SETTLEMENT AGREEMENTSettlement Agreement • October 29th, 2020 • California
Contract Type FiledOctober 29th, 2020 JurisdictionThis Settlement Agreement (“Agreement,” the terms of which are sometimes referred to as the “Settlement”) is entered into by and between Yolanda DiLorenzo (“DiLorenzo” or “Plaintiff”), on the one hand, on behalf of herself and all other individuals who are members of the Class as defined in Section III below, and defendants Bitdefender Inc. (“Bitdefender”), Avangate, Inc. (“Avangate”), and their direct and indirect parent companies, direct and indirect subsidiary companies, companies under common control with any of the foregoing, and affiliates, agents, employees, representatives, officers, directors, predecessors, and successors in interest of any of the foregoing (collectively, “Defendants”), on the other hand. For avoidance of doubt, the definition of Defendants includes Bitdefender S.R.L. and Avangate B.V. Each of the foregoing is a “Party” (collectively, the “Parties”).