LifeLock 2015 Annual Report Download - page 173

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 15 of 289
$1,000,000 against identity theft. Plaintiffs’ FAC seeks declaratory judgment, compensatory damages, equitable relief, attorneys’ fees,
and costs.
B. LifeLock expressly denies any wrongdoing and does not admit or concede any actual or potential fault, wrongdoing,
or liability in connection with any facts or claims that have been alleged against it in this Action. Nevertheless, LifeLock considers it
desirable to resolve the Action on the terms stated herein in order to avoid further expense, inconvenience, and interference with its
business operations and to dispose of burdensome litigation. Therefore, LifeLock has determined that the settlement of the Action on
the terms set forth herein is in its best interests.
C. This Settlement Agreement reflects a compromise between the Parties and shall in no event be construed as or
deemed an admission or concession by any Party of the truth of any of the pleadings in the Action or of any fault on the part of
LifeLock and all such allegations or the validity of any purported claim or defense asserted are expressly denied. Nothing in this
Settlement Agreement shall constitute an admission of liability or may be used as evidence of liability by or against any Party hereto.
D. LifeLock has informally produced approximately 10,000 pages of relevant documents in the Action to Class Counsel,
which Class Counsel has thoroughly reviewed. In particular, LifeLock’s production included, but was not limited to: (i) 416
exemplars of print advertisements, comprising approximately 1,279 pages, which were disseminated between April 2010 and
December 2012; (ii) 75 exemplars of aired television commercials; (iii) account histories for the individual Plaintiffs; (iv) the
Settlement Agreement in the Multi District Litigation entitled In Re LifeLock, Inc. Marketing and Sales Practices Litigation, MDL
Docket No. 08-1977-MHM in the United States District Court for the District of Arizona; (v) certain
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