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Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 74 of 289
maintain, or assert on their own behalf, 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, compensatory damages, exemplary damages, special
damages, consumer redress, penalties, punitive damages, and/or damage multipliers, disgorgement, declaratory relief, equitable relief, injunctive relief,
expenses, interest, and/or attorneys’ fees and costs.
18. As of the Final Settlement Date, Plaintiffs and, by operation of law, each Settlement Class Member shall further be deemed to have
waived and released any and all provisions, rights and benefits conferred by Section 1542 of the California Civil Code or similar laws of any other state or
jurisdiction.
19. The Court orders that, upon the Final Settlement Date, the Settlement shall be the exclusive remedy for any and all Released Claims of
the Releasing Parties.
- 5 - [PROPOSED] ORDER GRANTING FINAL APPROVAL
1275525.3 OF CLASS SETTLEMENT
CASE NO. 3:15-CV-258-HSG