STIPULATION AND AGREEMENT OF SETTLEMENTOctober 20th, 2021
FiledOctober 20th, 2021This Stipulation and Agreement of Settlement (together with all Exhibits hereto, the “Stipulation”), dated as of October 20, 2021, which is entered into by and among (i) Lead Plaintiff IGC Investor Group (consisting of Lead Plaintiff members Victor Blahut, Charles Dewayne Goss, Sherry Phyllis Goss, Melissa Culbertson, Timothy Culbertson, Duc Tran, and Yong P. Saito) (collectively, “Plaintiffs” or “Lead Plaintiffs”), individually and on behalf of the Settlement Class (as defined herein); (ii) Defendant India Globalization Capital, Inc. (“IGC” or the “Company”); and (iii) Defendants Ram Mukunda and Claudia Grimaldi (collectively, the “Individual Defendants” and, together with IGC, “Defendants”), by and through their undersigned attorneys, states all of the terms of the settlement and resolution of this matter by the Settling Parties (as defined herein) and is intended by the Parties to fully and finally release, resolve, remise, and discharge the Released Claims (as defined herein) again