Common Contracts

EXHIBIT A

Settlement Agreement • February 24th, 2022 • Texas

• Contract Type
  Settlement Agreement
• Filed
  February 24th, 2022
• Jurisdiction
  Texas

This Stipulation of Agreement and Settlement and Release is entered into by and among Named Plaintiffs, for themselves and on behalf of the Settlement Class, and Defendants Insurance Technologies Corp. and Zywave, Inc. (“ITC” or “Defendants”), subject to preliminary and final Court approval as required by Federal Rule of Civil Procedure 23(e). As provided herein, Defendants and Named Plaintiffs hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final order and judgment, all claims of the Settlement Class against Defendants in connection with the Data Breach (defined below) as alleged in the action titled Heath, et al. v. Insurance Technologies Corp. and Zywave, Inc., Case No. 3:21- cv-01444-N (N.D. Tex.) shall be settled and compromised upon the terms and conditions contained herein. Named Plaintiffs and Defendants are collectively referred to herein as the “Parties.”