LifeLock 2015 Annual Report Download - page 194

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 36 of 289
postmarked no later than the Opt-out Deadline and specifying that he or she wants to be excluded from the Class. Such written
request for exclusion (i) must contain the name and address of the person to be excluded; (ii) if applicable, must contain the name and
address of any person claiming to be legally entitled to submit an exclusion request on behalf of the Class Member and the basis for
such legal entitlement; (iii) must be made via email or mailed by First Class U.S. Mail, proper postage prepaid, to the Settlement
Administrator at the specified mailing address or email address; (iv) must be submitted or postmarked on or before the Opt- out
Deadline; and (v) must clearly indicate that he/she wants to be excluded from the Class.
72. Any Class Member who does not submit a timely and valid written request for exclusion as provided in paragraph 71
shall be bound by all subsequent proceedings, orders, and judgments in the Action, including, but not limited to, the Release, even if
he or she has litigation pending or subsequently initiates litigation against LifeLock relating to the Released Claims.
73. Any Class Member who timely submits a request for exclusion as provided in paragraph 71 shall waive and forfeit
any and all rights (s)he may have to benefits of the Settlement if it is approved and becomes final, including monetary relief, and shall
waive and forfeit any and all rights to object to the fairness, reasonableness, or adequacy of the Settlement, Class Counsel’s request
for Attorneys’ Fees and Costs, and/or the requested Service Awards to Plaintiffs.
74. Not later than ten (10) days after the Opt-out Deadline, the Settlement Administrator shall provide to Class Counsel
and LifeLock’s Counsel a complete and final list of Class Members who submitted timely and valid requests to exclude themselves
from the Class.
23