REVISED SETTLEMENT AGREEMENTSettlement Agreement • January 23rd, 2020 • California
Contract Type FiledJanuary 23rd, 2020 JurisdictionThis Revised Settlement Agreement (“Agreement”) is made and entered into this 21th day of January, 2020, by and between Plaintiff Timothy Elder (the “Plaintiff”), on behalf of himself and the Settlement Class defined below, and Defendants Hilton Worldwide Holdings Inc. and Hilton Grand Vacations Company, Inc. (collectively “Hilton”) and Blackhawk Engagement Solutions, Inc. (“Blackhawk”). For the purpose of this Agreement, the Plaintiff, Hilton and Blackhawk are described collectively as the “Parties” to this Agreement, and Hilton and Blackhawk collectively as “Defendants.” Subject to the preliminary and final court approval as described below, the Parties state and agree as follows: