SUMMARY NOTICE OF (I) PENDENCY OF CLASS ACTIONS AND PROPOSED SETTLEMENT OF FEDERAL CASE AND STATE CASES; (II) MOTIONS FOR AWARDS OF ATTORNEYS’ FEES AND LITIGATION EXPENSES;
AND (III) SETTLEMENT HEARINGS
This notice is directed at (i) All persons and entities who purchased or otherwise acquired Snap Inc. Class A common stock (“Snap Common Stock”) between March 2, 2017 and August 10, 2017, inclusive, and were damaged thereby (the “Federal Class”); and (ii) All persons who purchased or otherwise acquired Snap Common Stock between March 2, 2017 and July 29, 2017, inclusive, and were damaged thereby (the “State Class” and, together with the Federal Class, the “Classes”). Included within the Classes are all persons and entities who purchased shares of Snap Common Stock pursuant or traceable to Snap’s Initial Public Offering on or about March 2, 2017 and/or on the open market. Certain persons and entities are excluded from the Classes as set forth in detail in the settlement agreements for the Federal and State Actions and the Notices described below.
PLEASE READ THIS NOTICE CAREFULLY; YOUR RIGHTS WILL BE AFFECTED BY PENDING CLASS ACTION LAWSUITS.
YOU ARE HEREBY NOTIFIED, pursuant to Rule 23 of the Federal Rules of Civil Procedure, and an Order of the United States District Court for the Central District of California, that a lawsuit captioned In re Snap Inc. Securities Litigation, Case No. 2:17-cv-03679-SVW-AGR (C.D. Cal.) (the “Federal Action”) has been certified as a class action.
YOU ARE FURTHER NOTIFIED, pursuant to California Rules of Court 3.766 and 3.771, and an Order of the Superior Court of the State of California, Los Angeles County, that a related lawsuit captioned Snap Inc. Securities Cases, No. JCCP 4960 (Cal. Super Ct., Los Angeles Cty.) (the “State Action”) has been proposed for class certification (for settlement purposes only).
YOU ARE FURTHER NOTIFIED that the parties to the Federal Action and the State Action (together, the “Actions”) have reached proposed settlements (“Settlements”) in the amount of $154,687,500 in cash in the Federal Action (the “Federal Settlement”) and in the amount of $32,812,500 in cash in the State Action (the “State Settlement”). If approved, the Settlements will resolve all claims in the Actions. Hearings will be held in the Federal Action on February 22, 2021 at 1:30 p.m., before the Honorable Stephen V. Wilson at the United States District Court, First Street Courthouse, 350 W. 1st Street, Courtroom 10A, 10th Floor, Los Angeles, California, 90012 (the “Federal Court”), and in the State Action on February 25, 2021 at 9:00 a.m., before the Honorable Elihu M. Berle at the Superior Court of the State of California, Spring Street Courthouse, Department 6, 312 North Spring Street, Los Angeles, California, 90012 (the “State Court”) to determine whether: (i) the Federal and State Settlements, respectively, should be approved as fair, reasonable, and adequate; (ii) the Federal and State Actions, respectively, should be dismissed with prejudice against Defendants, and the releases specified and described in the settlement agreements (and in the Notices described below) should be entered; (iii) the proposed Plans of Allocation for the Federal and State Settlements, respectively, should be approved as fair and reasonable; and (iv) counsels’ applications for awards of attorneys’ fees and expenses should be approved. The State Court will also be asked to determine whether the State Class should be certified for purposes of effectuating the State Settlement.
The Settlements will not become effective until both the Federal and State Settlements receive final approval from their respective Courts, and both have become final. If approved, the Settlements will resolve all claims in the Federal and State Actions.
If you are a member of one or both Classes, your rights will be affected by the pending Federal and State Actions and the Settlements, and you may be entitled to share in the settlement proceeds. This notice provides only a summary of the information contained in the detailed Notice of (I) Pendency of Class Action and Proposed Settlement of Federal Case; (II) Motion for an Award of Attorneys’ Fees and Litigation Expenses; and (III) Settlement Hearing (the “Federal Notice”) and the detailed Notice of Pendency and Proposed Settlement of Class Action (the “State Notice” and, together with the Federal Notice, the “Notices”). You may obtain copies of both Notices, along with the Claim Form, on the website for the Settlements, www.SnapSecuritiesLitigation.com. You may also obtain copies of the detailed Notices and Claim Form by contacting the Claims Administrator for the Settlements at Snap Securities Litigation , c/o JND Legal Administration, P.O. Box 91314, Seattle, WA 98111; 1-855-958-0630; info@SnapSecuritiesLitigation.com.
If you are a member of one or both Classes, in order to be eligible to receive a payment under the proposed Settlements, you must submit a Claim Form postmarked (if mailed), or online at www.SnapSecuritiesLitigation.com, no later than January 25, 2021, in accordance with the instructions set forth in the Claim Form. If you are a member of one or both Classes and do not submit a proper Claim Form, you will not be eligible to share in the distribution of the net proceeds of the Settlements but you will nevertheless be bound by any releases, judgments, or orders entered by the Courts for the Federal Action and/or the State Action, respectively.
If you are a member of the Federal Class, the State Class, or both Classes and wish to exclude yourself from one or both Classes, you must submit a request for exclusion by no later than January 25, 2021, in accordance with the instructions set forth in the detailed Notices. If you properly exclude yourself from one or both Classes, you will not be bound by any releases, judgments, or orders entered by the Courts for the Federal Action and/or the State Action, respectively, and you will not be eligible to share in the net proceeds of the Settlements. Excluding yourself is the only option that may allow you to be part of any other current or future lawsuit against Defendants or any of the other released parties concerning the claims being resolved by the Settlements. Please note, however, if you decide to exclude yourself, you may be time-barred from asserting certain of the claims covered by the Federal and/or State Actions by a statute of repose.
If you are a member of one or both Classes and wish to submit an objection to the proposed Federal and State Settlements, the proposed Plans of Allocation (as contained in the Notices), and/or counsels’ motions for attorneys’ fees and expenses, you must do so no later than January 25, 2021, in accordance with the instructions set forth in the detailed Notices.
PLEASE DO NOT CONTACT THE FEDERAL OR STATE COURTS, THE CLERKS’ OFFICES, DEFENDANTS, OR THEIR COUNSEL REGARDING THIS NOTICE. All questions about this notice, the Federal and State Settlements, or your eligibility to participate in the Settlements should be directed to the counsel set forth below or the Claims Administrator.
For any questions, visit www.SnapSecuritiesLitigation.com
or call toll-free at 1-855-958-0630.
Requests for the detailed Notices and Claim Form should be made to the Claims Administrator:
Snap Securities Litigation
c/o JND Legal Administration
P.O. Box 91314
Seattle, WA 98111
Inquiries, other than requests for the detailed Notices and Claim Form, may be made to counsel as follows:
Inquiries for the Federal Settlement
should be directed to:
Sharan Nirmul, Esq.
Kessler Topaz Meltzer & Check, LLP
280 King of Prussia Road
Radnor, PA 19087
Inquiries for the State Settlement
should be directed to:
James I. Jaconette, Esq.
Robbins Geller Rudman & Dowd LLP
655 West Broadway, Suite 1900
San Diego, CA 92101
BY ORDER OF THE COURT
United States District Court
Central District of California
BY ORDER OF THE COURT
Superior Court of the State of California
Los Angeles County