LifeLock 2015 Annual Report Download - page 180

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 22 of 289
34. “Releasing Parties” means Plaintiffs and the Settlement Class Members, including, only to the extent they may have a
right to a claim on behalf of a Plaintiff or a Settlement Class Member, each of their respective spouses, executors, representatives,
heirs, predecessors, successors, bankruptcy trustees, guardians, wards, joint tenants, tenants in common, tenants by the entirety, co-
borrowers, agents, attorneys, and assigns, and all others of those who claim through them or who assert claims on their behalf.
35. “Service Award” means an award authorized by the Court to be paid to each Plaintiff in recognition of his/her efforts
in prosecuting the Action and obtaining the benefits of the Settlement for the Class Members, such award not to exceed Two
Thousand Dollars ($2,000) for each of the Plaintiffs.
36. “Settlement” or “Settlement Agreement” means this Settlement Agreement, including the exhibits attached hereto.
37. “Settlement Administrator” means Garden City Group, LLC, subject to Court approval.
38. “Settlement Class” means all Class Members who do not timely and validly exclude themselves from the Class
pursuant to the procedure set forth in Section IX of this Settlement Agreement.
39. “Settlement Class Member” means any member of the Settlement Class.
40. “Settlement Fund” means Sixty-Eight Million Dollars ($68,000,000), which LifeLock has agreed to pay pursuant to
the terms and conditions set forth in this Settlement Agreement.
41. “Settlement Subclass” means all Subclass Members who do not timely and validly exclude themselves from the Class
pursuant to the procedure set forth in Section IX of
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