The Court directed that the Notice be mailed to you because you or someone in your family or an investment account for which you serve as a custodian may have purchased or otherwise acquired Clover securities during the Settlement Class Period.  The Court has directed us to send you the Notice because, as a potential Settlement Class Member, you have a right to know about your options before the Court ruled on the approved Settlement.  Additionally, you have the right to understand how this class action lawsuit may generally affect your legal rights. On October 2, 2023, the Court approved the Settlement and the Plan of Allocation. The Claims Administrator will make payments pursuant to the Settlement after any objections and appeals are resolved.

The purpose of the Notice is to inform you of the existence of this case, that it is a class action, how you might be affected, and how to exclude yourself from the Settlement Class if you wished to do so. Please note that a Settlement Hearing was held by the Court on October 2, 2023, and on October 3, 2023, the Settlement and Plan of Allocation were approved. Please refer to the Final Judgment and Order of Dismissal With Prejudice, dated October 3, 2023, for more information.

The issuance of the Notice is not an expression of any opinion by the Court concerning the merits of any claim in the Action. The Court has approved the Settlement and Plan of Allocation. Payments to Authorized Claimants will be made after any appeals are resolved and after the completion of all claims processing.  Please be patient, as this process can take some time to complete.

On February 5, 2021, Timothy Bond commenced this Action in the United States District Court for the Middle District of Tennessee, styled Timothy Bond v. Clover Health Investments, Corp., et al., Case No. 3:21-cv-00096.

By Order dated April 23, 2021, Jabri was appointed Lead Plaintiff in the Action and Pomerantz LLP (“Pomerantz”) was appointed Lead Counsel for the putative class.

On June 28, 2021, Plaintiffs filed their First Amended Class Action Complaint (the “Complaint”), on behalf of the Settlement Class, asserting claims against Defendants under Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) and Rule 10b-5 promulgated thereunder, and against the Individual Defendants under Section 20(a) of the Exchange Act.  The Complaint alleges, among other things, that during the Settlement Class Period (as defined in the section entitled, "How Do I Know if I am Affected by the Settlement? Who is Included in the Class?" below), Defendants made false and misleading statements related to (i) legal or regulatory violations; (ii) regulatory investigations into those violations; (iii) the sources of Clover’s growth; (iv) use of Clover’s proprietary software by healthcare providers during patient visits; (v) compliance with GAAP; and (vi) compliance with the SEC Regulation S-K.  The Complaint further alleges that the prices of Clover securities were artificially inflated as a result of Defendants’ false and misleading statements, and that the price of Clover securities declined when the truth regarding Defendants’ alleged misrepresentations was revealed.  Defendants denied all of the allegations and moved to dismiss the Complaint.  By Order dated February 28, 2022, the Court denied Defendants’ motion to dismiss in full.  For the next four months, the Parties engaged in extensive negotiation and litigation regarding document discovery; the service of and response to requests for production; and extensive document review.  Defendants produced documents to Plaintiffs and Plaintiffs produced documents to Defendants.  On July 1, 2022, Plaintiffs filed a motion in support of class certification.  On September 30, 2022, Defendants filed a brief opposing class certification.  On October 31, 2022, Plaintiffs filed a reply brief in further support of class certification.

Plaintiffs and Defendants participated in mediation sessions in July and August 2022, before nationally recognized mediator Jed D. Melnick, Esq. and continued negotiations with Mr. Melnick’s assistance thereafter. As a result of the mediation, the Parties reached an agreement in principle to settle the Action for a cash payment of $22,000,000.00 for the benefit of the Settlement Class, subject to certain terms and conditions and the execution of a customary “long form” stipulation and agreement of settlement and related papers.

Based on their investigation, discovery, prosecution and mediation of the case, Plaintiffs and Lead Counsel have concluded that the terms and conditions of the Stipulation are fair, reasonable and adequate to Plaintiffs and the other members of the Settlement Class, and in their best interests.  Based on Plaintiffs’ oversight of the prosecution of this matter and with the advice of their counsel, each of the Plaintiffs has agreed to settle and release the claims raised in the Action pursuant to the terms and provisions of the Stipulation, after considering, among other things, (a) the substantial financial benefit that Plaintiffs and the other members of the Settlement Class will receive under the approved Settlement; (b) the significant risks and costs of continued litigation and trial; and (c) the desirability of permitting the approved Settlement to be consummated as provided by the terms of the Stipulation.

The Stipulation and the Settlement constitute a compromise of matters that are in dispute among the Parties.  Defendants have entered into the Stipulation solely to eliminate the uncertainty, burden and expense of further protracted litigation.  Each of the Defendants denies any wrongdoing, and the Settlement and Stipulation shall in no event be construed or deemed to be evidence of or an admission or concession on the part of any of the Defendants with respect to any claim or allegation of any fault, liability, wrongdoing, or damage whatsoever, or any infirmity in the defenses that the Defendants have, or could have, asserted.  Defendants expressly deny that Plaintiffs have asserted any valid claims as to any of them, and expressly deny any and all allegations of fault, liability, wrongdoing, or damages whatsoever. The Stipulation and the Settlement also shall in no event be construed or deemed to be evidence of or an admission or concession on the part of Plaintiffs of an infirmity in any of the claims asserted in the Action, or an admission or concession that any of the Defendants’ defenses to liability had any merit.

On May 26, 2023, the Court preliminarily approved the Settlement, authorized the Notice to be disseminated to potential Settlement Class Members, and scheduled the Settlement Hearing to consider, among other things, whether to grant final approval to the Settlement.

On October 2, 2023, the Court approved the Settlement and Plan of Allocation. 

If you are a member of the Settlement Class, you are subject to the Settlement, unless you file a timely and valid request to be excluded. The Settlement Class consists of:

all persons or entities who purchased or otherwise acquired Clover securities (including Clover warrants) between October 6, 2020, and February 3, 2021, both dates inclusive.¹

Excluded from the Class are Clover, the Individual Defendants, the officers and directors of the Company, at all relevant times, members of their immediate families and their legal representatives, heirs, successors or assigns and any entity in which Defendants have or had a controlling interest.  Also excluded from the Settlement Class are any persons and entities who or which properly exclude themselves by filing a valid and timely request for exclusion that is accepted by the Court.

PLEASE NOTE: RECEIPT OF THE NOTICE DOES NOT MEAN THAT YOU ARE A SETTLEMENT CLASS MEMBER OR THAT YOU WILL BE ENTITLED TO RECEIVE PROCEEDS FROM THE SETTLEMENT. IF YOU ARE A SETTLEMENT CLASS MEMBER AND YOU WISH TO BE POTENTIALLY ELIGIBLE TO PARTICIPATE IN THE DISTRIBUTION OF PROCEEDS FROM THE SETTLEMENT, YOU ARE REQUIRED TO SUBMIT THE CLAIM FORM THAT IS BEING DISTRIBUTED WITH THE NOTICE AND THE REQUIRED SUPPORTING DOCUMENTATION AS SET FORTH THEREIN POSTMARKED NO LATER THAN OCTOBER 9, 2023.

¹On January 7, 2021, the merger between Clover Health Investments, Corp. and Social Capital Hedosophia Holdings Corp. III (“SCH”) was consummated (the “Merger”). Prior to the Merger, SCH’s Class A ordinary shares, public warrants, and units were listed on the New York Stock Exchange (“NYSE”) under the ticker symbols “IPOC,” “IPOC.WS,” and “IPOC.U,” respectively. Each SCH warrant entitled the holder thereof to purchase one SCH Class A ordinary share at a price of $11.50 per share. Each SCH unit (“SCH Unit”) consisted of one Class A ordinary share and one-third of one public warrant. As a result of and upon the effective time of the Merger: (1) each of the then issued and outstanding SCH Class A ordinary shares automatically converted, on a one-for-one basis, into a share of Clover Class A common stock; (2) each of the then issued and outstanding SCH Class B ordinary shares automatically converted, on a one-for-one basis, into a share of Clover Class A common stock; (3) each then issued and outstanding SCH warrant automatically converted into a Clover warrant; and (4) each of the then issued and outstanding SCH Units that had not been previously separated into the underlying SCH Class A ordinary shares and SCH warrants upon the request of the holder thereof, was cancelled, entitling the holder thereof to one share of Clover Class A common stock and one-third of one Clover warrant. The continuing company was renamed “Clover Health Investments, Corp,” and the Company’s Class A stock and warrants were listed on the NASDAQ Stock Market (“Nasdaq”) under the ticker symbols “CLOV and “CLOVW,” respectively. The Company did not have publicly traded units followingly the closing of the Merger. Herein, SCH Class A ordinary shares (IPOC), SCH warrants (IPOC.WS), SCH Units (IPOC.U), Clover Class A stock (CLOV) and Clover warrants (CLOVW) are collectively referred to as “Clover Securities.” SCH Class A ordinary shares (IPOC) and Clover Class A stock (CLOV) are collectively referred to as “Clover Common Stock.” SCH warrants (IPOC.WS) and Clover warrants (CLOWV) are collectively referred to as “Clover Warrants.”

Plaintiffs and Lead Counsel believe that the claims asserted against Defendants have merit.  They recognize, however, the expense and length of continued proceedings necessary to pursue their claims against Defendants through further motion practice, trial and appeals, as well as the very substantial risks they would face in establishing liability and damages.  Plaintiffs and Lead Counsel recognized that Defendants had numerous avenues of attack that could preclude a recovery.  For example, Defendants would assert that their statements were not materially false and misleading, and that even if they were, they did not cause any damage to the Settlement Class.  Even if the hurdles to establishing liability were overcome, the amount of damages that could be attributed to the allegedly false statements would be hotly contested.  Plaintiffs would have to prevail at several stages – class certification, motions for summary judgment, trial, and if they prevailed on those, on the appeals that would be likely to follow.  Thus, there were very significant risks attendant to the continued prosecution of the Action.

In light of these risks, the amount of the Settlement and the immediacy of recovery to the Settlement Class, Plaintiffs and Lead Counsel believe that the proposed Settlement is fair, reasonable and adequate, and in the best interests of the Settlement Class.  Plaintiffs and Lead Counsel believe that the Settlement provides a substantial benefit to the Settlement Class, namely $22,000,000.00 in cash (less the various deductions described in the Notice), as compared to the risk that the claims in the Action would produce a smaller or no recovery after summary judgment, trial and appeals, possibly years in the future.

Defendants have denied the claims asserted against them in the Action and deny having engaged in any wrongdoing or violation of law of any kind whatsoever.  Defendants have agreed to the Settlement solely to eliminate the burden and expense of continued litigation. Accordingly, as noted above, the Settlement may not be construed as an admission of any wrongdoing by Defendants.

As a Settlement Class Member, you are represented by Plaintiffs and Lead Counsel, unless you entered an appearance through counsel of your own choice at your own expense.  You are not required to retain your own counsel, but if you choose to do so, such counsel must have filed a notice of appearance on your behalf and must have served copies of his or her appearance on the attorneys listed in the section titled “When And Where Will The Court Decide Whether To Approve The Settlement?” below.

If you are a Settlement Class Member and do not wish to remain a Settlement Class Member, you may exclude yourself from the Settlement Class by following the instructions in the section entitled, “What If I Do Not Want To Be A Member Of The Settlement Class?  How Do I Exclude Myself?” below. Please note that the deadline to exclude yourself from the Settlement has passed. 

If you are a Settlement Class Member and you wish to object to the Settlement, the Plan of Allocation, or Lead Counsel’s application for attorneys’ fees and reimbursement of Litigation Expenses, and if you do not exclude yourself from the Settlement Class, you may present your objections by following the instructions in the section entitled, “When And Where Will The Court Decide Whether To Approve The Settlement?” below. Please note that the deadline to object to the Settlement has passed. 

If you are a Settlement Class Member and you do not exclude yourself from the Settlement Class, you will be bound by any orders issued by the Court. The Settlement has been approved, and the Court has entered a judgment (the “Judgment”).  The Judgment dismisses with prejudice the claims against Defendants and will provide that, without further action by anyone, upon the Effective Date of the Settlement, Plaintiffs and each of the other Settlement Class Members, on behalf of themselves, and their respective heirs, executors, administrators, predecessors, successors, and assigns, assignees, employees, associates, insurers, co-insurers, reinsurers, spouses, trustees, general or limited partners or partnerships, limited liability companies, members, stockholders, underwriters, personal or legal advisors or representatives, estates, or other individuals or entities in which they have a controlling interest or which is related to or affiliated with them, any members of their immediate families, or any trusts for which any of them are trustees, settlors, or beneficiaries, and the predecessors, successors, administrators and assigns of each of the foregoing,  in their capacities as such, and anyone claiming through or on behalf of any of them, regardless of whether they execute and deliver a proof of claim and release and regardless of whether they share in the Settlement Fund, shall be deemed to have, and by operation of the Stipulation, of law, and of the Judgment shall have fully, finally and forever compromised, settled, released, resolved, relinquished, waived and discharged each and every Released Plaintiffs’ Claim against the Defendants’ Releasees, and covenant not to commence, institute, intervene in, participate in, or prosecute, and shall forever be barred and enjoined from prosecuting any or all of the Released Plaintiffs’ Claims against any of the Defendants’ Releasees in any court of law or equity, arbitration tribunal, administrative forum, or other forum of any kind or character, whether brought directly, in a representative capacity, derivatively, or in any other capacity.

“Released Plaintiffs’ Claims” means all claims, rights and causes of action, duties, obligations, demands, actions, debts, sums of money, suits, contracts, agreements, promises, damages, and liabilities, whether known claims or Unknown Claims, contingent or non-contingent, or suspected or unsuspected, whether foreign or domestic, whether arising under federal, state, common, or foreign law, rules, or regulations, that have been asserted, could have been asserted, or could be asserted in the future against Defendants or any other of Defendants’ Releasees that (i) arise out of, or relate in any way to, or are based upon, the allegations, transactions, acts, facts, events, matters, occurrences, representations or omissions involved, set forth, alleged or referred to in the Complaint or in any of the prior complaints in this Action and (ii) in any way are based upon or related to, directly or indirectly, the purchase or sale or other acquisition or disposition, or holding, of Clover securities during the Settlement Class Period.  Released Plaintiffs’ Claims do not include (i) any claims relating to the enforcement of the Settlement; and (ii) any claims of any person or entity who or which submits a request for exclusion from the Settlement Class that is accepted by the Court.

 “Defendants’ Releasees” means Defendants and any and all of their related parties in any forum, including, without limitation, any and all of their current or former parents, subsidiaries, affiliates, predecessors, successors, divisions, investment funds, joint ventures, and general or limited partnerships, and each of their respective current or former officers, directors, trustees, partners, members, contractors, auditors, principals, agents, managing agents, employees, attorneys, accountants, investment bankers, underwriters, insurers in their capacities as such, as well as each of the Individual Defendants’ immediate family members, heirs, executors, personal or legal representatives, estates, beneficiaries, predecessors, successors, and assigns.

“Unknown Claims” means any Released Plaintiffs’ Claims which Plaintiffs, any other Settlement Class Member, or any other Plaintiffs’ Releasee (as defined below) does not know or suspect to exist in his, her or its favor at the time of the release of such claims, and any Released Defendants’ Claims (as defined in paragraph 31 below) which any Defendant or any other Defendants’ Releasee does not know or suspect to exist in his, her or its favor at the time of the release of such claims, which, if known by him, her or it, might have affected his, her or its decision(s) with respect to this Settlement.  With respect to any and all Released Claims, the Parties stipulate and agree that, upon the Effective Date of the Settlement, Plaintiffs and Defendants shall expressly waive, and each of the other Settlement Class Members and each of the other Plaintiffs’ Releasees and Defendants’ Releasees shall be deemed to have waived, and by operation of the Judgment, shall have expressly waived, any and all provisions, rights, and benefits conferred by any law of any state or territory of the United States, or principle of common law or foreign law, which is similar, comparable, or equivalent to California Civil Code § 1542, which provides:

A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party.

Plaintiffs and Defendants acknowledge, and each of the other Settlement Class Members and each of the other Plaintiffs’ Releasees and Defendants’ Releasees shall be deemed by operation of law to have acknowledged, that the foregoing waiver was separately bargained for and a key element of the Settlement.

The Judgment provides that, upon the Effective Date of the Settlement, Defendants, on behalf of themselves, and their respective heirs, executors, administrators, predecessors, successors, and assigns, in their capacities as such, shall be deemed to have, and by operation of the Stipulation, of law, and of the Judgment shall have fully, finally, and forever compromised, settled, released, resolved, relinquished, waived, and discharged each and every Released Defendants’ Claim (as defined below) against any of the Plaintiffs’ Releasees (as defined below), and shall forever be barred and enjoined from prosecuting any or all of the Released Defendants’ Claims against any of the Plaintiffs’ Releasees.

“Released Defendants’ Claims” means all claims, rights and causes of action, duties, obligations, demands, actions, debts, sums of money, suits, contracts, agreements, promises, damages, and liabilities, whether known claims or Unknown Claims, contingent or non-contingent, or suspected or unsuspected, whether foreign or domestic, whether arising under federal, state, common, or foreign law, rules, or regulations, that arise out of or relate in any way to the institution, prosecution, or settlement of the claims against the Defendants in the Action.  Released Defendants’ Claims do not include any claims relating to the enforcement of the Settlement or any claims against any person or entity who or which submits a request for exclusion from the Settlement Class that is accepted by the Court, and further does not include claims or causes of action of a Defendant (including their affiliates) against any of their current or former employees, agents, or consultants arising out of any breach of an obligation, contractual or otherwise, owed to any of the Defendants (or their affiliates).

“Plaintiffs’ Releasees” means (i) Plaintiffs, all members of the Settlement Class, Lead Counsel and all other counsel for Plaintiffs, (ii) each of their respective immediate family members (for individuals) and each of their direct or indirect parent entities, subsidiaries, related entities, and affiliates, any trust of which any Settlement Class Member is the settler or which is for the benefit of any Settlement Class Member and/or member(s) of his or her immediate family, and (iii) for any of the entities listed in parts (i) or (ii), their respective past and present general partners, limited partners, principals, shareholders, joint venturers, officers, directors, managing directors, employees, contractors, consultants, auditors, accountants, financial advisors, investment bankers, insurers, trustees, trustors, agents, attorneys, predecessors, successors, assigns, heirs, executors, and any controlling person thereof, in their capacities as such, and any entity in which a Settlement Class Member has a controlling interest.  Plaintiffs’ Releasees do not include any persons and entities who or which exclude themselves by submitting a request for exclusion from the Settlement Class that is accepted by the Court.

The Judgment also provides that, upon the Effective Date, to the extent allowed by law, the Stipulation shall operate conclusively as an estoppel and full defense in the event, and to the extent, of any claim, demand, action, or proceeding brought by a Settlement Class Member against any of the Defendants’ Releasees with respect to any Released Plaintiffs’ Claim, or brought by a Defendant against any of the Plaintiffs’ Releasees with respect to any Released Defendants’ Claim.

The Judgment, among other things, provides for the dismissal with prejudice of the Action against the Defendants, without costs to any Party, except for the payments expressly provided for in the Stipulation.

For further information, please review the Final Judgment and Order of Dismissal With Prejudice, dated October 3, 2023. 

To be potentially eligible for a payment from the proceeds of the Settlement, you must be a member of the Settlement Class and you must timely complete and return the Claim Form with adequate supporting documentation postmarked no later than October 9, 2023.  A Claim Form is included with the Notice, or you may obtain one from this website, or you may request that a Claim Form be mailed to you by calling the Claims Administrator toll free at 1-800-877-381-0387.  Please retain all records of your ownership of and transactions in Clover securities, as they may be needed to document your Claim.  If you request exclusion from the Settlement Class or do not submit a timely and valid Claim Form, you will not be eligible to share in the Net Settlement Fund.

At this time, it is not possible to make any determination as to how much any individual Settlement Class Member may receive from the Settlement.

Pursuant to the Settlement, Defendants have agreed pay twenty-two million dollars ($22,000,000.00) in cash.  The Settlement Amount will be deposited into an escrow account.  The Settlement Amount plus any interest earned thereon is referred to as the “Settlement Fund.” The “Net Settlement Fund” (that is, the Settlement Fund less (a) all federal, state and/or local taxes (including any interest or penalties thereon) on any income earned by the Settlement Fund, the reasonable costs incurred in connection with determining the amount of and paying taxes owed by the Settlement Fund (including reasonable expenses of tax attorneys and accountants), and all taxes imposed on payments by the Settlement Fund, including withholding taxes; (b) the costs and expenses incurred in connection with providing notice to Settlement Class Members and administering the Settlement on behalf of Settlement Class Members; and (c) any attorneys’ fees and Litigation Expenses awarded by the Court) will be distributed to Settlement Class Members who submit valid Claim Forms, in accordance with the approved Plan of Allocation.

Neither Defendants nor any other person or entity that paid any portion of the Settlement Amount on their behalf are entitled to get back any portion of the Settlement Fund once the Court’s order or judgment approving the Settlement becomes final. Defendants shall not have any liability, obligation or responsibility for the administration of the Settlement, the disbursement of the Net Settlement Fund or the plan of allocation.

Any Settlement Class Member who fails to submit a Claim Form postmarked on or before October 9, 2023, shall be fully and forever barred from receiving payments pursuant to the Settlement but will in all other respects remain a Settlement Class Member and be subject to the provisions of the Stipulation, including the terms of any Judgment entered and the releases given. This means that each Settlement Class Member releases the Released Plaintiffs’ Claims (as defined in the section entitled, "How Are Class Members Affected by the Settlement?" above) against the Defendants’ Releasees (also defined in the section entitled,  "How Are Class Members Affected by the Settlement?" above) and will be enjoined and prohibited from filing, prosecuting, or pursuing any of the Released Plaintiffs’ Claims against any of the Defendants’ Releasees whether or not such Settlement Class Member submits a Claim Form.

Participants in and beneficiaries of a plan covered by ERISA (“ERISA Plan”) should NOT include any information relating to their transactions in Clover securities held through the ERISA Plan in any Claim Form that they may submit in this Action. They should include ONLY those Clover securities that they purchased or acquired outside of the ERISA Plan.

The Court has reserved jurisdiction to allow, disallow, or adjust on equitable grounds the Claim of any Settlement Class Member.

Each Claimant shall be deemed to have submitted to the jurisdiction of the Court with respect to his, her or its Claim Form.

Only Settlement Class Members will be eligible to share in the distribution of the Net Settlement Fund. Persons and entities that are excluded from the Settlement Class by definition or that exclude themselves from the Settlement Class pursuant to request will not be eligible to receive a distribution from the Net Settlement Fund and should not submit Claim Forms.

The Plan of Allocation can be reviewed beginning on page 13 of the Notice.

On October 2, 2023, the Court approved the Settlement and Plan of Allocation. 

On October 3, 2023, Lead Counsel was awarded attorneys’ fees in the amount of $5,500,000, and expenses in the amount of $365,656.44, plus any applicable interest, such amounts to be paid out of the Settlement Fund immediately upon entry of the Final Judgment and Order of Dismissal With Prejudice, dated October 3, 2023. Lead Counsel shall thereafter be solely responsible for allocating the attorneys’ fees and expenses amongst Lead Plaintiffs’ Counsel in a manner which they, in good faith, believe reflects the contributions of such counsel to the institution, prosecution, and settlement of the Action. 

Lead Plaintiff was also awarded $60,000 as a compensatory award for reasonable costs and expenses directly relating to the representation of the Settlement Class. These amounts are to be paid from the Settlement Fund upon the Effective Date of the Settlement. Named Plaintiff was awarded $20,000, as a compensatory award for reasonable costs and expenses directly relating to the representation of the Settlement Class, such amounts to be paid also from the Settlement Fund upon the Effective Date of the Settlement. 
 

Each Settlement Class Member will be bound by all determinations and judgments in this lawsuit, whether favorable or unfavorable, unless such person or entity mails or delivers a written request for exclusion from the Settlement Class. The exclusion request must have been received no later than September 11, 2023. The deadline to exclude yourself from the Settlement has now passed.

The Court held the Settlement Hearing on October 2, 2023 at 3:30 p.m., before the Honorable Aleta Trauger at the United States District Court for the Middle District of Tennessee, Courtroom 6C, Fred D. Thompson U.S. Courthouse and Federal Building, 719 Church Street, Suite 1300, Nashville, TN 37203. 

At the Settlement hearing, the Court decided to grant approval of the Settlement, the Plan of Allocation, and award of Attorneys' and Lead Plaintiff's Fees. 

If you purchased or otherwise acquired Clover securities during the Settlement Class Period for the beneficial interest of persons or organizations other than yourself, you must either (a) within seven (7) calendar days of receipt of the Postcard Notice, request from the Claims Administrator sufficient copies of the Postcard Notice to forward to all such beneficial owners and within seven (7) calendar days of receipt of those Postcard Notices forward them to all such beneficial owners; or (b) within seven (7) calendar days of receipt of the Postcard Notice, provide a list of the names and addresses of all such beneficial owners to c/o Clover Health Securities Litigation, c/o JND Legal Administration, PO Box 91462, Seattle, WA 98111.  If you choose the second option, the Claims Administrator will send a copy of the Postcard Notice to the beneficial owners.  Upon full compliance with these directions, such nominees may seek reimbursement of their reasonable expenses actually incurred, by providing the Claims Administrator with proper documentation supporting the expenses for which reimbursement is sought.  Copies of this Notice and the Claim Form may also be obtained from the website maintained by the Claims Administrator, www.CloverHealthSecuritiesLitigation.com, or by calling the Claims Administrator toll-free at 1-877-381-0387.

For more detailed information about the matters involved in the Action, you are referred to the papers on file in the Action, including the Stipulation, which are available online via the Public Access to Court Electronic Records (PACER) system at https://pacer.uscourts.gov or will be provided by Lead Counsel upon request. Additionally, copies of the Stipulation and any related orders entered by the Court will be posted on this website.

All inquiries concerning the Notice and the Claim Form should be directed to:

DO NOT CALL OR WRITE THE COURT, THE OFFICE OF THE CLERK OF THE COURT, DEFENDANTS OR THEIR COUNSEL REGARDING THE NOTICE.