LifeLock 2015 Annual Report Download - page 260

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 102 of 289
 [e-mail]
 Tuesday, November 03, 2015 2:37 PM

 Court Authorized Notice of Settlement



A proposed settlement has been reached in the nationwide class action lawsuit, Ebarle, et al. v.
LifeLock, Inc., Case. No. 3:15-CV-00258 (HSG) (“Lawsuit”). This Lawsuit challenges representations LifeLock made regarding its
identity theft protection plans and information security program. LifeLock denies all allegations or that it did anything wrong. Under
the proposed settlement, Lifelock has agreed to pay $68 million to a settlement fund.
If you were a member of a LifeLock identity theft protection plan at any time between September 1, 2010,
and [Preliminary Approval Date], such that you could assert a claim arising from the types of violations alleged in the lawsuit, you are
a . If you enrolled in a LifeLock identity theft protection plan between January 1, 2012, and April 30, 2015, you are
a .

(1) Filing a claim online using your Claim
ID; or (2) Printing a Claim Form, filling it out and mailing it (with postage) to the address listed on the Claim Form. 
Subclass Members who do not exclude themselves from the settlement will
receive a cash payment regardless of whether they submit a claim, but will receive an additional payment under the Settlement if they
submit a valid claim. .
If you don’t want to be bound by the settlement and any judgment in the Lawsuit, you can exclude
yourself by sending a written request no later than [DATE]. If you exclude yourself, you won’t get a cash payment. If you don’t
exclude yourself and the settlement is approved, you will be bound by its terms and cannot later sue LifeLock about the claims in the
Lawsuit. If you don’t exclude yourself, you may object to the Settlement or the request for fees by the attorneys appointed by the
Court to represent the Class (“Class Counsel”) or any service award to any of the four individuals who represent the Class in the
Lawsuit (“Class Representatives”). Any objection must be made in writing and postmarked before [DATE]. The Court will hold a
hearing on [DATE], 2016, at [TIME], to consider whether to approve: (1) the settlement; (2) up to $10.2 million in attorneys’ fees and
expenses to Class Counsel; and (3) service awards of $2,000 to each Class Representative. You may appear at the hearing, but you
don’t have to. You may hire your own attorney to appear for you.

A federal court authorized this notice. This isn’t a solicitation from a lawyer. You aren’t being sued.
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