Common use of Class Notice Clause in Contracts

Class Notice. 28. The parties agree to the following provisions for Class Notice, subject to Court approval. Within twenty-one (21) days of execution of the Settlement Agreement, DMC shall provide Plaintiffs with a current list of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the Court, the Claims Administrator shall mail a Court-approved form of Class Notice by first class mail postage prepaid to each member of the Class on the Class List (defined below) as updated through the National Change of Address database. If a Class Notice is returned as undeliverable, and the USPS provides a forwarding address, the Claims Administrator shall resend the Class Notice to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 2810.1. The parties agree to the following provisions for Class Notice, subject to Court approval. Within twenty-one (21) days of execution of the Settlement Agreement, DMC shall provide Plaintiffs with a current list of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the Court, the Claims Administrator shall mail a Court-approved form of Class Notice disseminate, by first class mail postage prepaid to each member mail, a copy of the Notice of Class on Action Settlement substantially in the form attached hereto as Exhibit I (the “Class Notice”), to every Class Member who is reasonably ascertainable from Transurban’s databases. The initial mailing to the Class List (defined below) as updated through the National Change of Address database. If a Class Notice is returned as undeliverable, and the USPS provides a forwarding address, the Claims Administrator shall resend the Class Notice to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice Members shall be resent to the potential Class Member completed, at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is sole expense of Transurban, not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry Court orders preliminary approval of an order approving the final distribution Settlement. The Settlement Administrator shall update mailing addresses with the NCOA database prior to the initial mailing. If any Class Notice is returned to the Settlement Administrator as undeliverable by the U.S. Postal Service and a forwarding address is provided, the Settlement Administrator will promptly re-mail such Class Notice to the forwarding address. If any Class Notice is returned to the Settlement Administrator as undeliverable by the U.S. Postal Service with no forwarding address, the Settlement Administrator shall promptly perform further reasonable address research and promptly re-mail such Class Notice to the new address (if any) identified by the Settlement Administrator. 10.2. The deadline by which objections to the Agreement and requests for exclusion from the Settlement Class are due shall not be less than forty-five (45) days after the initial mailing to the Class Members is complete. 10.3. The Settlement Administrator shall maintain a website dedicated to the settlement (“Settlement Website”) and a toll-free customer service number that Class Members may call. The Class Notice shall include the address (URL) of the Settlement FundWebsite and the toll-free number. Plaintiffs The Settlement Administrator shall update maintain the Settlement Website and toll- free number at least until nine (9) months following the Claim Submission Deadline, after which time the Settlement Administrator may direct Class Members to Class Counsel. 10.4. The Settlement Website shall enable Class Members to access and download the Class Notice and Claim Form and will provide answers to frequently asked questions (FAQs). The Parties will agree upon the form and functionality of the Settlement Website. 10.5. The toll-free number shall allow Class Members to request copies of the Class Notice and Claim Form by mail, provide updated address information, and ask questions concerning the Settlement and the process for obtaining the relief available to them pursuant to this website to reflect Agreement. 10.6. The Class Notice shall provide a procedure whereby Class Members may exclude themselves from the current status Settlement Class by mailing a request for exclusion. Any Class Member who does not timely and validly request exclusion shall be a Settlement Class Member and shall be bound by the terms of this settlementAgreement. 3210.7. The Class Notice shall also provide a procedure for Class Members to object to the Settlement set forth herein, the attorneys’ fees and expenses for which Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of will petition the Court, and/or the Service Awards. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 28Notice of the settlement shall be provided to the Settlement Class. The parties Parties believe and agree that the proposed procedures for notice provide the best practicable notice to the following provisions Settlement Class: a. The Claims Administrator shall be responsible for preparing, printing and mailing to all Settlement Class NoticeMembers the Class Notice and Claim Form attached to this Settlement Agreement as directed by the Court. b. No later than the date specified in the Implementation Schedule, subject Defendant shall provide to Court approval. Within twentythe Claims Administrator the last-one (21) days of execution known addresses, telephone numbers, and social security numbers of the Settlement AgreementClass Members. c. In order to provide the best notice practicable, DMC shall provide Plaintiffs with a current list of the names and addresses of members of Claims Administrator will do the following before mailing the Class Notice and Claim Form: (in electronic form, if available1) who worked at DMC during run this class list through the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees United States Postal Service’s National Change of Address database (“Updated Address ListNCOA”). DMC shall also provide ) and (2) perform address searches using public and proprietary electronic resources which collect their data from various sources such as soon as possibleutility records, property tax records, motor vehicle registration records (where allowed) and no credit bureaus. d. No later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of date specified in the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the CourtImplementation Schedule, the Claims Administrator shall mail send a Court-approved form of Class Notice by first class mail postage prepaid to each member copy of the Class on Notice substantially in the form attached hereto as Exhibit A, and a Claim Form substantially in the form attached hereto as Exhibit B, to all members of the Settlement Class via first-class mail, postage prepaid, using the most current mailing address information available as set forth above. e. Any Class Notice returned to the Claims Administrator as non-delivered before the deadline set forth in the Implementation Schedule for Class Members to mail Claim Forms shall be sent to the forwarding address affixed thereto. If no forwarding address is provided for a Class Notice that is returned as non-delivered, then such Class Notices will be re-sent by the Claims Administrator after the address is updated using reasonable efforts. The undelivered Class Notices will be re-sent within five days after the Claims Administrator receives notice that the Class List Notice was undeliverable. The Claims Administrator shall also call last-known telephone numbers (defined below) as and telephone numbers updated through the National Change public and proprietary databases) of Address database. If a Settlement Class Members whose Class Notice is returned as undeliverable, and the USPS provides non-delivered to attempt to obtain their current addresses. For a forwarding address, the Claims Administrator shall resend the Class Notice period not to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 exceed 45 days from the date specified in the Claims Administrator anticipates completion of Implementation Schedule for the initial mailing of the Class Notice (without regard and Claim Form, the Claims Administrator will continue to use reasonable efforts to obtain current addresses for Settlement Class Members whose Class Notice and Claim Form are returned envelopesas non-deliverable, and Claim Forms received within said 45-day period shall be deemed timely. f. The objection deadline shall not be extended pro-rata for members of the Settlement Class whose original notices are re-mailed pursuant to Paragraph 15(e). Because notice of certification . g. The Claims Administrator shall send a reminder postcard, based on the language of the Class was providedNotice, in accordance with Federal Rule to all Settlement Class Members who have not submitted Claim Forms, Notices of Civil Procedure 23(c)(2)Objection, and the deadline or Requests for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business Exclusion on or about 21 days after the mailing of the notice. h. No Settlement Class Notice, Plaintiffs Member shall post on have the already established Class right to obtain any payment through this Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) Agreement unless the Class Notice; (ii) Member submits a completed Claim Form, signed under penalty of perjury, on or before the deadline set forth in the Implementation Schedule, except that the Claims Administrator shall make use of the $50,000 held back from the Gross Settlement Amount to pay Settlement Awards to Settlement Class Members who submit a Claim Form containing all the necessary information within six months of the date of Final Approval of the Settlement Agreement; (iii) . In addition, the Preliminary Approval Order as entered Claims Administrator, upon agreement by the Court; (iv) information as all counsel, may determine that there is good cause to extend the date and time of the final approval hearingfor mailing a particular Claim Form, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel may find good cause to extend the date for mailing a particular Claim Form, or the parties; (vii) notification of Class Members’ right Parties may agree that there is good cause to be represented at extend the final approval hearing by counsel of their own choosing, at their own expense, and the deadline date for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for mailing a period of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.particular Claim Form

Class Notice. 281. The parties agree to After the following provisions Court’s Preliminary Approval of this Agreement and appointment of the Settlement Administrator, the Settlement Administrator shall be responsible for disseminating the Class Notice, subject substantially in the form as described in the Notice Plan that will be attached to Court approvalthe motion for Preliminary Approval, as specified in the Preliminary Approval Order, and as specified in this Agreement. 2. Within twenty-one Notice will be provided to the Class Members directly, first via email and then if necessary via mail, using the Class List. Where practicable, each Class Member will receive notice at least once through either channel. 3. Dissemination of the Class Notice shall commence within twenty (2120) business days following the Court’s Preliminary Approval of execution this Agreement and appointment of the Settlement Agreement, DMC shall provide Plaintiffs Administrator. 4. Notice will first be emailed to Class Members with a current list valid email address on the Class List. 5. For all Class Members for whom the email notice was returned undeliverable or for whom an email address was not available on the Class List, they will receive mailed notice via a postcard. The reverse side of the names postcard shall contain a Claim Form with return postage. 6. Mailed Notice shall be mailed to each Class Member at their last known mailing address as provided by Defendants, and as updated by the Settlement Administrator using the U.S. Postal Service’s database of verifiable mailing addresses (the CASS database), the National Change-of-Address database, and/or other databases readily available to the Settlement Administrator. 7. Where practicable, the Mailed Notice will include an indication that it is a “Class Action Settlement Notice authorized by the Court in Xxxxxxxx v. Telecom Evolutions, LLC, et al., Los Angeles Superior Court, Case No. 18STCV08068”, and may also include a bar code. 8. For all Mailed Notices returned to the Settlement Administrator undeliverable, the Settlement Administrator will also use available databases as practicable to update the addresses of members of the Settlement Class (in electronic form, if available) and will resend to such members who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery can be located. 9. The Settlement Administrator will also have published a 1/4 page Short Form Notice—or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than thirty (30) days after Preliminary Approval substantially similar—of the Settlement Agreement, Social Security Numbers in the Los Angeles Edition of USA Today for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Orderfour consecutive weeks. 2910. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the Court, the Claims Administrator shall mail a Court-approved form of Class Notice by first class mail postage prepaid to each member of the Class on the Class List (defined below) as updated through the National Change of Address database. If a Class All Notice is returned as undeliverable, and the USPS provides a forwarding address, the Claims Administrator shall resend the Class Notice to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least completed within sixty (60) calendar days after following the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status Court’s Preliminary Approval of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 2853. The parties agree to As soon as practicable after the following provisions for Class Notice, subject to Court approval. Within twenty-one (21) days of execution preliminary approval of the Proposed Settlement Agreementas provided in Paragraph 45, DMC Defendants shall provide Plaintiffs make a reasonable search of their computer/electronic databases to ascertain the name, last-known address, and if previously provided to USAA, the most-recently provided email address of each potential Settlement Class Member (if the Settlement Class Member has provided Defendants with a current list an email address for use in communications as reflected in Defendants’ records of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”email addresses). DMC shall also provide as soon as possiblePrior to mailing the Mailed and Emailed Notice and Claim Form, and no later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the Court, the Claims Administrator shall mail a Court-approved form of Class Notice by first class mail postage prepaid to each member of run the Class on the Class List (defined below) as updated physical mailing addresses once through the National Change of Address databaseDatabase (“NCOA”) to attempt to obtain a more current name and/or physical mailing address for each potential Settlement Class Member. The Settlement Administrator may also perform such further reasonable search for a more current name and/or physical mailing address for the potential Settlement Class Member, including potentially an Experian search or skip tracing, to the extent the Settlement Administrator determines in its sole discretion that a physical mailing address provided to it may not be accurate. The Settlement Administrator will not perform any searches for additional e-mail addresses for potential Settlement Class Members, but will use only e-mail addresses provided by Defendants. The Settlement Administrator shall: (a) send a copy of the Mailed Notice and a Claim Form by first-class mail to each potential Settlement Class Member identified as a result of the above search(es); and (b) send an Emailed Notice with a link to the settlement website (which will contain a prominent button titled “Make a Claim” to access a pre-filled Electronic Claim Form by use of Claimant ID and USAA Member last name) to each potential Settlement Class Member identified as a result of the above search(es). The Emailed Notice shall be without material alteration from Exhibit 3 hereto. The Settlement Administrator will utilize its standard procedures, including notifying web-based email providers, to increase the likelihood that the Emailed Notice will be received by Settlement Class Members and not treated by e-mail systems as spam. Defendants and the Settlement Administrator shall use their best efforts to complete the mailing of the Mailed and Emailed Notice and Claim Form to potential Settlement Class Members within forty-five (45) days after entry of the Preliminary Approval Order. The Settlement Administrator shall report to Class Counsel and Defendants the number of emails sent to Class Members and the dates that such emails were sent. 54. If a any Mailed Notice and/or Claim Form mailed to any potential Settlement Class Member in accordance with Paragraph 53 is returned to the Settlement Administrator as undeliverable, the Settlement Administrator will promptly log each Mailed Notice and/or Claim Form that is returned as undeliverable, undeliverable and provide copies of the USPS provides log to Defendants and Class Counsel as requested. The Settlement Administrator will not log or re-send any e-mails that are returned by any e-mail system or automated reply. If the mailing is returned to the Settlement Administrator with a forwarding address, the Claims Settlement Administrator shall resend forward the Class Notice mailing to that address. For the potential Class Member using remaining returned mailings, the corrected Settlement Administrator will conduct an updated NCOA database search, Experian search and, if those searches are unsuccessful, use skip tracing to identify a new address provided by and those mailings shall be forwarded to any new address obtained through such a search. In the USPS. If a Class event that any Mailed Notice is returned as undeliverable a second time, no further mailing shall be required. It is agreed by the USPS without a forwarding addressParties that the procedures set forth in the preceding Paragraph and this Paragraph constitute reasonable and the best practicable notice under the circumstances and an appropriate and sufficient effort to locate current addresses for Settlement Class Members such that no additional efforts to do so shall be required. Upon request, Defendants and the Settlement Administrator shall provide Class Counsel such reasonable access to the notice process as they may need to monitor compliance with the notice campaign. 55. The envelope on the Mailed Notice shall reference “Xxxxxxx et al. v. USAA et al.” and “USAA Florida Auto Sales Tax Class Action Notice.” 56. The Settlement Administrator shall establish the website XXXXXxxxxxxXxxxXxxxxXxxXxxxxxxxxx.xxx for the settlement and post the Agreement, Mailed Notice, Claim Form, Electronic Claim Form, Preliminary Approval Order, and frequently asked questions; the website may be amended from time to time as agreed to by the Parties. The website shall also contain Spanish translations of the Mailed Notice and Claim Form. The Settlement Administrator shall maintain the website for at least 180 days after expiration of the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more Submission Deadline. The home page of the nationally recognized credit reporting agencies website shall have a prominent “Make A Claim” button permitting a Class Member to access a pre- filled Electronic Claim Form by providing Claimant ID and USAA Member last name, with a method to submit the Electronic Claim Form with an electronic signature, and a method (such as Equifax, TransUnion, by use of Claimant ID or ExperianUSAA Member Number and USAA Member last name) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion request that another copy of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for optpre-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearing, including any changes to such hearing time filled paper Claim Form be mailed or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating emailed to the Settlement or distribution Class Member. A class member will also be able to request another copy of the pre-filled paper Claim Form from the Settlement FundAdministrator by telephone or e-mail. 57. The Mailed Notice and Claim Form, along with Spanish translations of those documents, will also be made available to all potential Settlement Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry of an order approving the final distribution of Members by request to the Settlement Fund. Plaintiffs Administrator, who shall update this website to reflect send via first- class U.S. mail any of these documents as requested from the current status of this settlementSettlement Administrator by any potential Settlement Class Member. 3258. Class Counsel The Settlement Administrator shall take all necessary and appropriate steps maintain a toll-free VRU telephone system containing recorded answers to ensure that notice of the settlement hearing is provided frequently asked questions, along with an option permitting callers to Class Members speak to live operators or to leave messages in accordance with this Settlement Agreement and the orders of the Courta voicemail box. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 28. The parties agree (A) Within five (5) days after the Court issues its Order Granting Preliminary Approval, Defendants or Class Counsel, will provide the designated Claims Administrator with a list of the names, last known addresses, last known telephone numbers, and dates of employment of all Class Members to the following provisions for Class Notice, subject to Court approval. extent that these records are available. (B) Within twenty-one ten (2110) days of execution of the Settlement Agreement, DMC shall provide Plaintiffs with a current list of the names and addresses of members of receiving the Class (Member list referenced in electronic form, if availableSection 2.3(A) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the Courtabove, the Claims Administrator shall mail a mail, via First Class United States mail, postage prepaid, the Court-approved form of Class Notice by first class mail postage prepaid and Claim Form (Exhibits “A” and “B”) to each member all Class Members with mailing addresses using the last known addresses set forth in Defendants’ records. The Claims Administrator shall take reasonable steps, including a skip-trace to obtain the correct addresses of the Class on Members for whom the Class List (defined notices are returned by the post office as “undeliverable” and shall attempt re- mailings as described below) as updated through the National Change of Address database. If the Claims Administrator receives notice of a Class Notice is returned mailing as undeliverable, and the USPS provides a forwarding address, the Claims Administrator shall resend the Class Notice to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than it has five (5) business days to attempt to locate an alternative address and issue a second mailing. The Claims Administrator shall notify Class Counsel and Defendants’ Counsel of any mail sent to Class Members that is returned as undeliverable after the first mailing as well as any such mail returned as undeliverable after any subsequent mailing(s) as set forth in Section 2.4. Defendants shall have no further obligation to search for Class Members who are former employees for whom the notice is returned because the last known address on file with Defendants is no longer current. The Claims Administrator shall provide all parties with information related to the administration of the settlement upon request. The Notice will also be published on the Claims Administrator’s publicly available website where a copy of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order Notice and Claim Form will be available as entered by the Court; (iv) information as to the date and time of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expensePDF downloads, and the deadline for notification of any intent to appear and request to Class Notice text will be heard at presented in HTML.‌‌ (C) On or about the final fairness hearing; (viii) same day as the Complaint; (ix) when availablepublication by mailing is effectuated, Class Counsel’s Plan Counsel shall publish a notice (“Newspaper Notice”) in a newspaper of Allocation local circulation such as AM New York or Metro NY. The notice shall be published on the first, third and any orders relating thereto; and fifth weeks of the notice period. (xD) any other document The Notice Response Deadline to file a Claim Form, opt-out of the settlement or notification relating object to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site settlement shall be maintained for a period of at least sixty (60) calendar days after from the entry of date that the Claims Administrator mails the Class Notice via USPS first class mail. This Notice Response Deadline shall be extended an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of additional fifteen (15) days for extraordinary circumstances, such as documented hospitalization, military service, unreported relocation, or as otherwise directed by the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 28. The parties agree Class Counsel are responsible for selecting a claims administrator to provide and administer notice of the proposed Settlement to the following provisions for Settlement Class NoticeMembers, subject and as such, Class Counsel were hereby authorized to Court approvalretain [INSERT NAME] as Claims Administrator. Within twenty-one (21) days of execution Subject to the direction and approval of the Settlement Agreement, DMC shall provide Plaintiffs with a current list of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the CourtEscrow Agent, the Claims Administrator shall mail pay from the Fund the costs and expenses reasonably and actually incurred in connection with providing notice to Settlement Class Members, mailing the Postcard Notice and establishing and maintaining a Court-approved website containing the Long Form Notice and Proof of Claim, and publishing Summary Notice, assisting with the filing of claims, administering and distributing the Net Settlement Fund to Authorized Claimants, processing Proofs of Claim and Releases, and paying escrow fees and costs, if any, and the administrative expenses incurred and fees charged by the Claims Administrator in connection with providing notice and processing the submitted claims (together, the “Notice and Administration Costs”). All Notice and Administration Costs shall be paid from the Common Fund. In the event that the Settlement does not become final, any money paid or incurred for the above purposes shall not be returned or repaid to Nationstar or its insurers. Postcard Notice shall be provided to each Class Member’s last known address, as provided by a national change of address database update search. This form of notice is sufficient and any Class Notice by first class mail postage prepaid to each Member who does not timely submit a claim form shall not receive a distribution from the Class Recovery or Subclass Recovery, but will otherwise remain a member of the Class on the Class List (defined below) for all other purposes of this Agreement and settlement. No skip-tracing shall be required or done as updated through the National Change of Address database. If a Class Notice is returned as undeliverable, and the USPS provides a forwarding address, the Claims Administrator shall resend the Class Notice to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is any Postcard Notices that are returned by the USPS without postal service as undeliverable and with no forwarding address. Postcard Notices returned with a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice address shall be resent re-mailed to the potential Class Member at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than new address within five (5) business days after the mailing days. The Parties will notify each other within a reasonable amount of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearingreceipt of any objection to this Agreement received from a member of the Class. Class Members, including any changes subject to such hearing time the Court's approval, shall have forty-five (45) days in which to return a claim form or place received by the Claims Administrator file an objection. Class Counsel shall, at least five ten (510) business days prior to before the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed Final Approval Hearing, file with the Court an appropriate affidavit or declaration regarding preparation and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period Postcard Notice, website, Long Form Notice, Proof of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlementClaim and Release, and Summary Notice. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 28. The parties agree to the following provisions for Class Notice, subject to Court approval. Within twenty-one (21) days of execution of the Settlement Agreement, DMC Direct Mail Notice shall provide Plaintiffs with a current list of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information be provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and practicable after entry of an Order of Preliminary Approval by the Court, the Claims Administrator shall mail a Court-approved form of Class Notice by first class mail postage prepaid to each member of the Class on the Class List (defined below) as updated through the National Change of Address database. If a Class Notice is returned as undeliverable, and the USPS provides a forwarding address, the Claims Administrator shall resend the Class Notice to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearingOrder, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least but in no event later than sixty (60) days after the following entry of an order approving such Order, as follows: a. Direct Mail Notice, substantially in the final distribution forms attached hereto as Exhibit D1 and D2 that is approved by the District Court, will be mailed, via first class mail, to Settlement Class Members at the most recent address shown in HSBC’s electronic records, as maintained in the ordinary course of business, for the loan at issue. The D1 form of Direct Mail Notice will be sent to those Settlement Class Members who, based on the HSBC Defendants’ records, appear to be eligible to make claims. The D2 form of Direct Mail Notice will be sent to those Settlement Class Members who, based on the HSBC Defendants’ records, appear eligible for other forms of relief under the Settlement. A Spanish translation of the Settlement Fund. Plaintiffs shall update this website to reflect class notice will be printed on the current status of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice reverse side or at the end of the settlement hearing is provided to Class Members in accordance notice. Addresses will be run once through the NCOA system and returned notices will be remailed if they are returned with this Settlement Agreement and the orders a postmark date within twenty-five (25) days of the Court. 33postmark date of the Direct Mail Notice and contain a forwarding address. DMC HSBC Defendants shall have no liability responsibility with respect to Direct Mail Notices that are returned undeliverable. b. The D1 form of Direct Mail Notice shall include a claim form substantially in the giving form attached hereto as Exhibit E that is approved by the District Court. If Mortgage Services does not own and actively service the Decision One Borrower’s loan(s) at the time of settlement administration, the Decision One Borrower must fully complete the claim form and return it in order for the claim form to be deemed submitted. The deadline for the submission of the claim form shall be a postmark date that is no later than one hundred and five (105) days after entry of the Preliminary Approval Order, and the Settlement Administrator will have no obligation to honor any claim form returned after that date. Although there is no obligation to accept any late claim forms, late claim forms may be accepted with the consent of HSBC Defendants and Class Counsel, if received before the settlement becomes Final and only if acceptance of the claim form would not trigger proration pursuant to Section 3.4(d) above, taking into consideration anticipated further costs and expenses of settlement administration. c. The notice provided for and claims process shall be administered, in this whole or in part, either by HSBC Defendants or by a mutually agreed-upon Settlement Agreement.Administrator, and all valid claims will be paid. Twenty

Class Notice. 28. The parties agree to the following provisions for Class Notice, subject to Court approval. Within twenty-one (21) days of execution of the Settlement Agreement, DMC shall provide Plaintiffs with a current list of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as As soon as possible, and no later than thirty (30) days practicable after Preliminary Approval of the Settlement AgreementProposed Settlement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty but in any event no more than fifteen (2015) days of receipt of the Updated Address List and after entry of an Order of the Preliminary Approval by Order, Defendants shall conduct a reasonable search of their records and provide to the CourtAdministrator for each Person reasonably believed to be a potential Class Member, the Claims following information, if reasonably available: name, last known mailing address, date of Covered Loss during the Class Periods, policy number, claim number for the Covered Loss, and data from Xactimate estimates for each such Person’s claims within the Class Periods showing replacement cost value of the Covered Loss, Depreciation as calculated by estimates, and ACV Payments, as well as any other information reasonably required to administer the Settlement. 5.3 The Administrator shall mail a Court-approved form of Class Notice by first class mail postage prepaid to each member copy of the Class on Notice and Claim Form in a form and content substantially similar to Exhibits B and C by first-class U.S. Mail to each potential Class Member identified by Defendants. Prior to mailing, the Class List (defined below) as updated Administrator shall run the addresses one time through the National Change of Address databasedatabase in order to obtain any updated address for potential Class Members. 5.4 The Administrator shall complete mailing of the Class Notice and Claim Form to potential Class Members not less than seventy-five (75) days prior to the Final Approval Hearing. Any material change(s) to the Class Notice or Claim Form agreed to by the Parties after entry of the Preliminary Approval Order must be approved by the Court prior to mailing. 5.5 If a Class Notice and Claim Form sent to any potential Class Member is returned as undeliverable, the Administrator will promptly log such return as undeliverable and provide copies of the USPS provides log to Defendants and Class Counsel as requested. If the mailing is returned to the Administrator with a forwarding address, the Claims Administrator shall resend will forward the Class Notice mailing to that address. For other returned mailings, the potential Class Member using Administrator will run the corrected name and address provided one time through a single commercial database (e.g., Accurint) chosen by the USPS. If Administrator, and should the commercial database show a Class Notice is returned by the USPS without a forwarding more current address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited re-mail the returned Class Notice and Claim Form to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If no more current address list exists, and Defendants can reasonably identify from their own information one or more available e-mail addresses for the Class Member, Defendants will provide the same to the Administrator to solicit a current mailing address, and if successful, a shall re-mail the returned Class Notice shall be resent and Claim Form to the potential Class Member at the more current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as further efforts to the date and time of the final approval hearing, including any changes locate or to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information find a more current address for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlementMembers is required. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 28. The parties agree to the following provisions for Class Notice, subject to Court approval. Within twenty-one (21) days of execution Notice of the Settlement Agreementshall be provided to Class Members. The Parties believe and agree that the following procedures for disseminating such notice provide the best practicable notice to Class Members. a. The Claims Administrator shall be responsible for preparing, DMC shall provide Plaintiffs with a current list of the names printing, and addresses of members mailing to all Class Members an individualized version of the Class (in electronic formNotice as approved by the Court and any such other materials as may be required to be distributed, if available) including a Workweek Discrepancy Form for individuals claiming to be Class Members who worked at DMC during request such a Form, all as approved and directed by the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no Court. b. Not later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) business days after the Court’s entry of a Preliminary Approval Order, Xxxxxx shall provide to the Claims Administrator a Class List. Based on the information provided in the Class List and the Plan of Allocation set forth herein, the Claims Administrator shall promptly calculate an Estimated Settlement Amount for every Class Member, to be included in the individualized Notice to be sent to that Class Member, and shall prepare and email to Class Counsel and Xxxxxx’x counsel no fewer than two days before mailing the Class Notice to Class Members, a spreadsheet without names, contact information and Social Security Numbers, and instead include a separate and distinct identification number for each class member, setting forth those calculations. c. Not later than ten (10) business days after receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the Courtinformation described in subsection (b) above, the Claims Administrator shall mail a Court-approved form of the Class Notice by first class mail postage prepaid to each member of the Class every individual on the Class List (defined below) as updated whose address information is known. This mailing shall be sent by first-class U.S. mail, postage pre-paid. Before mailing the Class Notice, the Claims Administrator shall run the Class Member addresses through the National U.S. Postal Service’s Change of Address databaseDatabase and update any addresses accordingly. If Any returned envelopes from the initial mailing with forwarding addresses shall be used by the Claims Administrator to re-mail the Class Notice. d. Except as otherwise provided herein, the Class Notice: i. Shall state that the deadline for submitting any Workweek Discrepancy shall be sixty (60) calendar days after the postmark date of the initial mailing of Class Notices; ii. Shall state the recipient’s Estimated Settlement Amount, as calculated by the Claims Administrator; iii. Shall inform the recipient of the need to provide updated contact information to the Claims Administrator until such time as all settlement funds have been distributed; iv. Shall include a summary of the release and waiver of claims against the Released Parties, and shall inform the recipient that any Class Member who receives notice of the Settlement and does not opt out shall be deemed to have released all covered claims against the Released Parties; v. Shall explain that a Class Member who is not identified on the Class List or whose Class Notice sent by U.S. mail is returned to the Claims Administrator as undeliverable, and undeliverable or addressee unknown without forwarding information shall not be eligible to share in the USPS provides settlement funds unless that individual contacts the Claims Administrator no later than sixty (60) calendar days after the postmark date of the initial mailing of Class Notices. e. The Claims Administrator shall send Workweek Discrepancy Form upon request to any individual who requests a Workweek Discrepancy Form. f. For any Class Notice that is returned by the Post Office with a forwarding address, the Claims Administrator shall resend forward the Class Notice to the potential Class Member using the corrected that new address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.within five

Class Notice. 28. The parties agree to Under, e.g., California Rules of Court, rule 3.769(f), the following provisions for Class NoticeSettlement Administrator shall, subject to Court approval. Within within twenty-one (21) days of execution after the entry of the Settlement AgreementPreliminary Approval Order, DMC shall provide Plaintiffs with a current list of the names and addresses of members of disseminate the Class (in electronic formNotice to Class Members, if available) who worked at DMC during the as follows: a. Before mailing any Class PeriodNotice, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the Court, the Claims Administrator shall mail use a Court-approved form of Class Notice by first class mail postage prepaid to each member of the Class on the Class List (defined below) as updated through the National Change of Address databasedatabase and any other commercially appropriate database of contact information to identify any outdated addresses for Class Members and to and update such addresses. b. The Settlement Administrator send Class Notice via first-class mail to each Class Member at his or her last known valid address, address correction requested. If a Class Notice any notice is returned as undeliverable, and the USPS provides with a forwarding new address, the Claims Settlement Administrator will re-mail the notice to the new address and shall update the Class Member address list with all forwarding addresses. c. The Settlement Administrator shall resend maintain a website where Class Members may access the following documents, as they are filed with the Court as practicable: the Class Notice to Notice; the potential operative complaint and any other papers now on file with the Court that may be relevant; the Parties’ motion for preliminary approval (which shall include this Agreement, which will be separately and distinctively labeled on the website); the Preliminary Approval Order; Class Member using Counsel’s Fee Application; and the corrected address provided by Parties’ motion for final approval. The Parties may also make available on the USPS. If a website any additional information that may assist the Class Notice is returned by in understanding the USPS without a forwarding addressAgreement and their rights and obligations thereunder, as well as any supplemental briefs supporting the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching motions for final approval and the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current addressFee Application. 30. d. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was providedclearly and concisely state in plain, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following itemseasily understood language: (i) the Class Noticenature of the action; (ii) the Settlement Agreementdefinition of the class certified; (iii) the Preliminary Approval Order as entered by the Courtclass claims, issues, or defenses; (iv) information as to that a class member may enter an appearance through an attorney if the date and time of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearingmember so desires; (v) contact information that the court will exclude from the class any member who files a timely and valid request for Class Counselexclusion; (vi) notification the time and manner for requesting exclusion; and (vii) the binding effect of a class judgment on members. A copy of the deadline by Class Notice shall be forwarded to Defendants’ counsel for his approval, which approval shall not be unreasonably withheld. e. The Class Notice shall also clearly and concisely state in plain, easily understood language: (i) that Plaintiff has settled the Action without any objections to final approval admission of liability on the part of Defendants; (ii) identify Class Counsel and Defendants’ Counsel; (iii) summarize the terms of the Agreement (i.e., that Defendants will create a $720,000 Settlement Agreement must Fund over 14 months, which will be filed with the Court and served on counsel distributed to Class Members in exchange for the partiesrelease and dismissal of Released Claims); (iv) identify the amount of attorney’s fees and litigation costs sought; (v) identify the amount of the incentive compensation for the named plaintiff sought; (vi) identify the Cy Pres Recipient; (vii) notification explain the time and manner for opting out of Class Members’ right the Settlement or making an objection to be represented at the final approval hearing by counsel of their own choosing, at their own expense, Agreement; and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) identify the Complaint; (ix) when availabletime, Class Counsel’s Plan of Allocation date, and any orders relating thereto; and (x) any other document or notification relating to location for the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlementFinal Hearing. 32. Class Counsel f. Further, the Notice shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to advise Class Members in accordance with this Settlement that their Released Claims will be released and dismissed under the Agreement and the orders of the Courtunless they submit a request for exclusion under Section 4.4. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 28Notice consistent with the due process requirements of Fed. The parties agree to R. Civ. P. 23 shall be provided within thirty (30) days following entry of the following provisions for Class Preliminary Approval Order, as follows: a. Direct Notice, subject substantially in the form attached hereto as Exhibit 1 or as modified by the District Court with the consent of all Parties, will be sent via electronic mail (email) to Court approval. Within twenty-one (21) days of execution of the Settlement Agreement, DMC shall provide Plaintiffs with a current list of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than Members within thirty (30) days after Preliminary Approval the date of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the Court, the Claims Administrator shall mail a Court-approved form of Class Notice by first class mail postage prepaid to each member of the Class on the Class List (defined below) as updated through the National Change of Address database. If a Class Notice is returned as undeliverable, and the USPS provides a forwarding address, the Claims Administrator shall resend the Class Notice to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order at the most recent email address shown in the Tribal Officials’ electronic records, as entered maintained in the ordinary course of business, for the loan at issue. b. Direct Notice, substantially in the form attached hereto as Exhibit 1 or as modified by the Court; (iv) information as District Court with the consent of all Parties, will be mailed, via first class mail, to Settlement Class Members whose email notice results in a bounce-back email. Mailing addresses will be run once through the date and time NCOA, or any other postal address verification database that the Administrator deems proper, prior to mailing. Returned Direct Notices will be re-mailed if they are returned within 20 days of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification postmark date of the deadline Direct Notice and contain a forwarding address. No further e-mailed or mailed notice shall be required except as otherwise expressly provided herein. c. The Administrator will establish and maintain a website, using a domain name approved by all Parties, on which will be posted the Direct Notice as well as the Class Action Complaint; this Agreement; any objections to final motions and memoranda seeking approval of the Settlement Agreement must be filed with the Court this Settlement, approval of attorneys’ fees and served on counsel for the partiescosts, or approval of Plaintiffs’ service awards; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33District Court relating to this Settlement; and any other information the Parties believe necessary and appropriate. DMC The Direct Notice shall have no liability with respect direct recipients to the giving location of any notice provided for in this the website. The website shall make available a form that allows Settlement Agreement.Class Members to update their mailing addresses; Settlement Class Members may also contact the Administrator by telephone or mail to update their mailing addresses. Within sixty

Class Notice. 28. The parties agree to the following provisions for Class Notice, subject to Court approval36. Within twenty-one (21) 15 days of execution after the Preliminary Approval of the Proposed Settlement Agreementas provided in Paragraph 33, DMC above, Defendant shall provide Plaintiffs with to Class Counsel and the Administrator those spreadsheets in its possession and readily obtainable that include the license plate data of each potential Class Member that they have been able to identify, after conducting a current reasonable search and making a reasonable inquiry of its records of bootings of Class Members during the Class Period. Such spreadsheets will be provided in their original or similar machine-parsable format. 37. Within 30 days after receipt of this information, the Administrator shall provide to Class Counsel and Defendant, a list of the names and addresses of members last known address of the potential Class Members the Class Administrator was able to identify through use of the license plate data. 38. Thereafter, not less than 60 days prior to the Final Approval Hearing, the Administrator shall send a copy of the Individual Notice and a Claim Form by text message and/or first-class mail to each potential Class Member for whom were identified through license plate data. Prior to posting of the Individual Notice by the Administrator with the United States Postal Service, the Administrator shall utilize the National Change of Address database (the “NCOA”) in electronic forman attempt to obtain the most current addresses for those receiving the Individual Notice. 39. After the posting of the Individual Notice by the Administrator with the United States Postal Service, for any Individual Notices returned as undeliverable, the Administrator shall utilize the services of a commercial database resources entity (e.g., Accurint, TransUnion, IDI, etc.), and attempt to obtain current mailing addresses and/or telephone numbers for such returned Individual Notice(s), and should the commercial database show a more current address, the Administrator shall re-post the returned Individual Notice to the more current address; provided however, if availablea determination is made in good faith by the Administrator that it is not possible to further update any particular Class Member’s address(es) who worked at DMC during in sufficient time to re-post the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than Notice(s) at least thirty (30) days after Preliminary before the scheduled Final Approval Hearing, then the Administrator need not make any further efforts to provide further Individual Notice to such Person(s). 40. The Individual Notice will be approved as to form and content by the Court and be substantially in the form attached hereto as Exhibit “3”, unless otherwise modified by agreement of the Parties and approved by the Court. The mailing to the Class Members that contains the Individual Notice will also include a copy of the Claim Form, in a format substantially similar to Exhibit “4”. 41. If any Individual Notice and/or Claim Form mailed to any potential Class Member in accordance with Paragraphs 38-40 is returned to the Administrator as undeliverable, the Administrator will promptly log each Individual Notice and/or Claim Form that is returned as undeliverable and provide copies of the log to Defendant and Class Counsel as requested. It is agreed by the Parties that the procedures set forth in the preceding paragraphs constitute reasonable and best practicable notice under the circumstances, and constitute an appropriate and sufficient effort to locate current addresses for Class Members such that no additional efforts to do so shall be required. Upon request, the Administrator shall provide Class Counsel and/or Defendant such reasonable access to the notice process as they may need to monitor compliance with the notice campaign. 42. In addition to the Individual Notices mailed in accordance with Paragraphs 38-40, above, the Administrator shall, commencing no later than the date of posting for the Individual Notices, cause to be published a notice (“Publication Notice”) of the Settlement Agreement, Social Security Numbers for members of in the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29Atlanta Journal Constitution. Within twenty (20) days of receipt of the Updated Address List and after entry of an Order of Preliminary Approval by the Court, the Claims Administrator shall mail a Court-approved form of Class Notice by first class mail postage prepaid to each member of the Class on the Class List (defined below) as updated through the National Change of Address database. If a Class Notice is returned as undeliverable, and the USPS provides a forwarding address, the Claims Administrator shall resend the Class Notice to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class The Publication Notice shall be resent published once a week for four consecutive weeks, in a form substantially similar to that attached hereto as Exhibit “5”. 43. The Individual Notice and Claim Form will also be made available to all potential Class Members by request to the Administrator, who shall send via first class U.S. mail any of these documents as requested from the Administrator by any potential Class Member at the current addressMember. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 28. The parties agree to the following provisions for Class Notice, subject to Court approval. Within twenty-one (21) days of execution of the Settlement Agreement, DMC shall provide Plaintiffs with a current list of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as As soon as possible, and no later than thirty (30) days practicable after Preliminary Approval of the Settlement AgreementProposed Settlement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty but in any event no more than fifteen (2015) days of receipt of the Updated Address List and after entry of an Order of the Preliminary Approval by Order, Defendant shall conduct a reasonable search of its records and provide to the CourtAdministrator for each Person reasonably believed to be a potential Class Member, the Claims following information, if reasonably available: name, last known mailing address, date of Covered Loss during the Class Periods, policy number, claim number for the Covered Loss, and data from estimates for each such Person’s claims within the Class Periods showing replacement cost value of the Covered Loss, Depreciation as calculated by estimates, and ACV Payments, as well as any other information reasonably required to administer the Settlement. 5.3 The Administrator shall mail a Court-approved form of Class Notice by first class mail postage prepaid to each member copy of the Class on Notice and Claim Form in a form and content substantially similar to Exhibits B and C by first-class U.S. Mail to each potential Class Member identified by Defendant. Prior to mailing, the Class List (defined below) as updated Administrator shall run the addresses one time through the National Change of Address databasedatabase in order to obtain any updated address for potential Class Members. 5.4 The Administrator shall complete mailing of the Class Notice and Claim Form to potential Class Members not less than seventy-five (75) days prior to the Final Approval Hearing. Any material change(s) to the Class Notice or Claim Form agreed to by the Parties after entry of the Preliminary Approval Order must be approved by the Court prior to mailing. 5.5 If a Class Notice and Claim Form sent to any potential Class Member is returned as undeliverable, the Administrator will promptly log such return as undeliverable and provide copies of the USPS provides log to Defendant and Class Counsel. If the mailing is returned to the Administrator with a forwarding address, the Claims Administrator shall resend will forward the Class Notice mailing to that address. For other returned mailings, the potential Class Member using Administrator will run the corrected name and address provided one time through a single commercial database (e.g., Accurint) chosen by the USPS. If Administrator, and should the commercial database show a Class Notice is returned by the USPS without a forwarding more current address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited re-mail the returned Class Notice and Claim Form to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successfulno more current address list exists, a and Defendant can reasonably identify from its own records one or more available e-mail addresses for the Class Notice shall be resent Member, Defendant will provide the same to the potential Class Member at the current address. 30Administrator. The Class Notice Administrator shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of then e-mail the Class Notice (without regard to returned envelopes)and Claim Form, which shall satisfy the notice requirements. Because notice of certification No acknowledgment of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2)e-mail by the potential class member is required, and even if the deadline for opte-outs expired June 1mail address is no longer valid or operational, 2015, the parties will seek Court approval for no further efforts to locate or to find a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information more current address for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlementMembers is required. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 28. The parties agree to the following provisions for Class Notice, subject Subject to Court approval. Within twenty-one (21) days of execution of , the Settlement Agreement, DMC shall provide Plaintiffs with a current list of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective Order. 29. Within twenty (20) days of receipt of the Updated Address List and Parties agree that after entry of an Order of the Preliminary Approval Order, Defendants will provide the Class with Notice of the proposed Settlement by the following methods: (a) Within 20 days of the Preliminary Approval Order, the Administrator shall cause a Summary Notice of Settlement (“Summary Notice”) to be published in a manner reasonably calculated to reach the Class, substantially in the form attached hereto as Exhibit B, and to be approved by the Court. The Summary Notice shall inform Class Members of a website (xxx.XxxxxxxXxxx00xxxxxxxxxxxxxxxxxxxx.xxx) through which Class Members may arrange for a mailing or downloading of the Detailed Notice of Settlement (“Detailed Notice”), substantially in the form attached hereto as Exhibit C. The Summary Notice shall reference the website address. Class Members may submit a Claim Form online, by U.S. mail, by email or by fax. (b) Prior to the dissemination of the Summary Notice, the Claims Administrator shall mail establish a Court-approved form of Class Notice by first class mail postage prepaid to each member of website (xxx.XxxxxxxXxxx00xxxxxxxxxxxxxxxxxxxx.xxx). Any mailed or publication notice will reference the Class on the Class List (defined below) as updated through the National Change of Address databasewebsite address. If a Class Notice is returned as undeliverableThe website will contain relevant court documents, frequently asked questions, Summary and Detailed Notices, and the USPS provides a forwarding address, the Claims Administrator shall resend the Class Notice to the potential Class Member using the corrected address provided by the USPS. If a Class Notice is returned by the USPS without a forwarding address, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited to searching the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class member’s current address. If successful, a Class Notice shall be resent to the potential Class Member at the current addressClaim Form. 30. The Class Notice (c) Defendants shall incorporate a final fairness hearing date as established by post information concerning the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Classsettlement on its website. 31. No later than five (5d) business Within 30 days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order (the “Mailing Deadline”), the Administrator shall mail the Detailed Notice and Claim Form, substantially in the forms attached hereto as entered Exhibits C and A, respectively, to be approved by the Court; (iv) information as , by first class mail, postage prepaid, to each Class Member to the date and time extent that the specific addresses of such Class Members are within the possession, custody, or control of Defendants. In addition, the Detailed Notice shall be mailed to each Class Member whose identity becomes actually known to Defendants or the Administrator as a result of the final approval hearingSummary Notice, including any changes to such hearing time or place received by who filed a settlement claim in Xxxx Xxxxxxxx, et al. v. TCL Communications, Inc., et al., No. 3:17-cv-095-FDW-DCK U.S.D.C. for the Claims Administrator at least five (5) business days prior Western District of North Carolina, Charlotte Division, that was, according to the final approval hearing; (v) contact information for Class Counsel; (vi) notification Administrator, rejected solely based on the state of residency of the deadline by which any objections to final approval of claimant, or who contacts the Settlement Agreement must be filed with the Court and served on counsel for the parties; Administrator within twelve (vii12) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days months after the entry of an order approving the final distribution of the Settlement FundCourt’s Preliminary Approval Order. Plaintiffs shall update this website to reflect the current status of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure The Parties recognize that notice of the settlement hearing is provided Defendants do not generally sell Idol 3 Smartphones directly to Class Members in accordance with this Settlement Agreement and that notice by publication may be the orders primary form of the Courtnotice hereunder. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.

Class Notice. 28. The parties agree to the following provisions for Class Notice, subject to Court approval. Within twenty-one (21) days of execution Following entry of the Settlement AgreementPreliminary Approval Order and at least 60 days before the Final Approval Hearing, DMC the Claims Administrator will transmit Class Notice to each Class Member. Notice will be sent as follows: x. Xxxxxxx shall provide Plaintiffs send the Long-Form Notice to Class Members with Current Accounts using (i) the mail address and (ii) the e-mail address (if any) that Xxxxxxx has on file for each such Class Member with a current list of the names and addresses of members of the Class (in electronic form, if available) who worked at DMC during the Class Period, either linked to previous name and address information provided during discovery or linked to the unique SSN-E number used during the litigation to identify DMC employees (“Updated Address List”). DMC shall also provide as soon as possible, and no later than thirty (30) days after Preliminary Approval of the Settlement Agreement, Social Security Numbers for members of the Class employed by DMC, which shall be subject to all confidentiality provisions of the Court’s Protective OrderCurrent Account. 29b. For Class Members who do not have Current Accounts: i. The Claims Administrator shall send the Short-Form Notice using the mailing address that Xxxxxxx has on file; and ii. Within twenty (20) days of receipt of the Updated Address List and after entry of If Xxxxxxx has an Order of Preliminary Approval by the Courte-mail address on file, the Claims Administrator shall mail a Courtsend the Long-approved form of Form Notice by e-mail. iii. Class Counsel may take additional steps to attempt to ensure Class Notice by first class mail postage prepaid to each member Class Members whose allocation of the Settlement Amount Class on the Class List (defined below) as updated through the National Change of Address database. If a Counsel deems sufficiently high that additional efforts at providing Class Notice is returned warranted. xx. Xxxxxxx will send a copy of the Long-Form Notice to any broker-dealer who is listed in Xxxxxxx’x system as undeliverablehaving been involved with any Class Member Policies. Because it is not feasible for Xxxxxxx to provide the brokerd-dealers with detailed information about which of the broker dealer’s customers may be Class Members, the Long-Form Notice will be accompanied by a communication from Xxxxxxx advising the broker- dealer that certain of the broker-dealer’s customers may be Class Members and therefore entitled to relief under the Settlement Agreement, and that if the USPS provides broker-dealer or the broker-dealer’s customer has questions about the Settlement, they may contact the Claims Administrator. c. The Long-Form Notice and the Short-Form Notice will instruct Class Members who do not have Current Accounts to provide additional contact information to facilitate distribution of settlement payments. The Long-Form Notice and the Short-Form Notice will specify that Class Members without Current Accounts who do not provide this information will not receive a settlement payment. d. Upon receipt of any returned Class Notice that includes a forwarding addressaddress provided by the Postal Service, the Claims Administrator shall resend will re-mail the Class Short- Form Notice to the potential Class Member using the corrected address provided by the USPS. If a forwarding address. e. For any Class Notice is returned by the USPS without a forwarding addressaddresses, the Claims Administrator shall utilize normal skip tracing techniques, including but not necessarily limited will use the United States Postal Service’s Address Element Correction (“AEC 1”) service to searching attempt to identify the database of one or more of the nationally recognized credit reporting agencies (such as Equifax, TransUnion, or Experian) to locate the potential Class memberMember’s current address. If successful, a The Claims Administrator will be obliged to re-mail the Class Notice shall be resent to only if the potential Class Member at the Claims Administrator obtains a current address. 30. The Class Notice shall incorporate a final fairness hearing date as established by the Court which is not less than 60 days from the date the Claims Administrator anticipates completion of the initial mailing of the Class Notice (without regard to returned envelopes). Because notice of certification of the Class was provided, in accordance with Federal Rule of Civil Procedure 23(c)(2), and the deadline for opt-outs expired June 1, 2015, the parties will seek Court approval for a Class Notice that shall not include any option to opt-out of this Settlement for any member of the Class. 31. No later than five (5) business days after the mailing of the Class Notice, Plaintiffs shall post on the already established Class Settlement Web Site, xxxxxxxxxxxxxxxxx.xxx, the following items: (i) the Class Notice; (ii) the Settlement Agreement; (iii) the Preliminary Approval Order as entered by the Court; (iv) information as to the date and time of the final approval hearing, including any changes to such hearing time or place received by the Claims Administrator at least five (5) business days prior to the final approval hearing; (v) contact information for Class Counsel; (vi) notification of the deadline by which any objections to final approval of the Settlement Agreement must be filed with the Court and served on counsel for the parties; (vii) notification of Class Members’ right to be represented at the final approval hearing by counsel of their own choosing, at their own expense, and the deadline for notification of any intent to appear and request to be heard at the final fairness hearing; (viii) the Complaint; (ix) when available, Class Counsel’s Plan of Allocation and any orders relating thereto; and (x) any other document or notification relating to the Settlement or distribution of the Settlement Fund. The Class Settlement Web Site shall be maintained for a period of at least sixty (60) days after the entry of an order approving the final distribution of the Settlement Fund. Plaintiffs shall update this website to reflect the current status of this settlement. 32. Class Counsel shall take all necessary and appropriate steps to ensure that notice of the settlement hearing is provided to Class Members in accordance with this Settlement Agreement and the orders of the Court. 33. DMC shall have no liability with respect to the giving of any notice provided for in this Settlement Agreement.