LifeLock 2015 Annual Report Download - page 199

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 41 of 289
90. In consideration for the Settlement benefits described in this Settlement Agreement, Releasing Parties will fully,
finally, and forever release, relinquish, acquit, and discharge the Released Parties from, and shall not now or hereafter institute,
maintain, or assert on their own behalf, on behalf of the Settlement Class, or on behalf of any other person or entity, any and all
manner of claims, actions, causes of action, suits, rights, debts, sums of money, payments, obligations, reckonings, contracts,
agreements, executions, promises, damages, liens, judgments, and demands of whatever kind, type, or nature whatsoever, both at law
and in equity, whether past, present, mature or not yet mature, known or unknown, suspected or unsuspected, contingent or non-
contingent, whether based on federal, state, or local law, statute, ordinance, regulation, code, contract, common law, or any other
source, or any claim that Plaintiffs or Settlement Class Members ever had, now have, may have, or hereafter can, shall, or may ever
have against the Released Parties that were or reasonably could have been alleged in the Action or in any other court, tribunal,
arbitration panel, commission, agency, or before any governmental and/or administrative body, or any other adjudicatory body, on the
basis of, connected with, arising from, or relating to the subject matter or allegations of the Action, including, without limitation, any
such claims: (1) alleged in the Action; (2) for rescission, restitution, or unjust enrichment for all damages of any kind related in any
way to their enrollment or re-enrollment in or renewal of a LifeLock identity theft protection plan; (3) for violations of any state’s
deceptive, unlawful, and/or unfair business and/or trade practices, false, misleading, or fraudulent advertising, consumer fraud, and/or
consumer protection statutes; (4) for failure to make any consumer disclosures required under any state or federal law or statute; (5) for
engaging in unfair or deceptive acts or practices in or affecting commerce; or (6) for damages, costs, expenses, extra-contractual
damages,
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