Notice of Pendency of Class Action

Based upon these considerations, the Plaintiffs and Class Counsel have concluded that it is in the
best interests of the Plaintiffs and the Class to settle the claims asserted in this lawsuit on the
terms and conditions agreed upon in the proposed settlement.
8. The proposed settlement provides significant benefits to the Plaintiffs and the
Class and will eliminate the burden and expense of further litigation and the risk that nothing will
be recovered for the Plaintiffs and the Class if the case goes to judgment, and it will finally put to
rest the claims of the Plaintiffs individually and on behalf of the Class that were or could have
been made against Iomega in this action.
a. The proposed settlement will become effective if the conditions of the
Stipulation are met and if the Court enters a final judgment which
approves the settlement (the “Final Judgment”) and the Final Judgment is
affirmed, if there is any appeal, or is no longer subject to appeal.
b. If the proposed settlement is approved by the Court, all Class
Members will be deemed to have released and discharged all Class
Claims, including claims for damage to the Zip® Drives and/or losses
from the corruption or loss of data as a result of such damage, against
the Releasees, and shall be barred from asserting any Class Claims
against the Releasees.
9. The Plaintiffs and the Class have been represented in this litigation by the
following law firms ("Class Counsel"):
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