LifeLock 2015 Annual Report Download - page 209

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 51 of 289
H. Notwithstanding the terms of this Section, if the Settlement is not consummated, Class Counsel may include
any time spent in settlement efforts as part of any fee petition filed at the conclusion of the case and LifeLock reserves the right to
object to such requested fees.
I. Notwithstanding the terms of this Section, in the event of the denial of Preliminary Approval or Final
Approval, Plaintiffs and/or LifeLock may seek appellate review through a writ or pursue any other available appellate remedy in
support of the Settlement or this Settlement Agreement. The Parties agree that nothing herein is intended to restrict or limit the rights
of either LifeLock or the Plaintiffs to appeal any order of this Court in the event the Settlement is not finally approved for any reason.
During the pendency of any appeal of the denial of Preliminary Approval or Final Approval, this Settlement Agreement shall remain
valid and binding.
XVII. 
118. Based upon the terms of this Settlement Agreement, the Parties anticipate the following schedule related to
Preliminary Approval and Final Approval of this Settlement Agreement and performance of this Agreement, which is subject to the
Court’s approval:
 
November 16, 2015 Deadline for Preliminary Approval Motion
Three (3) business days after entry of Preliminary Approval Order Deadline for LifeLock to provide Class Data to Settlement
Administrator
Ten (10) days after filing of Preliminary Approval Motion Deadline for Settlement Administrator to provide notice to federal or
state officials per U.S.C. § 1715
Ten (10) days after entry of Preliminary Approval Order (or within
three (3) calendar days after entry of Final Approval Order if money
not released from Court’s Registry in the FTC Action)
LifeLock shall pay the sum to the Settlement Administrator of Sixty-
Eight Million Dollars ($68,000,000.00) to create the Settlement Fund
Thirty (30) days after entry of Preliminary Approval Order Notice Date and deadline for the Settlement Website and Toll-Free
Number to go live
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