LifeLock 2015 Annual Report Download - page 201

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 43 of 289
principles, to the extent they are found to be applicable herein, are hereby knowingly and voluntarily waived, relinquished, and
released by Plaintiffs and, by application of law, all Settlement Class Members
94. The Parties shall be deemed to have agreed that the Release set forth herein may be raised as a complete defense to
and would preclude any action or proceeding based on the claims released by and through this Settlement Agreement.
95. Nothing in this Release shall preclude any action to enforce the terms of this Settlement Agreement.
96. Plaintiffs and LifeLock hereby agree and acknowledge that the provisions of this Release together constitute an
essential and material term of this Settlement Agreement and shall be included by reference in any Final Approval Order and Final
Judgment entered by the Court.
XIII. 
97. Subject to the provisions of this Section, Class Counsel will make, and LifeLock agrees not to oppose, an application
for an award of Attorneys’ Fees and Expenses in an amount not to exceed Ten Million Two Hundred Thousand Dollars
($10,200,000). Class Counsel shall file their application for Attorneys’ Fees and Expenses and their request for Service Awards for
the Plaintiffs no later than thirty (30) days after the Notice Date. The Settlement Administrator shall post on the Settlement Website
such application promptly after it is filed.
98. Any Attorneys’ Fees and Expenses awarded by the Court shall not be paid out of the Settlement Fund but, instead,
shall be paid separately by LifeLock. Class Counsel, in their
30