Inovalon Securities Settlement
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Welcome to the Inovalon Securities Settlement Website

This website has been established to provide general information related to the proposed settlement of the case referred to as Yi Xiang v. Inovalon Holdings, Inc., et al., Civil Action No. 1:16-cv-04923-VM-KNF (the "Action"), pending before the United States District Court for the Southern District of New York (the "Court"). The capitalized terms used on this website, and not otherwise defined, shall have the same meanings ascribed to them in the Stipulation of Settlement (the "Stipulation") dated February 19, 2019, which can be found and downloaded by clicking on the Case Documents tab above. Your rights may be affected by the Settlement if you purchased or otherwise acquired Inovalon Holdings, Inc. ("Inovalon") common stock on or before August 5, 2015 (the "Class").

The law firm of Robbins Geller Rudman & Dowd LLP represents you and other Class Members. You will not be charged for these lawyers. They will be paid from the Settlement Fund to the extent the Court approves their application for fees and expenses. If you want to be represented by your own lawyer, you may hire one at your own expense.

WHAT IS THIS LAWSUIT ABOUT?

As more fully described in the Notice of Proposed Settlement of Class Action (the "Notice"), the initial complaint in this action was filed on June 24, 2016. On September 20, 2016, the Court appointed Lead Plaintiff and Robbins Geller Rudman & Dowd LLP as Lead Counsel.

In an effort to conserve judicial resources, save litigation expenses, and attempt to settle the litigation, the parties engaged the services of Michelle Yoshida, Esq., an experienced mediator. The Settling Parties engaged in arm’s-length negotiations during the mediation session, but were unable to reach an agreement. Following the mediation, the Settling Parties continued to pursue discovery activity while settlement discussions continued through Ms. Yoshida. On January 17, 2019, the Settling Parties reached an agreement in principle to resolve the Litigation, subject to the negotiation of the terms of a Stipulation of Settlement and approval by the Court.

WHAT DOES THE SETTLEMENT PROVIDE?

The Settlement, if approved, will result in the creation of a cash settlement fund of $17,000,000 (the “Settlement Amount”). The Settlement Amount, plus accrued interest (the “Settlement Fund”) and minus the costs of the Notice and all costs associated with the administration of the Settlement, as well as any attorneys’ fees and expenses that may be approved by the Court (the “Net Settlement Fund”), will be distributed to eligible Class Members pursuant to the Plan of Allocation that is described in the Notice.

ADDITIONAL INFORMATION

Although the information in this website is intended to assist you, it does not replace the information contained in the Notice and Stipulation, both of which can be found and downloaded by clicking on the Case Documents tab above. We recommend that you read the Notice and other relevant case documents carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

SUBMIT A PROOF OF CLAIM The only way to be eligible to receive a payment from the Settlement. Proofs of Claim must be postmarked (if mailed) or received (if submitted online) on or before July 30, 2019.
EXCLUDE YOURSELF FROM THE SETTLEMENT BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION Get no payment. This is the only option that potentially allows you to ever be part of any other lawsuit against any of the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement. Should you elect to exclude yourself from the Class, you should understand that Defendants and the other Released Defendant Parties will have the right to assert any and all defenses they may have to any claims that you may seek to assert, including, without limitation, the defense that any such claims are untimely under applicable statutes of limitations and statutes of repose. Exclusions must be postmarked on or before June 21, 2019.
OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION Write to the Court about why you do not like the Settlement, the Plan of Allocation and/or the request for attorneys’ fees and expenses. You will still be a Member of the Class. Objections must be received by the Court and counsel for the Settling Parties on or before June 21, 2019.
GO TO THE HEARING ON JULY 12, 2019, AND FILE A NOTICE OF INTENTION TO APPEAR Ask to speak in Court about the fairness of the Settlement. Requests to speak must be received by the Court and counsel for the Settling Parties on or before June 21, 2019. If you submit a written objection, you may (but you do not have to) attend the hearing.
DO NOTHING Receive no payment. You will, however, still be a Class Member, which means that you give up your right to ever be part of any other lawsuit against the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement and you will be bound by any judgments or orders entered by the Court in the Litigation.

IMPORTANT DATES AND DEADLINES

Submit Proof of Claim: July 30, 2019
Request Exclusion: June 21, 2019
File Objection: June 21, 2019
File Notice of Intention to Appear: June 21, 2019
Court Hearing on Fairness of Settlement: July 12, 2019, at 10:00 a.m. ET