Estimate of Average Amount of Recovery Per Share. Based on Lead Plaintiff’s damages expert’s estimates of the number of shares K12 of common stock publicly traded on the NYSE purchased during the Settlement Class Period that may have been affected by the conduct at issue in the Action and assuming that all Settlement Class Members elect to participate in the Settlement, the estimated average recovery (before the deduction of any Court-approved fees, expenses, and costs as described herein) per eligible security is $0.
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Sources: Stipulation and Agreement of Settlement, Settlement Agreement