Common use of Reasons for the Settlement Clause in Contracts

Reasons for the Settlement. Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 2021. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 2021. This is the only way to be eligible to receive a payment from POSTMARKED NO LATER the Settlement Fund. If you are a Settlement Class Member THAN , 2020. and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 36 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 37 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212020. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212020. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ 2020 AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 20212020. Filing a written objection and notice of intention to appear by , 2021 2020 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – recovery, or indeed no recovery at all – all, might be achieved after additional contested motions, a trial of the Action and the likely appeals that would follow a trial. This process could be expected to last several one or more additional years. Defendants, who Defendants have stated that they deny all allegations of wrongdoing or liability whatsoever, whatsoever and are entering into the Settlement solely to eliminate the uncertaintyburden, burden risk and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212016. This is the only way to be potentially eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 paragraph 35 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 paragraph 36 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212016. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212016. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense Litigation Expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays and costs inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motionsa motion for summary judgment, a trial of the Action Action, and the likely appeals that would follow a trial. This process could be expected to last several years, particularly in light of substantial delays expected to result from the ongoing criminal prosecutions against Defendants Xxxxxx and Xxxxxxxx. Defendants, who deny all allegations of wrongdoing or liability whatsoever, Defendants are entering into the this Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. Defendants, X’Xxxxx, and XxXxxxxxxx expressly deny that Lead Plaintiffs have asserted any valid claims as to any of them, and expressly deny any and all allegations of fault, liability, wrongdoing, or damages whatsoever, or any infirmity in the defenses that Defendants, X’Xxxxx, or XxXxxxxxxx have, or could have asserted. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE POSTMARKED (IF MAILED), OR POSTMARKED ONLINE, NO LATER THAN , 2021202_. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 39 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 40 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the proposed Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This , a process that could be expected to last several years. Defendants, who Defendants deny all allegations of wrongdoing or liability whatsoever, whatsoever and are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 2021. 201 .2 This is the only way to be eligible to receive a payment from the Settlement Fundproceeds of the Settlement. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 below) that you have against the Defendants and the other Defendants’ Releasees (defined in ¶ 31 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A VALID WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 202120 . If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit and certain recovery for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit recovery provided under the Settlement must be considered against the significant risk that a smaller recovery – recovery—or indeed no recovery at all – all—might be achieved after contested motions, a trial of the Action Action, and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing that they have committed any act or omission giving rise to liability whatsoeverunder the federal securities laws, are entering into the Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212020. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 33 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 34 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212020. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212020. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for an award of attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation Allocation, or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the immediate and substantial immediate cash benefit for the Settlement Class that will be obtained without the risk or the delays inherent in further litigation. MoreoverIn particular, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212017. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 36 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 37 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will FROM THE SETTLEMENT not be eligible to receive any payment from the Settlement CLASS BY SUBMITTING A Fund. This is the only option that allows you ever to be part WRITTEN REQUEST FOR of any other lawsuit against any of the Defendants or the EXCLUSION SO THAT IT other Defendants’ Releasees concerning the Released IS RECEIVED NO LATER Plaintiffs’ Claims. THAN , 2017. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212017. If you do not like the proposed Settlement, the proposed Plan of Allocation, Allocation or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ 2017 AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 20212017. Filing a written objection and notice of intention to appear by , 2021 2017 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, Allocation and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ Lead Plaintiff’s principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action Action, and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212022. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Plaintiff’s Claims (defined in ¶ 30 33 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 34 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will FROM THE SETTLEMENT not be eligible to receive any payment from the Settlement CLASS BY SUBMITTING A Fund. This Excluding yourself from the Settlement Class is the WRITTEN REQUEST FOR only option that allows you ever to be part of any other EXCLUSION SO THAT IT lawsuit against any of the Defendants or the other Defendants’ Releasees concerning IS RECEIVED NO LATER the Released Plaintiffs’ Plaintiff’s Claims. THAN , 2022. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212022. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like one or more of them. You cannot object to the Settlement, the Plan of Allocation Allocation, or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ Continuing with the case could have resulted in a loss at summary judgment, trial or on appeal. The two sides vigorously disagree on both liability and the amount of money that could have been won if Lead Plaintiff had prevailed at trial. Lead Plaintiff’s principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after additional contested motions, a trial of the Action and the likely appeals that would follow a trial. This , a process that could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. Your legal rights are affected whether you act or do not act. Please read this Notice carefully. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212015. This is the only way to be potentially eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212015. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212015. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ 2015 AT : .M./A.M./P.M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 20212015. Filing a written objection and notice of intention to appear by , 2021 2015, allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ For Lead Plaintiff, the principal reason for entering into the Settlement is the substantial immediate cash benefit for payment to the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after (a) the Court decides contested motionsmotions to dismiss, for class certification, and for summary judgment, (b) trial, and (c) appeals, a trial of the Action and the likely appeals process that would follow a trial. This process could be expected to last several years. Defendants, who Defendants deny all allegations of wrongdoing or and liability whatsoeverand deny that Settlement Class Members were damaged, and are entering into the Settlement solely to eliminate the uncertainty, burden burden, expense and expense risk of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: ACTION YOU MAY TAKE EFFECT OF TAKING THIS ACTION SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 2021. This 2018 Submitting a Claim Form in accordance with the instructions on the Claim Form and in this Notice makes you eligible to receive a payment in the Settlement – and is the only way to be eligible to receive a payment from in the Settlement FundSettlement. If you are submit a Settlement Class Member Claim Form and you remain in the Settlement Classis approved by the Court, you will give up the claims that are the subject matter of the Settlement and you will be bound by the Settlement as approved by and the Court and you will give up any Released Plaintiffs’ Claims Judgment (defined in ¶ 30 belowParagraph 26 of this Notice) that you have against Defendants and the other Defendants’ Releasees (defined releases provided for in ¶ 31 below), so it is in your interest to submit a Claim Formthe Judgment. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude 2018 Excluding yourself from the Settlement ClassClass is the only option that allows you to be part of any other lawsuit concerning the claims that are the subject matter of the Settlement. If you do so, you will not be eligible to receive any a payment from in the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ ClaimsSettlement. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 2021. 2018 If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation Allocation, the request for Attorneys’ Fees and Litigation Expenses, or any other aspect of the fee Settlement, you may still submit a Claim Form and expense request unless be eligible to receive a payment in the Settlement but you are a Settlement Class Member and do may not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ 2018 AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. 2018 If you submit a written objection, you may (but you do are not have required to) attend submit a notice of intention to appear at the hearing Settlement Hearing, and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ Lead Plaintiff’s principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212019. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 34 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 35 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212019. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212019. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation Allocation, or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial and immediate cash benefit for the Settlement Class without the risk risks or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This , a process that could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN _____________, 20212016. This is the only way to be potentially eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 26 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 27 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN _____________, 20212016. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN _____________, 20212016. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after further contested motions, a trial of the Action Action, and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212017. This is the only way to be potentially eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 paragraph 35 below) that you have against Defendants and the other Defendants’ Defendant Releasees (defined in ¶ 31 paragraph 36 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will not FROM THE SETTLEMENT be eligible to receive any payment from the Settlement Fund. CLASS BY SUBMITTING A This is the only option that allows you ever to be part of any WRITTEN REQUEST FOR other lawsuit against any of the Defendants or the other Defendants’ EXCLUSION SO THAT IT Defendant Releasees concerning the Released Plaintiffs’ IS RECEIVED NO LATER Claims. THAN , 2017. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212017. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ Lead Plaintiff’s principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays and costs inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after full discovery, contested motions, a trial of the Action Action, and the likely appeals that would follow a trial. This process could be expected to last several years. In reaching the Settlement, Lead Counsel also considered Endo’s ability to fund a settlement or future judgment in an amount greater than the Settlement Amount. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into have determined that it is desirable and beneficial to them that the Settlement solely to eliminate Action be settled in the uncertainty, burden manner and expense upon the terms and conditions of further protracted litigationthe Settlement. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212020. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Plaintiff Claims (defined in ¶ 30 29 below) that you have against Defendants and the other Defendants’ Defendant Releasees (defined in ¶ 31 30 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212019. Get no payment. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows may allow you to ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claimsclaims that were, or could have been, asserted in this Action. It is also the only way for Settlement Class Members to remove themselves from the Settlement Class. If you are considering excluding yourself from the Settlement Class, please note that there is a risk that any new claims asserted against the Defendants may no longer be timely and would be time-barred. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212019. If you do not like the proposed Settlement, the proposed Plan of Allocation, or and/or the request for requested attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object In order to the Settlementobject, the Plan you must remain a member of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection , may not exclude yourself, and notice of intention to appear you will be bound by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection’s determinations.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit and certain recovery for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit recovery provided under the Settlement must be considered against the significant risk that a smaller recovery – recovery—or indeed no recovery at all – all—might be achieved after contested motions, a trial of the Action Action, and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing that they have committed any act or omission giving rise to liability whatsoeverunder the federal securities laws, are entering into the Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212020. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will FROM THE SETTLEMENT not be eligible to receive any payment from the Settlement CLASS BY SUBMITTING A Fund. This is the only option that allows you ever to be part WRITTEN REQUEST FOR of any other lawsuit against any of the Defendants or the EXCLUSION SO THAT IT other Defendants’ Releasees concerning the Released IS RECEIVED NO LATER Plaintiffs’ Claims. THAN , 2020. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212020. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation Allocation, or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – recovery—or indeed no recovery at all – all—might be achieved after further contested motions, a trial of the Action and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM POSTMARKED OR SUBMITTED ONLINE OR POSTMARKED NO LATER THAN , 20212024. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 40 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 41 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212024. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED FILED OR POSTMARKED NO LATER THAN , 20212024. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation Allocation, or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays and costs inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motionsa motion for summary judgment, a trial of the Action Action, and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, Defendants are entering into the this Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. Defendants expressly deny that Lead Plaintiffs have asserted any valid claims as to any of them, and expressly deny any and all allegations of fault, liability, wrongdoing, or damages whatsoever, or any infirmity in the defenses that Defendants have, or could have asserted. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE POSTMARKED (IF MAILED), OR POSTMARKED ONLINE, NO LATER THAN , 20212022. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 34 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 35 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212022. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows may allow you to ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212022. If you do not like the proposed Settlement, the proposed Plan of Allocation, or and/or the request for requested attorneys’ fees and reimbursement of Litigation Expenses, you may write object by writing to the Court and explain explaining why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a member of the Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ Plaintiff’s principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action Action, and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 2021. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 33 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 34 below), so it is in your interest to submit a Claim Form. SUBMIT A CLAIM FORM POSTMARKED NO LATER THAN , 2018. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212018. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212018. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ Lead Plaintiff’s principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the The substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – recovery— or indeed no recovery at all – all—might be achieved after contested motionsa motion for summary judgment, a trial of the Action Action, and the likely appeals that would follow a trial. This , a process that could be expected to last several years. DefendantsDefendants deny that Lead Plaintiff has asserted any valid claims as to any of them, who and expressly deny any and all allegations of wrongdoing fault, liability, wrongdoing, or liability damages whatsoever, or any infirmity in the defenses that Defendants have, or could have, asserted. Defendants are entering into the this Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE POSTMARKED (IF MAILED), OR POSTMARKED ONLINE, NO LATER THAN [ ], 20212023. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Plaintiff’s Claims (defined in ¶ 30 39 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 40 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will FROM THE CLASS BY not be eligible to receive any payment from the SUBMITTING A Settlement Fund. This is the only option that allows may WRITTEN REQUEST FOR allow you to ever to be part of any other lawsuit EXCLUSION SO THAT IT against any of the Defendants or the other Defendants’ Releasees IS RECEIVED NO LATER concerning the Released Plaintiffs’ Plaintiff’s Claims. THAN [ ], 2023. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN [ ], 20212023. If you do not like the proposed Settlement, the proposed Plan of Allocation, or and/or the request for requested attorneys’ fees and reimbursement of Litigation Expenses, you may write object by writing to the Court and explain explaining why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement member of the Class Member and do not exclude yourself from the Settlement Class. GO TO ATTEND A HEARING ON Filing a written objection and notice of intention to appear by [ ], 2021_ 2023, AT [ : ] [ ].M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN [ ], 20212023. Filing a written objection and notice of intention to appear by [ ], 2021 2023, allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. In the Court’s discretion, the [ ], 2023 hearing may be conducted by telephone or videoconference (see ¶¶ 65-66 below). If you submit a written objection, you may (but you do not have to) attend participate in the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial and immediate cash benefit for the Settlement Class without the risk risks or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This , a process that could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212016. This is the only way to be potentially eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 26 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 27 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212016. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit and certain recovery for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit recovery provided under the Settlement must be considered against the significant risk that a smaller recovery – recovery—or indeed no recovery at all – all—might be achieved after contested motions, a trial of the Action Action, and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing that they have committed any act or omission giving rise to liability whatsoeverunder the federal securities laws, are entering into the Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SETTLEMENT SUBMIT A CLAIM FORM ONLINE POSTMARKED (IF MAILED), OR POSTMARKED ONLINE, NO LATER THAN , 2021. This is the only way to be eligible to receive a payment from the Net Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 35 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 36 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Net Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you do not like the proposed Settlement, the proposed Plan of Allocation, or and/or the request for an award of attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or Allocation, and/or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO PARTICIPATE IN A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ 2021 AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. Filing a written objection and notice of intention to appear by , 2021 allows you to speak in Court, at the discretion of the Court, either in person or by video or telephonic conference as required or allowed by the Court, about the fairness of the proposed Settlement, the proposed Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212018. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 32 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 33 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212018. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212018. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ Lead Plaintiff’s principal reason for entering into the Settlement is the substantial immediate cash benefit and certain recovery that the Settlement provides for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the The substantial cash benefit recovery provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after a contested motionssummary judgment motion, a trial of the Action Action, and the likely appeals that would follow a trial. This process could would be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoeverwrongdoing, are entering into the Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE POSTMARKED (IF MAILED), OR POSTMARKED ONLINE, NO LATER THAN , 2021. 2022 This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement ClassMember, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Plaintiff’s Claims (defined in ¶ 30 ¶43 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 ¶44 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you to ever to be part of any other lawsuit against any of the Defendants or the other any Defendants’ Releasees concerning the Released Plaintiffs’ Plaintiff’s Claims. Exclusions must be postmarked on or before , 2022. If you excluded yourself from the Class in connection with the Notice of Pendency of Class Action provided in or around July 2020, you do not have to do so again. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 2021. 2022 If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation Allocation, or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objectionMember.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This , a process that could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, distraction, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212014. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 31 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 32 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212014. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212014. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement ࣖettlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212017. This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 36 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 37 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212017. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212017. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ Lead Plaintiffs principal reason for entering into the Settlement is the substantial immediate cash and stock benefit for the Settlement Class Class, without the risk or the delays inherent in further litigation. Moreover, the substantial cash and stock benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed recovery-or, indeed, no recovery at all – all-might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This , a process that could be expected to last several many months, or even years, into the future. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden burden, and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: - The amount of damages recoverable by the Settlement Class was and is challenged by Defendants. SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN AUGUST 9, 20212022. This is the only way to be eligible to receive a payment from the Settlement FundSettlement. If you are a Settlement Class Member and you remain in the Settlement ClassMember, you will be bound by the Settlement as approved approved-by the Court and you will give will·give up any Released Plaintiffs’ Claims (as defined in ¶ 30 paragraph 37 below) that you have against Defendants and the other Defendants’ Releasees (as defined in ¶ 31 paragraph 36 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021. If you exclude yourself from the Settlement Class, you will not be eligible FROM THE SETTLEMENT to receive any payment from the Settlement Fund. This is the only option CLASS BY SUBMITTING A that allows you to ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER concerning the Released Plaintiffs’ Claimsclaims that were, or could have been, asserted in this Action. It is also the only way for Settlement Class Members to remove themselves from the Settlement Class. If you are considering excluding yourself from THAN JUNE 8, 2022. the Settlement Class, please note that there is a risk that any new claims asserted against the Defendants may no longer be timely and would be time-barred. See paragraph 63 below. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN JUNE 8, 20212022. If you do not like the proposed Settlement, the proposed Plan of Allocation, or and/or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or Allocation, and/or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN JUNE 8, 20212022, AND GO TO THE HEARING ON JUNE 29, 2022 AT THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 000 XXXXX XXXXXX, XXXXXXXXX 00X, XXX XXXX, XX 00000. Filing a written objection and notice of intention to appear by June 8, 2021 2022 allows you to speak in CourtCoURt, at the discretion of the Court, about the fairness of the proposed Settlement, the proposed Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

Reasons for the Settlement. Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or 2 the delays inherent in further litigation. Moreover, the substantial cash benefit provided under 3 the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely 4 appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the 5 Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 2021201_. This is the only way to be potentially eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 30 ¶33 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 ¶34 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 2021201_. If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 2021201_. If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON Filing a written objection and notice of intention to appear by , 2021201_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021201_. Filing a written objection and notice of intention to appear by , 2021 201_, allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 26

Reasons for the Settlement. Plaintiffs’ Plaintiff’s principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: SUBMIT A CLAIM FORM ONLINE OR POSTMARKED NO LATER THAN , 20212020 (80 days after the Notice date). This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Settlement Class Member and you remain in the Settlement Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Plaintiff’s Claims (defined in ¶ 30 29 below) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 31 30 below), so it is in your interest to submit a Claim Form. EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN , 20212020 (30 days before the Settlement Hearing). If you exclude yourself from the Settlement Class, you will not be eligible to receive any payment from the Settlement Fund. This Excluding yourself from the Class is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Plaintiff’s Claims. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN , 20212020 (14 days before the Settlement Hearing). If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Settlement Class Member and do not exclude yourself from the Settlement Class. GO TO A HEARING ON , 2020 (105 days after the Notice date)AT : .M., AND FILE AN Filing a written objection and notice of intention to appear by , 2021_ AT : .M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2021. , 2021 2020 (14 days before the Settlement Hearing) allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of OBJECTION AND A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN , 2020 (14 days before the Settlement Hearing). Allocation, and/or the request for attorneys’ fees and reimbursement of Litigation Expenses. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.