STIPULATION AND AGREEMENT OF SETTLEMENTIxia • December 1st, 2015 • Instruments for meas & testing of electricity & elec signals
This Stipulation and Agreement of Settlement (the “Stipulation”), dated November 17, 2015, is made and entered into by and among the following Parties (as defined herein), each by and through their respective counsel of record: (i) plaintiffs in the above-captioned consolidated shareholder derivative action (the “Action”), Erie County Employees’ Retirement Fund (“Erie”) and Colleen Witmer (“Witmer”) (together, the “Plaintiffs”), on behalf of themselves and derivatively on behalf of Ixia (“Ixia” or the “Company” or the “Nominal Defendant”); (ii) Nominal Defendant Ixia; and (iii) individual defendants Victor Alston, Atul Bhatnagar, Thomas B. Miller, Errol Ginsberg, Jonathan Fram, Laurent Asscher, Gail Hamilton, Jon F. Rager, Alan Grahame, Raymond de Graaf, Walker H. Colston II and Ronald W. Buckly, each of whom is a current or former member of the Board of Directors (the “Board”) of Ixia and/or a current or former senior officer of Ixia (collectively, the “Individual Defendants” and toge
