Common use of FACTUAL BACKGROUND AND RECITALS Clause in Contracts

FACTUAL BACKGROUND AND RECITALS. 1. On October 20, 2021, Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 2. On December 22, 2021, ▇▇▇▇▇▇▇ House filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ granted the Motion to stay the case, deferring ruling on the Motion and referred the case to mediation. 3. Following arms-length negotiations, the Parties negotiated a settlement with the assistance of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at a mediation on May 12, 2022 by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the Litigation, including all claims Plaintiff and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House and related persons and entities, as set forth herein. 4. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 5. ▇▇▇▇▇▇▇ House denies all claims of wrongdoing or liability that Plaintiff, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇▇ House’s position that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 6. The Parties now enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On October 20March 4, 20212024, Plaintiff Plaintiffs filed the First Amended Class Action Complaint against Forward Bank related to a class action lawsuit against ▇▇▇▇▇▇▇ House based cyber security incident that it experienced on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 September 6, 2023 (the “Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract. Plaintiffs alleged that Defendant failed to adequately secure its network, and unjust enrichment (that as a result, cybercriminals were able to access Defendant’s network and steal sensitive personal information belonging to Plaintiffs and the “Litigation”)putative Class Members. 2. On December 22May 13, 20212024, following the exchange of informal discovery and a settlement demand, the Parties attended a mediation with well-respected mediator ▇▇▇▇▇▇▇ House filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. Jones (▇▇▇.) (“Judge ▇▇▇▇▇▇ granted ”) wherein they were unsuccessful in resolving the Motion to stay the case, deferring ruling on the Motion and referred the case to mediation. 3matter. Following arms-length negotiationsthe mediation, the Parties negotiated a settlement with the assistance of ▇Judge ▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at made a mediation mediator’s proposal which was accepted on May 1217, 2022 by which 2024, resolving all claims arising from the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the LitigationIncident, including all claims Plaintiff Plaintiffs and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House Forward Bank and related persons and entities, as set forth herein. 3. This Settlement Agreement resolves the claims of Plaintiffs and putative Class Members related to the disclosure of their name, Social Security number, driver’s license or other government ID number, financial account information, and/or other personal or financial information (“Private Information”) in the Incident. 4. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 5. ▇▇▇▇▇▇▇ House Forward Bank denies all claims of wrongdoing or liability that PlaintiffPlaintiffs, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Defendant contends that it has maintained and continues to maintain reasonable security information practices. Despite ▇▇▇▇▇▇▇ HouseForward Bank’s position that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House Forward Bank desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed performed, or document created in relation to the Settlement Agreement Agreement, or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 6. The Parties now enter into this Settlement Agreement. Plaintiff Plaintiffs and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff Plaintiffs and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s Plaintiffs’ determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, PlaintiffPlaintiffs, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On October 20April 24, 20212020, Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 2. On December 22, 2021, ▇▇▇▇▇▇▇ House filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇ filed a class action lawsuit against Defendant alleging violations of the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. (“BIPA”) in the Circuit Court of ▇▇▇▇ granted County Illinois. 2. Following the Motion to stay filing, the caseParties exchanged preliminary information, deferring ruling on including an estimate of the Motion number of potential members of the Settlement Class and referred general information about the case to mediationtime-keeping system at issue, and the parties informally engaged in arms-length settlement negotiations. 3. Following arms-length negotiations, the Parties negotiated now seek to enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement with according to the assistance terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at a mediation on May 12, 2022 by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the Litigation, including all claims Plaintiff and the Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House recognizing (1) the existence of complex and related persons contested issues of law and entitiesfact, (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement, (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as set forth hereinwell as the potential of no recovery whatsoever, and (5) the Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 4. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Partiesexpense. 5. ▇▇▇▇▇▇▇ House Defendant denies and continues to deny each and every allegation and all claims charges of wrongdoing or liability of any kind whatsoever that Plaintiff, Plaintiff or members of the Settlement Class Members, or anyone else presently have asserted in this Litigation or may assert in the futurefuture assert. Despite ▇▇▇▇▇▇▇ HouseDefendant’s position belief that it is they are not liable for, and has have good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House Defendant desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action or proceeding relating to the matters being fully settled and finally resolved and released put to rest in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 6. The Parties now enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members[Intentionally left blank]. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties Releasees of the Released Claims, without costs as to Released PartiesReleasees, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On October 20April 15, 20212020, Plaintiff ▇▇▇▇▇▇ ▇▇▇▇ filed a class action lawsuit against Plochman alleging violations of the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. (“BIPA”) in the Circuit Court of the Twenty First Judicial Circuit in Kankakee County, Illinois (the “Litigation”). The case was assigned to the ▇▇▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 2. On December 22, 2021, ▇▇▇▇▇▇▇ House ▇▇. 2. On June 22, 2020, Defendant filed its a Motion to DismissStay the proceedings based on the pendency of several appeals in other BIPA cases. Prior to responding to the Motion, which was then fully briefed by both PartiesPlaintiff and Defendant began to engage in settlement discussions. On February 8, 2022, and the Parties jointly moved agreed that Plaintiff need not respond to stay the case to allow Motion unless those discussions did not result in a settlement of the Parties to mediateLitigation. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ entered and continued Defendant’s Motion. 3. On December 3, 2020, the Parties participated in a formal, full-day mediation session with the ▇. ▇▇▇▇▇▇▇▇ granted the Motion to stay the case, deferring ruling on the Motion and referred the case to mediation▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ (▇▇▇.) of ADR Systems via Zoom. 34. Following arms-length negotiations, the Parties have negotiated a settlement with the assistance of Judge ▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at a mediation on May 12, 2022 by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the Litigation, including all claims Plaintiff and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House Defendant and related persons and entities, as set forth herein. 45. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, time and expense for both of the Partiesexpense. 56. ▇▇▇▇▇▇▇ House Plochman denies all claims charges of wrongdoing or liability of any kind whatsoever that Plaintiff, Plaintiff or Settlement Class Members, or anyone else Members have asserted in this Litigation or may assert in the futurefuture assert. Despite ▇▇▇▇▇▇▇ HouseDefendant’s position belief that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House Defendant desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action or proceeding relating to the matters being fully settled and finally resolved and released put to rest in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 67. The Following arms-length negotiations, including mediation before an experienced mediator, the Parties now seek to enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, Class recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.;

FACTUAL BACKGROUND AND RECITALS. 1. On October 20February 28, 20212019, Plaintiff filed a class action lawsuit complaint against ▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network Defendant alleging violations of the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. (“BIPA”) in June 2021 the Circuit Court of Will County, Illinois (the “Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (Underlying Action” or the “Litigation”). 2. On December May 22, 20212019, ▇▇▇▇▇▇▇ House Defendant filed its Motion an answer to Dismissthe complaint. Defendant denied and continues to deny liability for the claims made in the Underlying Action. 3. Defendant also moved for a stay of the Underlying Action pending certain appeals, which was then fully briefed by both Parties. On February 8, 2022, and the Parties jointly moved to stay Court stayed the case to allow Underlying Action pending resolution of the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇appeal in ▇▇▇▇▇▇ ▇. Ring Container Technologies, LLC, No. 3-20-0184 (3d Dist.) (“▇▇▇▇▇▇”). The ▇▇▇▇▇▇ granted the Motion to stay the case, deferring ruling on the Motion and referred the case to mediationappeal remains pending. 34. During the stay of the Underlying Action, the Parties exchanged information relevant to the putative class, including an estimate of the number of potential members of the Settlement Class, percentage of union members in the Settlement Class, and general information about the Biometric tracking system at issue. 5. Following arms-length negotiations, the Parties negotiated now seek to enter into this Settlement Agreement. Plaintiff and Class Counsel have concluded that a settlement with according to the assistance terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at a mediation on May 12, 2022 by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the Litigation, including all claims Plaintiff and the Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House recognizing: (i) the existence of complex and related persons contested issues of law and entitiesfact; (ii) the risks inherent in litigation; (iii) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; and (iv) the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as set forth hereinwell as the potential of no recovery whatsoever. 46. The Parties have agreed Defendant denies and continues to settle the Litigation on the terms deny each and conditions set forth herein in recognition that the outcome of the Litigation is uncertain every allegation and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 5. ▇▇▇▇▇▇▇ House denies all claims charges of wrongdoing or liability of any kind whatsoever that Plaintiff, Plaintiff or members of the Settlement Class Members, or anyone else presently have asserted in this Litigation Underlying Action or may assert in the futurefuture assert. Despite ▇▇▇▇▇▇▇ HouseDefendant’s position belief that it is not liable for, and has good defenses to, the claims alleged in the LitigationUnderlying Action, ▇▇▇▇▇▇▇ House Defendant desires to settle the LitigationUnderlying Action, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action or proceeding relating to the matters being fully settled and finally resolved and released in by this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed performed, or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 67. The Parties now enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interestsinterests considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation Underlying Action be settled and compromised, and that the Releasors release the Released Parties Releasees of the Released Claims, without costs as to Released PartiesReleasees, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On October 20June 12, 20212024, Plaintiff filed a class action lawsuit against Plaintiffs ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇, ▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 2. On December 22, 2021, ▇▇▇▇▇▇▇ House filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇ ▇▇▇, ▇▇▇▇▇ ▇▇▇▇▇▇ granted the Motion to stay the case▇, deferring ruling on the Motion and referred the case to mediation. 3. Following arms-length negotiations, the Parties negotiated a settlement with the assistance of ▇▇▇▇▇▇ ▇▇▇▇ filed a Consolidated Complaint against TalentLaunch related to a cyber security incident that TalentLaunch experienced in May 2023 (the “Data Incident”). Plaintiffs allege that TalentLaunch failed to adequately secure its network, and that as a result, cybercriminals were able to access TalentLaunch’s network and steal sensitive personal information belonging to Plaintiffs and other putative class members. 2. On August 7, 2024, following the exchange of Rule 408 discovery, the Parties jointly filed a Motion to Stay the Litigation pending Mediation. Subsequently, on November 6, 2024 the Parties attended a full day mediation with the ▇▇▇▇▇ ▇▇▇▇▇▇▇▇, Esq. of JAMS mediation service at a mediation on May 12, 2022 by which the Parties agree and hereby wish did not reach an agreement. However, after further negotiations the following week, the Parties were able to reach a settlement in principle to resolve all matters pertaining to, claims arising from, or associated with from the LitigationData Incident, including all claims Plaintiff Plaintiffs and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House TalentLaunch and related persons and entities, as set forth herein. 3. This Settlement Agreement resolves the claims of Plaintiffs and putative Class Members related to the disclosure of their names, dates of birth, Social Security numbers, drivers’ license numbers, state identification numbers, passport numbers, financial account information, digital signatures, medical information, health insurance information, biometric information, and mothers’ maiden names (“Private Information”) in the Data Incident. 4. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 5. ▇▇▇▇▇▇▇ House TalentLaunch denies all claims of wrongdoing or liability that PlaintiffPlaintiffs, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇▇ House’s position TalentLaunch contends that it is not liable forhas maintained and continues to maintain reasonable security information practices. Nevertheless, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House TalentLaunch desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed performed, or document created in relation to the Settlement Agreement Agreement, or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 6. The Parties now enter into this Settlement Agreement. Plaintiff Plaintiffs and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff Plaintiffs and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.;

FACTUAL BACKGROUND AND RECITALS. 1. On October 2011, 2022, the Action was filed against ESGW in the United States District Court for the District of Montana, Great Falls Division. 2. The Action relates to a data security incident impacting ESGW, that occurred between October 12, 2021 and November 11, 2021, Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇▇ House based which was publicly acknowledged by Defendant on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 September 16, 2022. The data security incident potentially affected certain personal information of at least 7,551 current and former ESGW patients, employees, and customers (the “Data Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 23. On December 22ESGW denies (i) the allegations and all liability with respect to facts and claims alleged in the Action, 2021(ii) that the class representative in the Action and the class she purports to represent have suffered any damage, ▇▇▇▇▇▇▇ House filed its Motion and (iii) that the Action satisfies the requirements to Dismissbe certified or tried as a class action under Federal Rules of Civil Procedure 23. Nonetheless, ESGW has concluded that further litigation would be protracted and expensive, and that it is desirable that the Action be fully and finally settled in the manner and upon the terms and conditions set forth in this Settlement Agreement. Neither this Settlement Agreement nor any negotiation or act performed, or document created in relation to the Settlement Agreement or negotiation or discussion thereof, is or may be deemed to be or may be used as an admission of any wrongdoing or liability. 4. The Parties began negotiating settlement as early as March 2023. Class Counsel and Defendant’s Counsel engaged in multiple telephone and email correspondences. The Parties were engaged in an offer and counteroffer process which was then fully briefed by both Partiestook months to complete. On February 8In anticipation of continued litigation and formal mediation, 2022ESGW began to prepare initial discoveries related to the merits of Plaintiffs’ claims, potential defenses thereto, and class certification, and the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ granted the Motion to stay the case, deferring ruling discussed their respective positions on the Motion merits of the claims and referred the case to mediationclass certification. 35. Following months of extensive arms-length negotiations, the Parties negotiated a settlement with the assistance of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇on August 30, Esq. at a mediation on May 122023, 2022 by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the LitigationAction, including all claims Plaintiff and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House and related persons and entities, as set forth herein. 4. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 5. ▇▇▇▇▇▇▇ House denies all claims of wrongdoing or liability that Plaintiff, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇▇ House’s position that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liabilityESGW. 6. The Parties now enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into In exchange for the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenantsmutual promises, agreements, and releases set forth hereinreleases, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly consideration provided for in this Settlement Agreement, and without any admission or concession by either Party, the Parties agree to a full, complete and final settlement and resolution of the Action, subject to the approval of the CourtCourt approval, on the following terms and conditions.:

FACTUAL BACKGROUND AND RECITALS. 1. On October 20December 31, 20212020, after an extensive pre-filing investigation, Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 2. On December 22, 2021, ▇▇▇▇▇▇▇ House filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇filed a class action lawsuit against Defendant alleging violations of the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. ▇▇(“BIPA”) in the Circuit Court of ▇▇▇▇ granted County, Illinois. 2. The Parties thereafter commenced settlement negotiations after Defendant provided Plaintiff’s counsel early confirmatory discovery regarding the Motion to stay correct identity of Defendant (erroneously sued and served as Onni Contracting (Chicago) Inc.) and the case, deferring ruling on the Motion and referred the case to mediationpotential class size. 3. Following extensive arms-length negotiations, the Parties have negotiated a settlement with that, if approved by the assistance of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇Court, Esq. at a mediation on May 12, 2022 by which the Parties agree and hereby wish to will resolve all matters pertaining to, claims arising from, or associated with the Litigation, including all claims under BIPA that Plaintiff and members of the Settlement Class Members (defined below) have or may have had against ▇▇▇▇▇▇▇ House Defendant and its related persons and affiliated entities, through the date on which the Parties sign this Agreement. Defendant has represented that the potential class size consists of 124 individuals who utilized Defendant’s Time-Keeping System, as set forth defined herein, between December 31, 2015 and the present. 4. The Following arm’s length negotiations, the Parties have agreed now seek to enter into this Settlement Agreement to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Partiesexpense. 5. ▇▇▇▇▇▇▇ House denies all claims of wrongdoing or liability that Plaintiff, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇▇ House’s position that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 6. The Parties now enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an extensive investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, recognizing: recognizing (1) the existence of complex and contested issues of law and fact; , (2) the risks inherent in litigation; , (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; , (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; , and (5) the Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 76. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlementThus, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties Releasees of the Released Claims, without costs as to Released PartiesReleasees, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On October 20July 10, 20212020, Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ House based on filed a cyberattack on class action lawsuit against Xavier, alleging claims of breach of contract, unjust enrichment, and promissory estoppel, related to adjustments made to Xavier University’s College of Nursing’s Accelerated Bachelor of Science in Nursing program in response to the emergence of the COVID-19 pandemic. 2. In response to ▇▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”)motion to dismiss, alleging Plaintiff filed an Amended Complaint on October 2, 2020. The Amended Complaint asserted claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, unjust enrichment, promissory estoppel, and unjust enrichment (violations of the “Litigation”)Ohio Consumer Sales Practices Act R.C. 1345.01 et seq. 23. On December 22March 28, 20212022, the U.S. District Court granted in part and denied in part ▇▇▇▇▇▇▇ House filed its Motion ’s motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ granted the Motion to stay the case, deferring ruling on the Motion and referred the case to mediationdismiss. 34. Following arms-length negotiations, the The Parties negotiated a settlement with the assistance of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇, Esq. ▇▇▇▇▇ (▇▇▇.) at a mediation on May 12December 19, 2022 2022, by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the all Litigation, including all claims Plaintiff and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House and related persons and entities, as set forth herein. 45. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition acknowledgement of the fact that the outcome of the Litigation Litigation, as with all litigation, is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 56. ▇▇▇▇▇▇▇ House Xavier University denies all claims of wrongdoing or liability that Plaintiff, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇▇ House’s position that it is not liable for, and has good strong defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved settled, resolved, and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or even as evidence of, any wrongdoing or liability. 6. The Parties now enter into this Settlement Agreement7. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members.the 78. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 89. In consideration of the covenants, agreements, and releases set forth herein, and for the other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties Party of the Released Claims, without costs as to Released PartiesParty, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. Plaintiff asserts that Pinnacle suffered a ransomware attack on its IT network systems on December 4, 2022, (“Incident”) that resulted in an unauthorized third party accessing files that contained the names, addresses, and/or Social Security numbers (“Private Information” or “Personal Information”) of current and former employees of Pinnacle. 2. On October 20July 13, 20212023, Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network filed a Class Action Complaint against the Defendant in June 2021 the United States District Court for the Northern District of Texas, Dallas Division, Case No. 3:23cv1559 (the “IncidentClass Action Complaint”), alleging . The complaint alleges claims for damages and equitable relief based on theories of negligence, negligence per se, breach of fiduciary dutyimplied contract, breach of confidencefiduciary duty, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 2. On December 22, 2021, ▇▇▇▇▇▇▇ House filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ granted the Motion to stay the case, deferring ruling on the Motion and referred the case to mediationenrichment. 3. Following arms-length negotiations, the Parties negotiated a settlement with the assistance of ▇▇▇. ▇▇▇ ▇. Gandhi (▇▇▇▇▇▇, Esq. .) at a mediation on May 12December 5, 2022 2023, by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the Litigation, including all claims Plaintiff and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House Pinnacle and related persons and entities, as set forth herein. 4. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 5. ▇▇▇▇▇▇▇ House Pinnacle denies all claims of wrongdoing or liability that Plaintiff, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇▇ HousePinnacle’s position that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House Pinnacle desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 65. The Parties now enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members.obtained 76. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 87. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On October 20The Parties expressly acknowledge that this Agreement is entered into solely for the purpose of compromising significantly disputed claims and that nothing herein is an admission of liability or wrongdoing by Defendants, 2021or any of them, Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ Houseor any of their Affiliates or personnel. Defendants specifically deny all of Plaintiff’s network claims as to liability and remedies in June 2021 the Litigation, any and all claims or allegations asserting violations of Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. (the “IncidentBIPA”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contractPlaintiff’s class and representative allegations, and unjust enrichment (any other wrongdoing alleged by Plaintiff or otherwise, and expressly reserve all rights to challenge all such claims and allegations upon all procedural and substantive grounds, including the “Litigation”)assertion of any and all defenses, if the Court does not approve this settlement. 2. On December 22January 15, 2021, ▇▇▇▇▇▇▇ House filed its Motion to Dismissafter a pre-filing investigation, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇Plaintiff ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ granted filed a putative class action lawsuit against Defendants alleging violations of the Motion to stay Illinois BIPA in the caseCircuit Court of ▇▇▇▇ County, deferring ruling on the Motion and referred the case to mediationIllinois, Chancery Division. 3. The Parties thereafter commenced settlement negotiations after Defendants provided Plaintiff’s counsel evidence confirming the putative class size. 4. Following extensive arms-length negotiations, the Parties have negotiated a settlement with that, if approved by the assistance of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇Court, Esq. at a mediation on May 12, 2022 by which the Parties agree and hereby wish to will resolve all matters pertaining to, claims arising from, or associated with the Litigation, including all claims under BIPA that Plaintiff and members of the Settlement Class Members (defined below) have or may have had against ▇▇▇▇▇▇▇ House and related persons and entitiesDefendants or the Releasees (as defined below), through the date on which the Parties sign this Agreement. FILED DATE: 5/6/2022 3:09 PM 2021CH00177 Defendants have represented that 465 employees who performed work at the Radisson Blu Aqua Hotel, as set forth defined herein, utilized the Time-Keeping System, as defined herein, between January 15, 2016, and January 10, 2019. Since January 10, 2019, Defendants and their Affiliates have not utilized the Time-Keeping System, as defined below, or any other timekeeping system that implicates the provisions of BIPA. 45. The Following arm’s length negotiations, the Parties have agreed now seek to enter into this Settlement Agreement to settle the Litigation on the terms and conditions set forth herein herein, in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 5. ▇▇▇▇▇▇▇ House denies all claims of wrongdoing or liability that Plaintiff, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇▇ House’s position that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 6. The Parties now enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, recognizing: recognizing (1) the existence of complex and contested issues of law and fact; , (2) the risks inherent in litigation; , (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; , (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; , and (5) the Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlementThus, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties Releasees of the Released Claims, without costs as to Released PartiesReleasees, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On October 20, 2021, Plaintiff filed Defendant is a class action lawsuit against digital pharmacy that operates a nationwide network of URAC- accredited mail order and specialty pharmacies. Defendant is a Delaware corporation with its principal place of business located at ▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 2. On December 22, 2021, ▇▇▇▇▇▇▇ House filed its Motion to Dismiss▇, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ granted . 2. The Litigation arose after Defendant began sending a notice letter (the Motion “Notice Letter”) on October 30, 2023, alerting Plaintiffs that their personally identifiable information (“PII”) and protected health information (“PHI”) (collectively referred to stay as “Private Information”) had been accessed by an unauthorized third party between August 30, 2023 and September 1, 2023 (the case, deferring ruling on the Motion and referred the case to mediation“Data Incident”). 3. Following arms-length negotiationsPlaintiffs filed their respective complaints in the United States District Court for the Northern District of California in or around November 2023. On December 5, 2023 the court issued an order consolidating the Plaintiffs’ individual cases into one consolidated case, the Parties negotiated a settlement with the assistance of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at a mediation on May 12, 2022 by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the aforementioned Litigation, including all claims Plaintiff and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House and related persons and entities, as set forth herein. 4. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 5. ▇▇▇▇▇▇▇ House Defendant denies all claims of wrongdoing or liability that PlaintiffPlaintiffs, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇▇ House▇▇▇’s position that it is not liable for, for and has good defenses to, to the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House Defendant desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed performed, or document created in relation to the Settlement Agreement or negotiation negotiation, or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liabilityliability of Defendant. 6. The Parties now enter into this Settlement Agreement. Plaintiff and Settlement Class Counsel have has conducted an investigation into a pre-suit investigation, reviewed informal discovery materials in preparation for and during the facts course of a mediation, and fully evaluated the law regarding risk of future litigation. Moreover, Settlement Class Counsel has fully evaluated the available facts, applicable law, and comparable settlements related to the Litigation and have concluded that a the proposed settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff Plaintiffs and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; , (2) the risks inherent in litigation; the Litigation, (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; , and (4) the magnitude of the benefits derived from the contemplated settlement proposed Settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be fully and finally settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, PlaintiffPlaintiffs, Settlement Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On or about October 2012, 20212022, Plaintiff filed Defendant became aware of a class action lawsuit against ▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 cyber-security incident impacting certain company systems (the “Data Incident”). The Data Incident impacted certain private and personally identifying information stored in Defendant’s files, alleging claims including full names and addresses, dates of negligencebirth, negligence per seSocial Security numbers, breach payment card numbers, driver’s license and/or state identification numbers, account and routing numbers, health insurance and medical information (these types of fiduciary dutyinformation, breach inter alia, being thereafter referred to as “protected health information” or “PHI”1 and “personally identifiable information” or “PII.” Specifically, the information of confidence, intrusion upon seclusion/invasion approximately 161,130 people may have been accessed as a result of privacy, breach of implied contract, and unjust enrichment (the “Litigation”)this Data Incident. 2. Defendant sent notice to Plaintiffs and the Settlement Class Members of the Data Incident on or about October 11, 2023. Shortly thereafter, Plaintiffs filed their respective Complaints, and the Court issued an order consolidating the cases into the instant action on November 29, 2023. On December 2213, 20212023 Plaintiffs filed their Consolidated Class Action Complaint, ▇▇▇▇▇▇▇ House which is the operative Complaint in this matter. On January 12, 2024 Defendant filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved Dismiss and to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ granted the Motion to stay the case, deferring ruling on the Motion and referred the case to mediationStrike Plaintiffs’ Consolidated Class Action Complaint. 3. After Defendant’s Motion to Dismiss was fully briefed, but prior to an Order on the Motion being entered, the Parties agreed to discuss the possibility of early resolution to minimize the costs and time expended through litigation. Following armsextensive arm’s-length negotiations, the Parties negotiated a settlement with the assistance of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at a mediation on May 12, 2022 by through which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated in any way with the Litigation, including all claims Plaintiff Plaintiffs and Settlement Class Members have have, had, or may have had against ▇▇▇▇▇▇▇ House Defendant and related persons and entitiesentities regarding the Data Incident, as set forth herein. 4. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, time and expense for both of the Parties. 5. ▇▇▇▇▇▇▇ House Defendant denies all claims of wrongdoing or liability that PlaintiffPlaintiffs, Settlement Class Members, Members or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇▇ House▇▇▇’s position that it is not liable for, for and has good defenses to, to the claims alleged in the 1 Protected Health Information (“PHI”) is a category of information which is protected under the Health Insurance Portability and Accountability Act. Litigation, ▇▇▇▇▇▇▇ House Defendant desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed performed, or document created in relation to the Settlement Agreement or negotiation negotiation, or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 6. The Parties now enter into this Settlement Agreement. Plaintiff and Settlement Class Counsel have has conducted an investigation into a pre-suit investigation, reviewed informal discovery materials in preparation for and during the facts course of the mediation, and fully evaluated the law regarding risk of future litigation. Moreover, Settlement Class Counsel has fully evaluated the available facts, applicable law, and comparable settlements related to the Litigation and have concluded that a the proposed settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff Plaintiffs and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; , (2) the risks inherent in the litigation; , (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; , and (4) the magnitude of the benefits derived from the contemplated settlement proposed Settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be fully and finally settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, PlaintiffPlaintiffs, Settlement Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On October 20November 1, 20212019, Plaintiff plaintiff ▇▇▇▇▇ ▇▇▇▇ filed a class action lawsuit against ▇▇▇Defendant TimeClock Plus, LLC alleging violations of the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. (“BIPA”) in the Circuit Court of ▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”)County, alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 2Illinois. On December 22, 2021, ▇▇▇▇▇▇▇ House filed its Motion The case is assigned to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇. 2. Defendant filed its answer and affirmative defenses to the complaint on January 15, 2020. Plaintiff subsequently filed a Motion for Leave to File First Amended Complaint instanter on March 20, 2020, in which Plaintiff seeks to substitute ▇▇▇▇ granted the ▇▇▇▇▇▇▇ as Plaintiff. The Motion to stay the case, deferring ruling on the Motion and referred the case to mediationremains pending. 3. Following armsThe Parties thereafter agreed to attempt to resolve the Litigation through participation in a remotely-length negotiationsconducted, full-day mediation session overseen by the Parties negotiated a settlement with the assistance of ▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇ ▇. Holderman (▇▇▇.) of JAMS in Chicago, EsqIllinois. 4. at During that mediation session and throughout the following weeks, the Parties negotiated a mediation on May 12, 2022 settlement by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the Litigation, including all claims Plaintiff and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House Defendant, its parents, predecessors, successors, holding companies, brands, subsidiaries, members, employees, board members, directors, officers, insurers, and related persons and entities, as set forth hereinassigns. 45. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, time and expense for both of the Partiesexpense. 56. ▇▇▇▇▇▇▇ House Defendant denies all claims charges of wrongdoing or liability of any kind whatsoever that Plaintiff, Plaintiff or Settlement Class Members, or anyone else Members have asserted in this Litigation or may assert in the futurefuture assert. Despite ▇▇▇▇▇▇▇ HouseDefendant’s position belief that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House Defendant desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action or proceeding relating to the matters being fully settled and finally resolved and released put to rest in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 67. The Following arms-length negotiations, including the full-day mediation with Judge ▇▇▇▇▇▇▇▇▇, the Parties now seek to enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, Class recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.;

FACTUAL BACKGROUND AND RECITALS. 1. On October 20January 24, 20212019, Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇▇ House based on a cyberattack on ▇▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”), alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment (the “Litigation”). 2. On December 22, 2021, ▇▇▇▇▇▇▇ House filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ granted filed a class action lawsuit against Defendant and Swissport International, Ltd., alleging violations of the Motion Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. (“BIPA”). Only Defendant was served in the Litigation. 2. Defendant initially moved to dismiss Plaintiff’s complaint. Prior to full briefing and resolution of Defendant’s motion, the Parties agreed to stay the case, deferring ruling on the Motion and referred the case Litigation to mediationexplore settlement. 3. To that end, in order to seek resolution of the Litigation, on January 30, 2020, the Parties participated in a formal, full-day mediation session with the ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇ Denlow (Ret.) of JAMS in Chicago, Illinois. 4. Following arms-length negotiations, the Parties negotiated a settlement with the assistance of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at a mediation on May 12, 2022 Judge Denlow by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or and associated with the Litigation, including all claims Plaintiff and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House Defendant and related persons and entitiesany Released Parties, as set forth that term is defined herein. 45. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, time and expense for both of the Partiesexpense. 56. ▇▇▇▇▇▇▇ House Defendant denies all claims charges of wrongdoing or liability of any kind whatsoever that Plaintiff, Plaintiff or Settlement Class Members, or anyone else Members have asserted in this Litigation or may assert in the futurefuture assert. Despite ▇▇▇▇▇▇▇ HouseDefendant’s position belief that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House Defendant desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action or proceeding relating to the matters being fully settled and finally resolved and released put to rest in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 67. The Following arms-length negotiations, including mediation before an experienced mediator, the Parties now seek to enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, Class recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.;

FACTUAL BACKGROUND AND RECITALS. 1. On October 20April 11, 20212022, Plaintiff ▇▇▇▇▇ ▇▇▇▇▇▇ filed a class action lawsuit against ▇▇▇▇▇▇▇ House in the Western District of Wisconsin based on a cyberattack on ▇▇▇▇▇▇▇ HouseMarten’s network in June from September 30, 2021 to October 4, 2021 (the “Data Incident”), alleging claims of negligence, negligence per se, breach of fiduciary dutyunjust enrichment, breach of confidence, intrusion upon seclusion/invasion of privacy, and breach of implied contract, . The Complaint alleged the Data Incident potentially impacted Plaintiff’s and unjust enrichment Settlement Class Members’ full names and Social Security numbers (the collectively referred to in this Settlement Agreement as “LitigationPrivate Information”). 2. On December 22March 17, 20212023, the Court granted in part and denied in part ▇▇▇▇▇▇’▇ House filed its Motion motion to Dismiss, which was then fully briefed by both Partiesdismiss Plaintiff’s Complaint thereby allowing only Plaintiff’s negligence claim to proceed. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediateDoc. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ granted the Motion to stay the case, deferring ruling on the Motion and referred the case to mediation23. 32. Following armsextensive arm’s-length negotiationsnegotiations culminating in a June 20, the Parties negotiated a settlement 2023 mediation with the assistance of experienced data breach class action mediator ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at the Parties negotiated a mediation on May 12, 2022 settlement by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated in any way with the Litigation, including all claims Plaintiff and Settlement Class Members have have, had, or may have had against ▇▇▇▇▇▇▇ House Marten and related persons and entitiesentities related to the Data Incident, as set forth herein. 43. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 54. ▇▇▇▇▇▇▇ House denies all claims of wrongdoing or liability that Plaintiff, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the future. Despite ▇▇▇▇▇▇’▇ House’s position that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 65. The Parties now enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement Settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.and

FACTUAL BACKGROUND AND RECITALS. 1. Plaintiffs assert that LendingTree, as a result of a code vulnerability, disclosed personal information, including unencrypted and unredacted full names, Social Security numbers, dates of birth, and addresses (“Private Information”) of consumers, to an unauthorized third party in February 2022. 2. On October 20July 11, 20212022, Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇▇▇▇▇▇ House based ▇▇▇▇▇ filed a Class Action Complaint against the Defendant that was subsequently amended on a cyberattack on ▇September 2, 2022, to add Plaintiff ▇▇▇▇▇▇ House’s network in June 2021 (the “Incident”), alleging ▇▇▇. The Litigation alleges claims for damages and equitable relief based on theories of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of an implied contract, unjust enrichment, and unjust enrichment (the “Litigation”). 2. On December 22, 2021, ▇▇▇▇▇▇▇ House filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ granted the Motion to stay the case, deferring ruling on the Motion and referred the case to mediationfor violations of North Carolina's Unfair Trade Practices Act. 3. Following arms-length negotiations, the Parties negotiated a settlement with the assistance of ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at a mediation on May 1230, 2022 2023, by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the Litigation, including all claims Plaintiff Plaintiffs and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House LendingTree and related persons and entities, as set forth herein. 4. Throughout their mediation session, the Parties engaged in an extensive evaluation and discussion of the relevant facts and law, and the Parties carefully considered the risk and uncertainties of continued litigation and all other factors bearing on the merits of settlement. 5. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, and expense for both of the Parties. 56. ▇▇▇▇▇▇▇ House LendingTree denies all claims of wrongdoing or liability that PlaintiffPlaintiffs, Settlement Class Members, or anyone else have asserted in this Litigation or may assert in the futurefuture based on the conduct alleged in the complaint. Despite ▇▇▇▇▇▇▇ House’s ▇▇▇▇▇'s position that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House LendingTree desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action relating to the matters being fully settled and finally resolved and released in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 67. The Parties now enter into this Settlement Agreement. Plaintiff Plaintiffs and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff Plaintiffs and the Settlement Class, recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s Plaintiffs' determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 78. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 89. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, PlaintiffPlaintiffs, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.

FACTUAL BACKGROUND AND RECITALS. 1. On October 20February 13, 2021, 2019 Plaintiff filed a class action lawsuit against ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ House based on filed a cyberattack on ▇▇▇class action lawsuit against Providence alleging violations of the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. (“BIPA”) and a common law count of negligence in the Circuit Court of ▇▇▇▇ House’s network in June 2021 (the “Incident”)County, alleging claims of negligence, negligence per se, breach of fiduciary duty, breach of confidence, intrusion upon seclusion/invasion of privacy, breach of implied contract, and unjust enrichment Illinois (the “Litigation”). 2. On December 22, 2021, The case was assigned to the ▇▇▇▇▇▇▇ House filed its Motion to Dismiss, which was then fully briefed by both Parties. On February 8, 2022, the Parties jointly moved to stay the case to allow the Parties to mediate. During the case management conference on February 9, 2022, Judge ▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇. 2. On May 24, 2019 Defendant filed Defendant’s Section 2-619.1 Motion to Dismiss. Prior to responding to the Motion, Plaintiff filed a Motion for Substitution of Judge which was granted on June 4, 2019 and the case was reassigned to Judge Sanjay Tailor. After this reassignment, the Parties began discussing the possibility of settlement and the Parties agreed that Plaintiff need not respond to the Motion to stay unless those discussions did not result in a settlement of the case, deferring ruling on the Motion and referred the case to mediationLitigation. 3. On September 17, 2019, the Parties participated in a formal, full-day mediation session with the ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ (▇▇▇.) of ADR Systems in Chicago, Illinois. 4. Following arms-length negotiations, the Parties have negotiated a settlement with the assistance of Judge ▇▇▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇, Esq. at a mediation on May 12, 2022 by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the Litigation, including all claims Plaintiff and Settlement Class Members have or may have had against ▇▇▇▇▇▇▇ House Defendant and related persons and entities, as set forth herein. 45. The Parties have agreed to settle the Litigation on the terms and conditions set forth herein in recognition that the outcome of the Litigation is uncertain and that achieving a final result through litigation would require substantial additional risk, uncertainty, discovery, time, time and expense for both of the Partiesexpense. 56. ▇▇▇▇▇▇▇ House Providence denies all claims charges of wrongdoing or liability of any kind whatsoever that Plaintiff, Plaintiff or Settlement Class Members, or anyone else Members have asserted in this Litigation or may assert in the futurefuture assert. Despite ▇▇▇▇▇▇▇ HouseDefendant’s position belief that it is not liable for, and has good defenses to, the claims alleged in the Litigation, ▇▇▇▇▇▇▇ House Defendant desires to settle the Litigation, and thus avoid the expense, risk, exposure, inconvenience, uncertainty, and distraction of continued litigation of any action or proceeding relating to the matters being fully settled and finally resolved and released put to rest in this Settlement Agreement. Neither this Settlement Agreement, nor any negotiation or act performed or document created in relation to the Settlement Agreement or negotiation or discussion thereof is, or may be deemed to be, or may be used as, an admission of, or evidence of, any wrongdoing or liability. 67. The Following arms-length negotiations, including mediation before an experienced mediator, the Parties now seek to enter into this Settlement Agreement. Plaintiff and Class Counsel have conducted an investigation into the facts and the law regarding the Litigation and have concluded that a settlement according to the terms set forth below is fair, reasonable, and adequate, and beneficial to and in the best interests of Plaintiff and the Settlement Class, Class recognizing: (1) the existence of complex and contested issues of law and fact; (2) the risks inherent in litigation; (3) the likelihood that future proceedings will be unduly protracted and expensive if the proceeding is not settled by voluntary agreement; (4) the magnitude of the benefits derived from the contemplated settlement in light of both the maximum potential and likely range of recovery to be obtained through further litigation and the expense thereof, as well as the potential of no recovery whatsoever; and (5) Plaintiff’s determination that the settlement is fair, reasonable, adequate, and will substantially benefit the Settlement Class Members. 7. Considering the risks and uncertainties of continued litigation and all factors bearing on the merits of settlement, the Parties are satisfied that the terms and conditions of this Settlement Agreement are fair, reasonable, adequate, and in their respective best interests. 8. In consideration of the covenants, agreements, and releases set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, it is agreed by and among the undersigned that the Litigation be settled and compromised, and that the Releasors release the Released Parties of the Released Claims, without costs as to Released Parties, Plaintiff, Class Counsel, or the Settlement Class, except as explicitly provided for in this Settlement Agreement, subject to the approval of the Court, on the following terms and conditions.;