LifeLock 2015 Annual Report Download - page 181

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 23 of 289
this Settlement Agreement.
42. “Settlement Subclass Member” means all individuals who are members of the Settlement Subclass.
43. “Subclass” means all individuals who enrolled in (i.e., became a member of) a LifeLock identity theft protection plan
in the United States at any time between January 1, 2012, and April 30, 2015. LifeLock estimates there are approximately 3.4 million
Subclass Members.
44. “Subclass Fund” means the amount of the Settlement Fund that shall be available for direct automatic distribution to
Settlement Subclass Members and shall be determined by the percentage of the Class that the Subclass comprises. For instance, if the
Subclass comprises fifty percent (50%) of the Class, then fifty percent (50%) of the Settlement Fund shall be allocated to the Subclass
Fund for use in making direct automatic payments to the Settlement Subclass.
45. “Subclass Member” means any individual falling within the Subclass definition.
46. “Summary Notice” means the notice substantially in the form attached as to this Settlement Agreement and
approved by the Court that the Settlement Administrator shall email or mail to Class Members.
47. “Valid Claimant(s)” means and includes all Class Members who have not opted- out and who the Settlement
Administrator determines have submitted a timely and valid Claim.
III. 
48. Other capitalized terms used in this Settlement Agreement but not defined in the Definitions Section (Section II) of
this Settlement Agreement shall have the meanings ascribed to them elsewhere in this Settlement Agreement.
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