Common use of Estimate of Average Amount of Recovery Per Share Clause in Contracts

Estimate of Average Amount of Recovery Per Share. Based on Class Representatives’ damages expert’s estimate of the number of shares of KBR common stock eligible to participate in the Settlement, and assuming that all investors eligible to participate in the Settlement do so, Class Representatives estimate that the average recovery, before deduction of any Court-approved fees and expenses, such as attorneys’ fees, litigation expenses, Taxes, and Notice and Administration Expenses, would be approximately $0.22 per allegedly damaged share.3 If the Court approves the attorneys’ fees and litigation expenses requested by Class Counsel (discussed below), the average recovery would be approximately $0.14 per allegedly damaged share. Class Members should note, however, that the foregoing average recovery amounts are only estimates and Class Members may recover more or less than these estimated amounts. A Class Member’s actual recovery will be a portion of the Net Settlement Fund, determined by comparing the Class Member’s “Recognized Claim” to the total Recognized Claims of all Class Members who timely submit 3 An allegedly damaged share might have been traded, and potentially damaged, more than once during the Class Period, and the average recovery indicated above represents the estimated average recovery for each share that allegedly incurred damages. valid Claim Forms, as described more fully below. An individual Class Member’s actual recovery will depend on, for example: (i) the total number of claims submitted; (ii) the amount of the Net Settlement Fund; (iii) when the Class Member purchased or acquired KBR common stock during the Class Period; and (iv) whether and when the Class Member sold KBR common stock. See the Plan of Allocation beginning on page [ ] for information on the calculation of your Recognized Claim.

Estimate of Average Amount of Recovery Per Share. Based on Class Representatives’ damages expert’s estimate of the number of shares of KBR Conn’s common stock eligible to participate in the Settlement, and assuming that all investors eligible to participate in the Settlement do so, Class Representatives estimate Representatives’ expert estimates that the average recovery, before deduction of any Court-approved fees and expenses, such as attorneys’ fees, litigation expenses, Taxes, and Notice and Administration Expenses, would be approximately $0.22 0.36 per allegedly damaged share.3 If the Court approves the attorneys’ fees and litigation expenses requested by Class Counsel (discussed below), the average recovery would be approximately $0.14 0.26 per allegedly damaged share. Class Members should note, however, that the foregoing average recovery amounts are only estimates and Class Members may recover more or less than these estimated amounts. A Class Member’s actual recovery will be a portion of the Net Settlement Fund, determined by comparing the Class Member’s “Recognized Claim” to the total Recognized Claims of all Class Members who timely submit 3 An allegedly damaged share might have been traded, and potentially damaged, more than once during the Class Period, and the average recovery indicated above represents the estimated average recovery for each share that allegedly incurred damages. valid Claim Forms, as described more fully below. An individual Class Member’s actual recovery will depend on, for example: (i) the total number of claims submitted; (ii) the amount of the Net Settlement Fund; (iii) when the Class Member purchased or acquired KBR Conn’s common stock and/or call options, or sold/wrote put options, during the Class Period; and (iv) whether and when the Class Member sold KBR Conn’s common stockstock or options. See the Plan of Allocation beginning on page [ ] for information on the calculation of your Recognized Claim.