LifeLock 2015 Annual Report Download - page 211

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 53 of 289
(whether anonymously or for ascription) on the web, in blogs, in chat rooms, in emails, or in other electronic means of transmitting
information.
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120. Plaintiffs and Class Counsel agree that the confidential information made available to them, including but not limited
to attorneys’ eyes only information made available to Class Counsel, solely through the mediation and settlement process was made
available, as agreed to, on the condition that neither Plaintiffs nor Class Counsel disclose it to third parties; that it not be the subject of
public comment; that it not be used by Plaintiffs or Class Counsel in any way in the Action should Settlement not be achieved; and
that it is to be returned or destroyed; provided, however, that nothing contained herein shall prohibit Plaintiffs from seeking such
information through formal discovery or from referring to the existence of such information in connection with this Settlement and the
Preliminary Approval and Final Approval of this Settlement.
121. Plaintiffs and Class Counsel agree that they will not make any statements or comments, written or oral, about this
Settlement or Settlement Agreement to any person other than to Class Members in any way other than as provided in this Settlement
Agreement, the Class Notice, on the Settlement Website, or as otherwise agreed upon by LifeLock in writing in each instance.
Notwithstanding the terms of this provision, Class Counsel may display a link to the Settlement Website on their respective firms’
websites and reference this Settlement as evidence of Class Counsel’s professional qualifications in resumes, curriculum vitae, and
motions for appointment as class counsel pursuant to Fed. R. Civ. P. 23 and similar state rules of procedure, but only to state that (i) it
was a nationwide consumer class; (ii) the general
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