STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • July 22nd, 2022
This Stipulation and Agreement of Settlement, dated as of June 24, 2022 (the “Stipulation”) is entered into between (a) lead plaintiff Fadi E. Rahal (“Lead Plaintiff”), on behalf of himself and the Settlement Class (defined below); and (b) defendant Groupon, Inc. (“Groupon” or the “Company”) and defendants Rich Williams (“Williams) and Melissa Thomas (“Thomas”) (collectively, the “Individual Defendants,” and, together with Groupon, “Defendants”), and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”).1 Subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever compromise, settle, release, resolve, and dismiss with prejudice the Action and all claims asserted therein against Defendants.