Common use of Estimate of Average Amount of Recovery Per Share Clause in Contracts

Estimate of Average Amount of Recovery Per Share. Plaintiffs’ damages expert estimates that the conduct at issue in the Action affected approximately 31.9 million shares of ZBH Common Stock4 purchased during the Settlement Class Period. If all eligible Settlement Class Members elect to participate in the Settlement, the estimated average recovery would be approximately $1.57 per affected share of ZBH Common Stock (before the deduction of any Court-approved fees, expenses and costs as described herein). Settlement Class Members should note, however, that the foregoing average recovery per share is only an estimate. Some Settlement Class Members may recover more or less than this estimated amount depending on,