Common use of Reasons for the Settlement Clause in Contracts

Reasons for the Settlement. For Lead Plaintiff, the principal reason for the Settlement is the guaranteed cash benefit to the Settlement Class. This benefit must be compared to the uncertainty of being able to prove the allegations in the Complaint; the risk that the Court may grant some or all of the anticipated summary judgment motions to be filed by Defendants; the uncertainty of a greater recovery after a trial and appeals; and the difficulties and delays inherent in such litigation.

Reasons for the Settlement. For Lead PlaintiffPlaintiffs, the principal reason for the Settlement is the guaranteed cash benefit to the Settlement Class. This benefit must be compared to the uncertainty of being able to prove the allegations in the Complaint; the risk that the Court may grant some or all of the anticipated summary judgment motions to be filed by Defendants; the uncertainty inherent in the Parties’ competing theories of a greater recovery after a trial liability and appealsdamages; and the risks of litigation, especially in complex actions like this; as well as the difficulties and delays inherent in such litigationlitigation (including any trial and appeals).

Reasons for the Settlement. For Lead Plaintiff, the principal reason for the Settlement is the guaranteed cash benefit to the Settlement Class. This benefit must be compared to the uncertainty of being able to overcome the Settling Defendants’ motion to dismiss, prove the allegations in the Complaintcomplaint; the risk that the Court may grant some or all of the anticipated summary judgment motions to be filed by Defendantsnot certify a class; the uncertainty of a greater recovery after summary judgment, a trial and appeals; and the difficulties and delays inherent in such litigation.

Reasons for the Settlement. For Lead Plaintiff, the principal reason for the Settlement is the guaranteed cash benefit to the Settlement Class. This benefit must be compared to the uncertainty of being able to prove the allegations in the Complaint; the risk that the Court may grant some or all of the anticipated summary judgment motions to be filed by Defendants; the uncertainty of a greater recovery after a trial and appeals; and the risks of litigation, especially in complex actions like this; as well as the difficulties and delays inherent in such litigationlitigation (including any trial and appeals).

Reasons for the Settlement. For Lead PlaintiffPlaintiffs, the principal reason for the Settlement is the guaranteed cash benefit to the Settlement Class. This benefit must be compared to the uncertainty of being able to prove the allegations in the Amended Class Action Complaint for Violations of the Federal Securities Laws (the “Complaint”); the risk that the Court may grant some or all of the anticipated summary judgment motions motion to be dismiss filed by Defendants; the uncertainty of a greater recovery after a trial and appeals; and the difficulties and delays inherent in such litigation.

Reasons for the Settlement. For Lead Plaintiff, the principal reason for the Settlement is the guaranteed cash benefit to the Settlement Class. This benefit must be compared to the uncertainty of being able to prove the allegations in the Complaint; maintaining certification of the class through trial; the risk that the Court may grant some or all of the anticipated summary judgment motions to be filed by Defendants; the uncertainty of a greater recovery after a trial and appeals; and the risks of litigation, especially in complex actions like this; as well as the difficulties and delays inherent in such litigationlitigation (including any trial and appeals).