Common use of Purpose of this Policy Clause in Contracts

Purpose of this Policy. The purchase or sale of securities while possessing material nonpublic (“inside”) information or the disclosure of inside information (“tipping”) to others who may trade in such securities is sometimes referred to as “▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇” and is prohibited by federal and state securities laws. As an essential part of your work, you may have or obtain access to material nonpublic information about Acacia Research Corporation and/or its subsidiaries (including information about other companies with which Acacia does, or may do, business). When we refer in this Policy to “Acacia” or the “Company,” we are referring to Acacia Research Corporation and all its subsidiaries and divisions worldwide. This ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇ Policy (the “Policy”) was adopted by Acacia Research Corporation’s Board of Directors on February 1, 2019 to prevent illegal ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇ and to avoid even the appearance of improper conduct on the part of any Company director, officer, employee or contractor. This Policy is designed to protect and further the reputation of Acacia for integrity and ethical conduct. Remember, however, the ultimate responsibility for complying with the securities laws, adhering to this Policy and avoiding improper transactions rests with you. It is imperative that you use your best judgment.

Purpose of this Policy. The purchase or sale of securities while possessing material nonpublic (“inside”) information or the disclosure of inside information (“tipping”) to others who may trade in such securities is sometimes referred to as “▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇” and is prohibited by federal and state securities laws. As an essential part of your work, you may have or obtain access to material nonpublic information about Acacia Research Corporation and/or its subsidiaries (including information about other companies with which Acacia does, or may do, business). When we refer in this Policy to “Acacia” or the “Company,” we are referring to Acacia Research Corporation and all its subsidiaries and divisions worldwide. This ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇ Policy (the “Policy”) was adopted by Acacia Research Corporation’s Board of Directors on February 1, 2019 to prevent illegal ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇ and to avoid even the appearance of improper conduct on the part of any Company director, officer, employee or contractor. This Policy is designed to protect and further the reputation of Acacia for integrity and ethical conduct. Remember, however, the ultimate responsibility for complying with the securities laws, adhering to this Policy and avoiding improper transactions rests with you. It is imperative that you use your best judgment.