LifeLock 2015 Annual Report Download - page 304

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 146 of 289
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1. In consideration for the settlement benefits described in the Class Action Settlement Agreement (“Settlement Agreement”) to
which this General Release is an integral and material part, Jeanne Stamm (“Stamm”), on his own behalf and on behalf of his
administrators, representatives, and assigns, hereby completely fully, finally, and forever releases, relinquishes, acquits, and discharges
LifeLock, Inc. (“LifeLock”) and each of its respective present and former parents, subsidiaries, divisions, affiliates, predecessors,
successors, assigns, and insurers, including all of their insurers’ affiliates, predecessors, successors, assigns, and reinsurers, and the
respective agents, servants, attorneys, employees, officers, directors, shareholders, and representatives of the foregoing, and each of
them, and all of the present and former directors, officers, employees, agents, attorneys, and shareholders of LifeLock and each of
their present and former parents, subsidiaries, divisions, affiliates, predecessors, successors, and assigns (“Released Parties”), from 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, 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, which Stamm has, may
now have, or has ever had against any of the Released Parties, or any of them arising from or in any way connected with Stamm’s
relationship with LifeLock, as of the date of Stamm’s execution of this General Release including but not limited to claims that were
asserted in or arising from or that may have arisen from the same facts alleged in the matter entitled Ebarle, et al. v. LifeLock, Inc.,
Case No. 3:15-CV-00258 HSG, currently pending in the District Court for the Northern District of California (the “Action”). This
General Release covers all statutory, common law, constitutional, and other claims, including but not limited to:
(a) Any and all claims concerning the advertising of LifeLock’s identity theft protection services;
(b) Any and all claims concerning the advertising of LifeLock’s information security program;
(c) Any and all claims concerning LifeLock’s disclosures concerning the nature of its identity theft protection services;
(d) Any and all claims concerning LifeLock’s disclosures concerning the nature of its information security program;
(e) Any and all claims under California’s Unfair Competition Law, Cal. Bus. & Prof. Code § 17200, et seq., the Arizona
Consumer Fraud Act, A.R.S. § 44-1521, et seq., or any other applicable law or statute related to LifeLock’s advertising or
disclosures concerning its identity theft protection services or information security program;
(f) Any and all claims that LifeLock’s advertising or disclosures regarding LifeLock’s identity theft protection services or
information security program constituted a fraudulent, unlawful, unfair, or deceptive business practice, were
unconscionable, violated consumer protection statutes, and/or constituted a breach of contract and/or breach of the
covenant of good faith and fair dealing or unjust enrichment; and/or
(g) Any and all claims concerning any fact or circumstance that relates to LifeLock’s advertising or disclosures regarding its
identity theft protection services or information security program (collectively, the “Released Claims”).
This General Release described herein covers, includes, and is intended to include all remedies that could be sought for the Released
Claims including, but not limited to, statutory,
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