The Notice is given pursuant to an order issued by the Superior Court of the State of California, County of Los Angeles (the “Court”).  The Notice serves to inform you of the proposed settlement of a class action lawsuit (the “Settlement”) and the hearing (the “Final Approval Hearing”) to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement, as set forth in the Amended Stipulation of Settlement dated October 13, 2020 (the “Stipulation”).  The Stipulation is by and between: (i) Plaintiffs Joseph Iuso, Chenghsin D. Hsieh and Wei C. Hsieh, on behalf of themselves and each member of the Settlement Class (“Plaintiffs”); and (ii) Defendants Snap Inc. (“Snap” or the “Company”), Evan Spiegel, Robert Murphy, Andrew Vollero, Imran Khan, Joanna Coles, A.G. Lafley, Mitchell Lasky, Michael Lynton, Stanley Meresman, Scott D. Miller, and Christopher Young (collectively, the “Snap Defendants”), Morgan Stanley & Co. LLC, Goldman Sachs & Co. LLC, J.P. Morgan Securities LLC, Deutsche Bank Securities Inc., Barclays Capital Inc., Credit Suisse Securities (USA) LLC, and Allen & Company LLC (the “Underwriter Defendants”) (collectively, with the Snap Defendants, the “Defendants”), by and through their respective counsel of record in the case (the “Action”).  Upon and subject to the terms and conditions hereof, Plaintiffs on behalf of themselves and the Settlement Class on the one hand, and each of the Defendants, on the other hand (collectively, “Parties”), intend this Settlement to be a final and complete resolution of all disputes between the Parties with respect to the Action.  The Notice is not an expression of any opinion by the Court as to the merits of the claims or defenses asserted in the lawsuit.

    Currently pending before the Superior Court of the State of California, County of Los Angeles (the “Court”) are two coordinated class actions alleging securities law violations: (1) Hsieh v. Snap Inc., No. BC669394 (Cal. Super. Ct., Cty. of Los Angeles) (“Hsieh Action”); and (2) Iuso v. Snap Inc., No. 17CIV03710 (Cal. Super. Ct., Cty. of San Mateo) (“Iuso Action”).

    Plaintiffs Chenghsin D. Hsieh and Wei C. Hsieh commenced the Hsieh Action on July 25, 2017 in the Los Angeles Superior Court alleging violations of the Securities Act of 1933 (the “1933 Act” or “Securities Act”) for claims under §§11, 12(a)(2) and 15 against the Defendants.  The complaint in the Hsieh Action claims that Snap’s Registration Statement and Prospectus were false because they allegedly failed to disclose the following material information relating to Snap’s financial condition:  (1) Snap was experiencing slow growth in its Daily Active User rate and was being adversely affected by Instagram; (2) a purported whistleblower complaint, filed by former employee Anthony Pompliano, raised questions regarding false growth metrics used by Snap executives; and (3) Snap faced substantial liability in connection with a potential patent-infringement action by iFrame Canada Ltd. and its successors.  Plaintiffs claim that when the purportedly concealed information came to light between May and July 2017, Snap’s stock price declined to nearly $14.00 per share.

    On July 27, 2017, Defendants removed the Hsieh Action to the Federal Court.  On August 29, 2017, the Federal Court sua sponte remanded the Hsieh Action for lack of jurisdiction.

    On November 15, 2017, pursuant to the parties’ stipulation, the Court stayed the Hsieh Action pending the U.S. Supreme Court’s issuance of a decision in Cyan, Inc. v. Beaver County Employees Retirement Fund, No. 15-1439 (U.S.).  On March 20, 2018, the U.S. Supreme Court issued a decision in Cyan, holding that state courts have subject matter jurisdiction over class actions under the Securities Act.

    Following the issuance of the Cyan decision, Defendants moved to stay the Hsieh Action in favor of a similar but distinct action in Federal Court  or, in the alternative, to dismiss due to inconvenient forum based on Snap’s forum-selection clause.  The plaintiffs in the Hsieh Action opposed the motion.  By order dated August 16, 2018, the Court stayed the coordinated Hsieh Action pending the resolution of the Federal Action.

    On August 14, 2017, Joseph Iuso commenced the Iuso Action in San Mateo Superior Court.  The Iuso Action was brought as a class action on behalf of all persons who purchased Snap common stock pursuant or traceable to the IPO and alleged only violations of §11 of the Securities Act.  Moreover, unlike the Hsieh Action, the complaint in the Iuso Action focused solely on the Registration Statement’s purported misstatement of the stock-based compensation to be incurred by Snap following the IPO.

    On August 17, 2017, Defendants removed the Iuso Action to the United States District Court for the Northern District of California. On August 24, 2017, Iuso moved to remand.  On August 25, 2017, Defendants moved to transfer the Iuso Action to the United States District Court for the Central District of California.  Iuso did not oppose transfer and on September 27, 2017, the Iuso Action was transferred to the Central District of California.  On November 21, 2017, the Federal Court granted Iuso’s motion to remand the Iuso Action to San Mateo Superior Court.

    On December 19, 2017, Defendants petitioned the Judicial Council of California to coordinate the Hsieh Action with the Iuso Action.  On February 22, 2018, the Judicial Council granted the petition and ordered that both cases be coordinated in the Los Angeles Superior Court.  The coordinated proceeding was assigned to this Court under the caption Snap Inc. Securities Cases, JCCP No. 4960 (the “JCCP Proceeding”).

    On June 1, 2018, pursuant to the parties’ stipulation, the Court stayed the JCCP Proceeding pending litigation in the Delaware Court of Chancery, captioned Sciabacucchi v. Salzberg, No. 2017-0931, relating to the validity of mandatory forum-selection clauses in the Company’s certificate of incorporation with regard to Securities Act claims.

    On December 19, 2018, the Delaware Court of Chancery issued its decision in Sciabacucchi, finding forum-selection clauses in certificates of incorporation to be invalid and contrary to the federal regime to the extent they sought to regulate Securities Act claims.  See Sciabacucchi v. Salzberg, No. 2017-0931-JTL, 2018 Del. Ch. LEXIS 578, at *2-*4, *15 (Del. Ch. Dec. 19, 2018).  The Court of Chancery’s ruling was subsequently reversed by the Delaware Supreme Court.  Salzberg v. Sciabacucchi, No. 346 2019, 2020 Del. LEXIS 100, at *1 (Mar. 18, 2020).

    By order dated January 17, 2019, the Court vacated the stay in the JCCP Proceeding.  On February 19, 2019, Defendants filed a motion to stay the JCCP Proceeding in favor of the Federal Action.  Defendants also filed a demurrer to the complaint in the coordinated Iuso Action, seeking to dismiss the lawsuit.  On February 25, 2019, instead of opposing the demurrer on the merits, the plaintiff in the coordinated Iuso Action filed an amended complaint.  On April 10, 2019, the Court ordered the Iuso Action and JCCP Proceeding stayed until the next status conference set for July 29, 2019, and it extended the stay at subsequent status conferences.

    In September 2019, the parties in both this Action and in the Federal Action began mediation-related discussions and ultimately selected the Hon. Layn R. Phillips (Ret.) as the mediator.  On September 13, 2019, the parties submitted confidential mediation statements concerning the legal and factual issues in the two actions.

    On October 15, 2019, the parties participated in a full-day formal mediation conducted by the Hon. Layn R. Phillips.  Following the mediation session and additional negotiations amongst all parties, the mediator advised the parties on January 17, 2020, that all parties had accepted a mediator’s proposal.  The parties then entered into a Term Sheet on January 24, 2020.

    The Parties continued to negotiate the detailed terms of the Settlement of this Action, and these negotiations resulted in the agreement to settle all claims of the Settlement Class against the Defendants, i.e., the Stipulation entered into on October 13, 2020.  Plaintiffs’ Counsel believe that the claims asserted in the Action have merit and that the evidence developed to date in the Action supports the claims asserted therein.  However, Plaintiffs’ Counsel recognize and acknowledge the expense and length of continued proceedings, trial, and appeals, and have taken into account the uncertain outcome and the risk of any litigation, especially complex actions such as this.  Plaintiffs’ Counsel are also mindful of the inherent problems of proof under, as well as the defenses to, the federal securities law violations asserted in the Action, including the defenses asserted by Defendants.

    Plaintiffs’ Counsel believe that the Settlement set forth in the Stipulation confers a meaningful benefit upon the Settlement Class.  Plaintiffs’ Counsel have determined that the Settlement is in the best interests of the Settlement Class.

    The Parties acknowledge, and each of the Settlement Class Members shall be deemed by operation of law to have acknowledged, that the foregoing waiver was separately bargained for and a key element of the Settlement.

    THE COURT HAS NOT RULED AS TO WHETHER DEFENDANTS ARE LIABLE TO PLAINTIFFS OR TO THE SETTLEMENT CLASS.  THE NOTICE IS NOT INTENDED TO BE AN EXPRESSION OF ANY OPINION BY THE COURT WITH RESPECT TO THE TRUTH OF THE ALLEGATIONS IN THE ACTION OR THE MERITS OF THE CLAIMS OR DEFENSES ASSERTED.  THE NOTICE IS SOLELY TO ADVISE YOU OF THE PENDENCY OF THE ACTION AND PROPOSED SETTLEMENT THEREOF AND YOUR RIGHTS IN CONNECTION WITH THAT SETTLEMENT.

    The proposed Settlement affects the rights of the members of the Settlement Class.  The Settlement Class consists of:

All Persons and entities who purchased or otherwise acquired Snap common stock between March 2, 2017 and July 29, 2017, inclusive, and were damaged thereby.

    Excluded from the Settlement Class are Defendants, members of families of Defendants and their legal representatives, heirs, successors and assigns, and any entity in which Defendants have or had a controlling interest. Also excluded from the Settlement Class is any Person who validly requests exclusion pursuant to the requirements set forth in the Notice.

PLEASE NOTE:  Receipt of the Notice should not be construed as any indication of the Court’s view as to the merits of any claims or defenses asserted by any party to this Action.

    The complaint in the Hsieh Action claims that Snap’s Registration Statement and Prospectus were false because they allegedly failed to disclose the following material information relating to Snap’s financial condition:  (1) Snap was experiencing slow growth in its Daily Active User rate and was being adversely affected by Instagram; (2) a purported whistleblower complaint, filed by former employee Anthony Pompliano, raised questions regarding false growth metrics used by Snap executives; and (3) Snap faced substantial liability in connection with a potential patent-infringement action by iFrame Canada Ltd. and its successors.  Plaintiffs claim that when the purportedly concealed information came to light between May and July 2017, Snap’s stock price declined to nearly $14.00 per share.

    The Iuso Action was brought as a class action on behalf of all persons who purchased Snap common stock pursuant or traceable to the IPO and alleged only violations of §11 of the Securities Act.  Moreover, unlike the Hsieh Action, the complaint in the Iuso Action focused solely on the Registration Statement’s purported misstatement of the stock-based compensation to be incurred by Snap following the IPO.

    The Court has not reached any decisions in connection with Plaintiffs’ claims against Defendants.  Instead, Plaintiffs and Defendants have agreed to this Settlement, which was reached with the substantial assistance of the Hon. Layn R. Phillips (Ret.), a highly experienced mediator of complex class actions.  In reaching the Settlement, the Parties have avoided the cost, delay and uncertainty of further litigation.

    As in any litigation, Plaintiffs and the Settlement Class would face an uncertain outcome if they did not agree to the Settlement, and would have to overcome a variety of significant defenses anticipated to be interposed by Defendants.  The Parties expected that the case could continue for a lengthy period of time and that if Plaintiffs succeeded, Defendants would file appeals that would postpone final resolution of the case.  Continuation of the case against Defendants could result in a judgment greater than this Settlement.  Conversely, continuing the case could result in no recovery at all or a recovery that is less than the amount of the Settlement.

    Plaintiffs and Plaintiffs’ Counsel believe that this Settlement is fair and reasonable to the members of the Settlement Class.  They have reached this conclusion for several reasons.  Specifically, if the Settlement is approved, the Settlement Class will receive a significant monetary recovery.  Additionally, Plaintiffs’ Counsel believe that the significant and immediate benefits of the Settlement, when weighed against the significant risk, delay and uncertainty of continued litigation, are a very good result for the Settlement Class.

    As a Class Member, you are represented by Class Representatives and Class Counsel, unless you exercise your right to enter an appearance through counsel of your own choice and at your own expense. You are not required to retain your own counsel, the law firms of Robbins Geller Rudman & Dowd LLP, Bottini & Bottini, Inc., and Block & Leviton LLP represent Plaintiffs in the Action.  These lawyers are called Plaintiffs’ Counsel.  These lawyers will apply to the Court for payment of attorneys’ fees and expenses from the Settlement Fund; you will not be otherwise charged for their work.  If you want to be represented by your own lawyer, you may hire one at your own expense.

    Unless you exclude yourself, you will remain a member of the Settlement Class, and that means that you cannot sue, continue to sue, or be part of any other lawsuit against the Defendants about the same issues in the Action or about issues that could have been asserted in the Action.  It also means that all of the Court’s orders will apply to you and legally bind you and you will release your Plaintiffs’ Released Claims in this case against Defendants and the other Released Defendants’ Parties.  “Plaintiffs’ Released Claims” means Plaintiffs’ Claims, whether they are known claims or Unknown Claims (as defined below).  Plaintiffs’ Released Claims shall not include: (i) any claims relating to the enforcement of the Settlement; or (ii) any claims of any person or entity who or which submits a request for exclusion that is accepted by the Court.  “Plaintiffs’ Claims” means all claims, demands, rights, and causes of action, or liabilities of every nature and description, whether arising under federal, state, local, common, statutory, administrative, or foreign law, or any other law, rule, or regulation, at law or in equity, whether fixed or contingent, whether foreseen or unforeseen, whether accrued or unaccrued, whether liquidated or unliquidated, whether matured or unmatured, whether direct, representative, class, or individual in nature that (a) Plaintiffs or any other Settlement Class Member: (i) asserted in the Action and/or the Federal Action or (ii) could have asserted in any court or forum that arise out of or are based upon any of the allegations, transactions, facts, matters or occurrences, representations, or omissions set forth in the Action and/or the Federal Action; and (b) relate in any way to the purchase or other acquisition of Snap common stock during the Settlement Class Period.

    “Released Defendants’ Parties” means: (i) each Defendant and all underwriters of Snap’s IPO (including those not among the Underwriter Defendants ); (ii) each of their respective immediate family members (for individuals) and each of their direct or indirect parent entities, subsidiaries, related entities, and affiliates, any trust of which any individual Defendant is the settler or which is for the benefit of any Defendant and/or member(s) of his or her family; and (iii) for any of the entities listed in parts (i) or (ii), their respective past and present general partners, limited partners, principals, shareholders, joint venturers, members, officers, directors, managers, managing directors, supervisors, employees, contractors, consultants, auditors, accountants, financial advisors, professional advisors, investment bankers, representatives, insurers, trustees, trustors, agents, attorneys, professionals, predecessors, successors, assigns, heirs, executors, administrators, and any controlling person thereof, in their capacities as such, and any entity in which a Defendant has a controlling interest.

    “Unknown Claims” means any and all Plaintiffs’ Claims against the Released Defendants’ Parties which any Plaintiff or any member of the Settlement Class does not know or suspect to exist in his, her, or its favor at the time of their release of the Plaintiffs’ Claims (for the avoidance of doubt and consistent with the definition of Plaintiffs’ Claims, such claims are limited to those that (a) Plaintiffs or any other Settlement Class Member: (i) asserted in the Action or the Federal Action or (ii) could have asserted in any court or forum that arise out of or are based upon any of the allegations, transactions, facts, matters or occurrences, representations, or omissions set forth in the Action and/or the Federal Action; and (b) relate in any way to the purchase or other acquisition of Snap common stock during the Settlement Class Period), and any and all Defendants’ Claims against the Released Plaintiffs’ Parties which any Defendant does not know or suspect to exist in his, her, or its favor at the time of their release of the Defendants’ Claims, and including, without limitation, those that, if known by such Plaintiff, member of the Settlement Class or Defendant, might have affected his, her, or its decision(s) with respect to the Settlement or the releases, including his, her, or its decision(s) to object or not to object to the Settlement or to submit a Request for Exclusion.  With respect to any and all Defendants’ Released Claims and Plaintiffs’ Released Claims, the Parties stipulate and agree that, upon the Effective Date, the Parties shall expressly waive, and each of the Settlement Class Members shall be deemed to have waived, and by operation of the Judgment shall have waived any objection to the release of such claims.  Plaintiffs, any other Settlement Class Member, and Defendants may hereafter discover facts in addition to or different from those that he, she, or it now knows or believes to be true with respect to the subject matter of Plaintiffs’ Claims or Defendants’ Claims, but they stipulate and agree that, upon the Effective Date of the Settlement, Plaintiffs, any other Settlement Class Member, and Defendants shall expressly waive and by operation of the Judgment, or Alternative Judgment, if applicable, shall have, fully, finally, and forever settled and released, any and all Plaintiffs’ Claims or Defendants’ Claims, known or unknown, suspected or unsuspected, contingent or non-contingent, whether or not concealed or hidden, that now exist, or heretofore have existed, upon any theory of law or equity now existing or coming into existence in the future, including, but not limited to, conduct that is negligent, intentional, with or without malice, or a breach of fiduciary duty, law or rule, without regard to the subsequent discovery or existence of such different or additional facts.  The Parties acknowledge, and each of the Settlement Class Members shall be deemed by operation of law to have acknowledged, that the foregoing waiver was separately bargained for and a key element of the Settlement.

    THE COURT HAS NOT RULED AS TO WHETHER DEFENDANTS ARE LIABLE TO PLAINTIFFS OR TO THE SETTLEMENT CLASS.  THE NOTICE IS NOT INTENDED TO BE AN EXPRESSION OF ANY OPINION BY THE COURT WITH RESPECT TO THE TRUTH OF THE ALLEGATIONS IN THE ACTION OR THE MERITS OF THE CLAIMS OR DEFENSES ASSERTED.  THE NOTICE IS SOLELY TO ADVISE YOU OF THE PENDENCY OF THE ACTION AND PROPOSED SETTLEMENT THEREOF AND YOUR RIGHTS IN CONNECTION WITH THAT SETTLEMENT.

    To be eligible to receive a cash distribution from the Settlement Fund, you must timely complete, sign and submit a Proof of Claim and Release Form (“Proof of Claim”). A Proof of Claim may be downloaded on this website.  Only one Proof of Claim is required to participate in the settlements of both this Action and the Federal Action.  Read the instructions carefully, fill out the Proof of Claim, include all the documents the form asks for, sign it, and mail or submit it online so that it is postmarked (if mailed) or received (if filed electronically) no later than January 25, 2021.  The claim form may be submitted online on the File a Claim page of this website.  If you do not submit a valid Proof of Claim form with all of the required information, you will not receive a payment from the Net Settlement Fund; however, unless you expressly exclude yourself from the Settlement Class as described above, you will still be bound in all other respects by the Settlement, the Judgment, and the release contained in the Stipulation.

    Members of the Settlement Class who do not exclude themselves from the Settlement Class and who fail to submit a valid and timely Proof of Claim will nevertheless be bound by the Settlement if finally approved, and all orders and the judgment entered by the Court in connection therewith.  The Release will become effective on the Effective Date of the Settlement.

    Each person or entity submitting a Proof of Claim thereby submits to the jurisdiction of the Court for purposes of the Action, the Settlement and any proceedings relating to such Proof of Claim, and agrees that such a filed Proof of Claim will be subject to review and further inquiry as to such person’s or entity’s status as a member of the Settlement Class and the allowable amount of the claim.

Please Note: There is one Claim Form for both this Settlement and the Federal Settlement. Accordingly, if you submit a Claim Form, your claim will be processed in connection with both settlements. Please do not submit two Claim Forms.

    The Settlement Class in this Action, brought under the Securities Act of 1933, includes all Persons or entities who purchased or otherwise acquired Snap common stock pursuant or traceable to the Registration Statement and Prospectus (collectively, “Registration Statement”) issued in connection with Snap’s IPO and/or on the open market between March 2, 2017, and July 29, 2017, inclusive.  For example, Plaintiffs in this Action allege that the Registration Statement contained false and misleading statements omitting material facts regarding: (1) slow growth in Snap’s Daily Active User rate, which was being adversely affected by Instagram; (2) a whistleblower complaint filed by former employee Anthony Pompliano and its allegations that Snap executives were manipulating the Company’s growth metrics; and (3) substantial liability Snap faced in connection with a potential patent-infringement action by iFrame Canada Ltd. and its successors.  Moreover, this Action asserts damages under the 1933 Act based on the price investors paid for Snap’s stock in the IPO, $17 per share.  By contrast, the Federal Action is brought on behalf of all purchasers of Snap common stock between March 2, 2017 and August 10, 2017, inclusive, including those who purchased stock traceable to the Registration Statement. The Federal Action asserts damages under the 1933 Act based on a different theory related to the value of Snap as of the IPO, as well as damages under the Securities Exchange Act of 1934, and includes allegations of false statements outside the Registration Statement.  Investors can recover the sum of different amounts as a result of the settlement of each action.  Nevertheless, while there are differences between the two actions, Settlement Class Members in this Action must only submit one claim form to recover in both cases.

    INVESTORS MUST ONLY SUBMIT ONE CLAIM FORM TO RECOVER IN BOTH THIS ACTION AND THE FEDERAL ACTION

    Although there are differences between this Action and the Federal Action, including the alleged false statements, legal claims, damages theories, and recoveries, investors nonetheless may be entitled to recover from both the Settlement in this Action and the settlement in the Federal Action.  For the sake of simplicity and efficiency, there is a single, identical claim form for both this Action and the Federal Action. Settlement Class Members in this Action must only submit one claim form to recover in both cases.

    At this time, it is not possible to make any determination as to how much any individual Class Member may receive from the Settlement.

    Your share of the Net Settlement Fund will depend on the number of valid Proofs of Claim that Settlement Class Members send in and how many shares of Snap common stock you purchased or otherwise acquired during the relevant period and when you bought and sold them.

    The $32,812,500.00 Settlement Amount and any interest earned thereon shall be the Settlement Fund.  The Settlement Fund less taxes, tax expenses, notice and claims administration expenses, approved attorneys’ fees and expenses as well as any awards to the Plaintiffs (the “Net Settlement Fund”) shall be distributed to members of the Settlement Class who submit valid Proofs of Claim (“Authorized Claimants”).

    The Claims Administrator shall determine each Authorized Claimant’s pro rata share of the Net Settlement Fund based upon each Authorized Claimant’s “Recognized Loss.” The Recognized Loss formula is not intended to be an estimate of the amount of what a Settlement Class Member lost or might have been able to recover after a trial; nor is it an estimate of the amount that will be paid to Authorized Claimants pursuant to the Settlement.  The Recognized Loss formula is simply the basis upon which the Net Settlement Fund will be proportionately allocated to Authorized Claimants.

    The Stipulation may be terminated under several circumstances outlined in it.  If the Stipulation is terminated, the Action will proceed as if the Stipulation had not been entered into.

    Plaintiffs’ Counsel will file a motion for an award of attorneys’ fees and expenses that will be considered at the Final Approval Hearing.  Plaintiffs’ Counsel will apply for an award of attorneys’ fees in the amount of one-third of the Settlement Amount, plus payment of expenses incurred in connection with the Action in an amount not to exceed $400,000.  Such sums as may be approved by the Court will be paid from the Settlement Fund.  Settlement Class Members are not personally liable for any such fees or expenses.

    The attorneys’ fees and expenses requested will be the only payment to Plaintiffs’ Counsel for their efforts in achieving this Settlement and for their risk in undertaking this representation on a wholly contingent basis.  Plaintiffs’ Counsel have committed significant time and expenses in litigating this case for the benefit of the Settlement Class.  To date, Plaintiffs’ Counsel have not been paid for their services in conducting the Action on behalf of the Plaintiffs and the Settlement Class, or for their expenses.  The Court will decide what constitutes a reasonable fee award and may award less than the amount requested by Plaintiffs’ Counsel.  The requested fees and expenses, if approved, would represent, on average, no more than $0.18 per share in the aggregate.  In addition, Plaintiffs’ Counsel intend to apply to the Court on behalf of Plaintiffs for an award pursuant to 15 U.S.C. §77z-1(a)(4) in connection with their representation of the Settlement Class.  Plaintiffs’ Counsel will seek no more than $5,000 each for Plaintiffs. Class Members are not personally liable for any such attorneys’ fees or expenses.

    If you want to keep the right to sue or continue to sue Defendants on your own about the legal issues in the Action, then you must take steps to get out of the Settlement Class.  This is called excluding yourself from, or “opting out” of, the Settlement Class.  If you are requesting exclusion because you want to bring your own lawsuit based on the matters alleged in this Action, you may want to consult an attorney and discuss whether any individual claim that you may wish to pursue would be time-barred by the applicable statutes of limitation or repose.

    To exclude yourself from the Settlement Class, you must send a letter by mail saying that you want to be excluded from the Settlement Class.  Be sure to include your name, address, telephone number, and sign the letter.  You should also include the number of shares of Snap common stock you purchased or acquired that are subject to the Action, including the number of shares of Snap common stock that you purchased/acquired and/or sold during the Settlement Class Period, as well as the dates, number of shares, and prices of each such purchase/acquisition and sale.  Your exclusion request must be postmarked no later than January 25, 2021 and sent to the Claims Administrator at:

Snap Securities Litigation
Claims Administrator
c/o JND Legal Administration
P.O. Box 91314
Seattle, WA 98111

    You cannot exclude yourself by phone or by e-mail.  If you make a proper request for exclusion, you will not receive a Settlement payment, and you cannot object to the Settlement.  If you make a proper request for exclusion, you will not be legally bound by anything that happens in this lawsuit.

    Excluding yourself from the Class in this Action does not automatically exclude you from the class in the Federal Action. If you would like to exclude yourself from the Federal Class, you must do so in accordance with the instructions set forth in the notice for the Federal Settlement available here.

    Attendance at the Final Approval Hearing is not necessary; however, if you wish to be heard orally at the Final Approval Hearing please indicate in your written objection your intention to appear at the hearing.

    Please Note: The date and time of the Settlement Hearing may change without further written notice to the Class. It is also within the Court’s discretion whether to hold the hearing in person or telephonically. If you plan on attending the hearing, please check this website, or contact Class Counsel to confirm that the date and/or time of the hearing has not changed.

    The Settlement Hearing will be held on March 26, 2021 at 9:00 a.m., before the Honorable Elihu M. Berle either telephonically or in person at the Superior Court of the State of California, County of Los Angeles, 312 North Spring Street, Los Angeles, CA. for the purpose of determining whether: (1) the Settlement of the Action for $32,812,500.00 in cash should be approved by the Court as fair, reasonable and adequate; (2) to award Plaintiffs’ Counsel attorneys’ fees and expenses out of the Settlement Fund; and (3) the Plan of Allocation should be approved by the Court.  The Court may adjourn or continue the Final Approval Hearing without further notice to members of the Settlement Class.  You should check this website, for further details on the Final Approval Hearing.

    Any Settlement Class Member may appear at the Final Approval Hearing and be heard on any of the foregoing matters.  Any written objection should be mailed to:

Snap Securities Litigation
Claims Administrator
c/o JND Legal Administration
P.O. Box 91314
Seattle, WA 98111

together with proof of membership in the Settlement Class, so that it is postmarked no later than January 25, 2021.

    In addition, you may contact Rick Nelson, Shareholder Relations, Robbins Geller Rudman & Dowd LLP, 655 West Broadway, Suite 1900, San Diego, CA 92101, 1-800-449-4900, if you have any questions about the Action or the Settlement.

    If you hold any Snap common stock purchased or otherwise acquired between March 2, 2017 and July 29, 2017, inclusive, as a nominee for a beneficial owner, then, within ten (10) days after you receive the Notice, you must either: (1) send a copy of the Postcard Notice by First-Class Mail to all such Persons; or (2) provide a list of the names and addresses of such Persons to the Claims Administrator:

Snap Securities Litigation
Claims Administrator
c/o JND Legal Administration
P.O. Box 91314
Seattle, WA 98111
1-855-958-0630
info@SnapSecuritiesLitigation.com
www.SnapSecuritiesLitigation.com

    If you choose to mail the Postcard Notice yourself, you may obtain from the Claims Administrator (without cost to you) as many copies of the Postcard Notice as you will need to complete the mailing.

    Regardless of whether you choose to complete the mailing yourself or elect to have the mailing performed for you, you may obtain reimbursement for or advancement of reasonable administrative costs actually incurred or expected to be incurred in connection with forwarding the Postcard Notice and which would not have been incurred but for the obligation to forward the Postcard Notice, upon submission of appropriate documentation to the Claims 

    The records in the Action may be examined and copied at any time during regular office hours, and subject to customary copying fees, at the Clerk of the Superior Court of the State of California, County of Los Angeles, 111 North Hill Street, Los Angeles, CA 90012.  In addition, all of the Settlement documents, including the Stipulation, the Proof of Claim form and proposed Judgment may be obtained online on the Important Documents page of this website or by contacting the Claims Administrator at:

Snap Securities Litigation
Claims Administrator
c/o JND Legal Administration
P.O. Box 91314
Seattle, WA 98111
1-855-958-0630
info@SnapSecuritiesLitigation.com
 

    In addition, you may contact Rick Nelson, Shareholder Relations, Robbins Geller Rudman & Dowd LLP, 655 West Broadway, Suite 1900, San Diego, CA 92101, 1-800-449-4900, if you have any questions about the Action or the Settlement.

DO NOT WRITE TO OR TELEPHONE THE COURT FOR INFORMATION