STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • March 15th, 2022
Contract Type FiledMarch 15th, 2022This Stipulation and Agreement of Settlement (the “Stipulation” or “Settlement Agreement”) is made and entered into by and between Lead Plaintiff Public Employees’ Retirement System of Mississippi (“MissPERS” or “Lead Plaintiff”) and additionally named Plaintiff Monroe County Employees’ Retirement System (“Monroe,” and with MissPERS, “Plaintiffs”), on behalf of themselves and all other members of the proposed Settlement Class (defined below), on the one hand, and Defendants Nielsen Holdings plc (“Nielsen” or the “Company”), Dwight Mitchell Barns, Kelly Abcarian, and Jamere Jackson (the “Individual Defendants,” and together with Nielsen the “Defendants,” and together with both Nielsen and Plaintiffs the “Parties”), on the other, by and through their counsel of record in the above-captioned litigation pending in the United States District Court for the Southern District of New York (the “Court”). This Stipulation is intended by the Parties to fully, finally, and forever resolve, discharg