SETTLEMENT AGREEMENTSettlement Agreement • December 3rd, 2010
Contract Type FiledDecember 3rd, 2010Representative Plaintiffs, on behalf of themselves and all Class Members, on the one hand, and, on the other hand, defendants Quantcast Corporation (“Quantcast”); Clearspring Technologies, Inc. (“Clearspring”); American Broadcasting Companies, Inc.; Demand Media, Inc.; ESPN, Inc.; Fox Entertainment Group, Inc.; Hulu, LLC; JibJab Media, Inc.; MTV Networks, a division of Viacom International Inc.; MySpace, Inc.; NBC Universal, Inc; Scribd, Inc.; Soapnet, LLC; Walt Disney Internet Group; and Warner Bros. Records Inc. (“Defendants”); and certain Defendants’ affiliated Undertaking Parties (as defined below) hereby enter into this Stipulation and Agreement of Settlement (“Settlement Agreement”), subject to the approval of the Court pursuant to Rule 23 of the Federal Rules of Civil Procedure.