as fair, reasonable, and adequate as to the Class.