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  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview
  • SEAN DEBOTTE VS. KING DIGITAL ENTERTAINMENT PLC SECURITIES/INVESTMENT document preview 
						
                                
Preview

                                ww

ROBBINS GELLER RUDMAN

& DOWD LLP
SHAWN A. WILLIAMS (213113)
Post Montgomery Center
One Montgomery Street, Suite 1800
San Francisco, CA 94104
Telephone: 415/288-4545
415/288-4534 (fax)

—and —

JAMES I. JACONETTE (179565)
655 West Broadway, Suite 1900
San Diego, CA 92101
Telephone: 619/231-1058
619/231-7423 (fax)

Lead Counsel for Plaintiffs

ELECTRONICALLY
FILED

Supertor Court of Calffornia,
County of San Francisco

04/10/2017
Clerk of the Court
BY:SANDRA SCHIRO

Deputy Clerk

SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
JOHN T. JASNOCH (281605)

707 Broadway, Suite 1000

San Diego, CA 92101

Telephone: 619/233-4565

619/233-0508 (fax)

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO

In re KING DIGITAL ENTERTAINMENT plc)
SHAREHOLDER LITIGATION

Lead Case No. CGC-15-544770
CLASS ACTION

This Document Relates To:

ALL ACTIONS.

DECLARATION OF JAMES I. JACONETTE
FILED ON BEHALF OF ROBBINS GELLER
RUDMAN & DOWD LLP IN SUPPORT OF
APPLICATION FOR AWARD OF
ATTORNEYS’ FEES AND EXPENSES

Assigned for All Purposes to the
Honorable Curtis E.A. Karnow

Date: May 18, 2017

Time: 9:00 a.m.

Dept. 304

Date Action Filed: 03/17/15

DECLARATION OF JAMES I. JACONETTE FILED ON BEHALF OF ROBBINS GELLER RUDMAN & DOWD
LLP IN SUPPORT OF APPLICATION FOR AWARD OF ATTORNEYS’ FEES AND EXPENSES

1244391_1ww

I, JAMES I. JACONETTE, declare as follows:

1. Jama member of the firm of Robbins Geller Rudman & Dowd LLP (“Robbins Geller”
or the “Firm”). Iam submitting this declaration in support of my Firm’s application for an award of
attorneys’ fees, expenses and charges (“expenses”) in connection with services rendered in the above-
entitled action (the “Litigation”).

2. This Firm is counsel for City of Taylor Police and Fire Retirement System and co-lead
counsel for plaintiffs and the Class.

3. The information in this declaration regarding the Firm’s time and expenses is taken from
time and expense printouts and supporting documentation prepared and/or maintained by the Firm in
the ordinary course of business. I am the partner who oversaw and/or conducted the day-to-day
activities in the Litigation and I reviewed these printouts (and backup documentation where necessary
or appropriate) in connection with the preparation of this declaration. The purpose of this review was to
confirm both the accuracy of the entries on the printouts as well as the necessity for, and reasonableness
of, the time and expenses committed to the Litigation. Asa result of this review, reductions were made
to both time and expenses in the exercise of billing judgment. Based on this review and the adjustments
made, I believe that the time reflected in the Firm’s lodestar calculation and the expenses for which
payment is sought herein are reasonable and were necessary for the effective and efficient prosecution
and resolution of the Litigation. In addition, I believe that these expenses are all of a type that would
normally be charged to a fee-paying client in the private legal marketplace.

4, After the reductions referred to above, the number of hours spent on the Litigation by the
Firm is 2,980.95. A breakdown of the lodestar is provided in the attached Exhibit A. The lodestar
amount for attorney/paraprofessional time based on the Firm’s current rates is $1,537,010.75. The
hourly rates shown in Exhibit A are the usual and customary rates set by the Firm for each individual.

5. Attached as Exhibit B is a task-based summary of the work performed and the lodestar

incurred by each attorney and professional staff member who performed services in this Litigation.

-1-

DECLARATION OF JAMES I. JACONETTE FILED ON BEHALF OF ROBBINS GELLER RUDMAN & DOWD
LLP IN SUPPORT OF APPLICATION FOR AWARD OF ATTORNEYS’ FEES AND EXPENSES
1244391_1ww

6. The Firm seeks an award of $157,968.95 in expenses and charges in connection with the
prosecution of the Litigation. Those expenses and charges are summarized by category in the attached
Exhibit C.

7. The following is additional information regarding certain of these expenses:

(a) Filing, Witness and Other Fees: $11,275.15. These expenses have been paid to

the Court for filing fees and to attorney service firms or individuals who either: (i) served process of the

complaint or subpoenas; or (ii) delivered courtesy copies to the Court for plaintiffs. The vendors who
were paid for these services are set forth in the attached Exhibit D.

(b) Transportation, Hotels & Meals: $12,761.27. In connection with the prosecution
of this case, the Firm has paid for travel expenses, among other things, to attend Court hearings, to meet
with witnesses, mediators and opposing counsel and to take or defend depositions. The date,
destination and purpose of each trip is set forth in the attached Exhibit E.

(c) Court Hearing and Deposition Reporting, and Transcripts: $6,598.70. The
vendors who were paid for hearing and deposition transcripts are listed in the attached Exhibit F.

(d) Experts/Consultants/Investigators: $84,143.85.

(i) Tasta Group dba Caliber Advisors, Inc.: $54,150.00. This firm is
comprised of economists and Certified Financial Advisers and provided expert services related to the
estimation of damages and assessment of materiality in this case. Their work required extensive review
and analysis of King Digital Entertainment plce’s U.S. Securities and Exchange Commission (“SEC”)
filings, analyst reports, and trading data, as well as market and industry data. I personally worked with
representatives of this firm and oversaw their damages analyses and limited event study work. I also
conferred with them in assessing the materiality of statements investigated and alleged as misleading.
In addition, this firm reviewed, evaluated, and commented upon and conferred with me regarding
damages analyses submitted by defendants in connection with the mediation.

(ii) LR. Hodges & Associates, Ltd. (““LRH&A”): $28,948.85. Over a five-
month period (February through June 2015) in which LRH&A provided investigative services to Lead

Counsel, LRH&A expended 138.1 hours for combined fees of $27,242.50, and incurred related

-2-

DECLARATION OF JAMES I. JACONETTE FILED ON BEHALF OF ROBBINS GELLER RUDMAN & DOWD
LLP IN SUPPORT OF APPLICATION FOR AWARD OF ATTORNEYS’ FEES AND EXPENSES
1244391_1ww

expenses of $1,706.35 for a total of $28,948.85. LRH&A’s research staff expended 41.1 hours to
research, identify, and confirm the employment status of prospective witnesses, locating all key targets,
as well as maintaining and updating an evolving witness list to support other LRH&A investigative
members. This also involved research, retrieval and analysis of relevant documents, including SEC
filings, media articles, Court filings, as well as other materials related to the case issues. The case
manager and interviewing investigators expended a combined 97 hours to research, review and analyze
materials in preparation for the investigation; contacting and conducting interviews with targeted third-
party witnesses; and thereafter, to prepare comprehensive interview summaries and other case reports.
In addition, LRH&A was involved in analyzing key case issues, as well as establishing and executing
the joint litigation-investigation plan, and participating in numerous strategy sessions and investigation
briefings with Lead Counsel.

(iii) Seufert Strategy OU (“Seufert Strategy”): $525.00. In connection with
the Firm’s investigation of this case, I retained Seufert Strategy to consult on limited specific aspects of
“freemium” gaming models, and the firm performed such services.

(iv) Lily Haggerty: $350.00. In addition to LRH&A, Robbins Geller also
retained Lily Haggerty to assist in locating potential witnesses.

(v) John L. Gaveollo: $170.00. In addition to LRH&A and Lily Haggerty,
Robbins Geller retained Mr. Gaveollo to assist in locating potential witnesses.

(e) Photocopies: $4,405.70. In connection with this case, the Firm made 19,778
black and white copies. Robbins Geller requests $0.15 per copy for a total of $2,966.70. In addition,
the Firm made 2,878 color copies. Robbins Geller requests $0.50 per copy for a total of $1,439.00.
Each time an in-house copy machine is used, our billing system requires that a case or administrative
billing code be entered and that is how the number of in-house copies were identified as related to the
Litigation.

(f) Online Legal and Financial Research: $7,478.04. These included vendors such as
ALM Media Service, LexisNexis Products, PACER, Thomson Financial and Westlaw. These databases

were used to obtain access to SEC filings, factual databases, legal research and for cite-checking of

-3-

DECLARATION OF JAMES I. JACONETTE FILED ON BEHALF OF ROBBINS GELLER RUDMAN & DOWD
LLP IN SUPPORT OF APPLICATION FOR AWARD OF ATTORNEYS’ FEES AND EXPENSES
1244391_1ww

briefs. This expense represents the expenses incurred by Robbins Geller for use of these services in
connection with this Litigation. The charges for these vendors vary depending upon the type of services
requested. For example, Robbins Geller has flat-rate contracts with some of these providers for use of
their services. When Robbins Geller utilizes online services provided by a vendor with a flat-rate
contract, access to the service is by a billing code entered for the specific case being litigated. At the
end of each billing period in which such service is used, Robbins Geller’s costs for such services are
allocated to specific cases based on the percentage of use in connection with that specific case in the
billing period. As a result of the contracts negotiated by Robbins Geller with certain providers, the
Class enjoys substantial savings in comparison with the “market-rate” for a /a carte use of such services
which some law firms pass on to their clients. For example, the “market rate” charged to others by
LexisNexis for the types of services used by Robbins Geller is more expensive than the rates negotiated
by Robbins Geller.

(g) Database Management and Hosting: $11,720.24. Robbins Geller requests
$11,720.24 for database management and hosting charges related to this Litigation. Because of the
number of components that are part of hosting documents (i.e., hardware, software, license/access fees,
etc.) and the difficulty of allocating a portion of the cost of each component, some of which are multi-
year costs, the amount requested is a discounted market rate estimate of what the hosting services used
in this action would have cost the Class if performed by an outside vendor, an estimate based on a
review by Robbins Geller of what vendors charge for these services. In the last ten years, electronic
discovery has transformed litigation practices and enabled the preservation, collection, production, and
review of vast quantities of documents far more efficiently and cost-effectively than was previously
possible. Historically, Robbins Geller retained the services of third-party providers to assist with the
storage, analysis, printing, and review of electronic discovery. However, in the last several years,
Robbins Geller has undertaken much of this work in-house through the use of the Relativity platform.
Relativity is offered by over 120 vendors and is currently being used by 195 of the AmLaw200 law
firms. Robbins Geller’s Relativity platform consists of over 20 servers and currently consumes more

than 50 terabytes of storage all located in a SSAE 16 Type II data center. Robbins Geller has another

-4-

DECLARATION OF JAMES I. JACONETTE FILED ON BEHALF OF ROBBINS GELLER RUDMAN & DOWD
LLP IN SUPPORT OF APPLICATION FOR AWARD OF ATTORNEYS’ FEES AND EXPENSES
1244391_1om YN DH FF BW NY

YN YBN NY NN KRY De em a
oN A WF BH = FSO we A AH BF BH KF SO

50 terabytes of storage which serves as our backup in a separate location with automatic replication.
Robbins Geller’s Relativity platform allows users to securely login, view, search, download, code and
analyze documents produced in this Litigation. Using an in-house system allows Robbins Geller to
prosecute actions more efficiently and has reduced the time and expense associated with maintaining
and searching electronic discovery databases. The amount requested reflects charges for the
management of the database of over 250,000 pages of documents produced by defendants, plaintiffs and
non-parties in this action. Similar to third-party vendors, Robbins Geller uses a tiered rate system to
calculate hosting charges. Robbins Geller charges $14 per gigabyte per month for less than 500
gigabytes of data for maintaining, hosting and utilizing its Relativity platform. These rates were
developed by Robbins Geller after a review of market rates charged for the same services performed by
third-party vendors. The rates set forth here by Robbins Geller reflect the lowest rate of any
comparable service found by Robbins Geller. Robbins Geller’s in-house database management and
hosting offers additional savings by not charging monthly user fees typically charged by third-party
vendors which can range from $70-$100 per user per month. Database management and hosting
charges are in-house charges, not out-of-pocket expenses paid to outside vendors.

(h) Database Analytics: $213.00, Relativity Analytics is a software package that was
added on to a portion of the documents produced in this matter. Robbins Geller used analytics to
identify and group near-duplicate documents together to speed review and ultimately reduce cost.

@ Mediation Fees: $18,187.50. This amount reflects one-half of the fees charged
by the mediator for mediations services leading to the settlement of this action. The other half was
paid by defendants and/or their insurance carriers. The parties retained as the mediator the Honorable
Layn R. Phillips, a former federal judge with an excellent national reputation and extensive experience
in mediating complex securities actions such as this one. It was clear from the mediation and follow-on

discussions that the mediator and his staff devoted considerable resources to understanding all aspects

| The first invoice for the services of Judge Phillips was $33,000.00. Of that amount, Class Counsel
was responsible for paying half, or $16,500.00. Robbins Geller and Scottt+Scott, Attorneys at Law,
LLP each paid half of the $16,500.00, or $8,250.00. Class Counsel’s share of the additional invoices
submitted by Judge Phillips was $9,937.50, which was paid entirely by Robbins Geller.

-5-
DECLARATION OF JAMES I. JACONETTE FILED ON BEHALF OF ROBBINS GELLER RUDMAN & DOWD
LLP IN SUPPORT OF APPLICATION FOR AWARD OF ATTORNEYS’ FEES AND EXPENSES
1244391_1of the Litigation and the parties’ positions. The parties agreed to a full-day formal mediation at Judge
Phillips’ office on July 1, 2016. At Judge Phillips’ direction, the parties submitted extensive mediation
memoranda and exhibits, and term sheets containing non-economic terms, in advance of the mediation.
Counsel for all parties and defendants’ insurers attended the formal mediation session. During that
session, the parties gave detailed and thoughtful presentations on the perceived strengths and
weaknesses of their respective cases, and Judge Phillips and his assistant worked to challenge the

parties” positions and successfully brought the parties into a settlement range that enabled further

mediation on an informal basis after the full-day formal session. At the same time, Judge Phillips and
his assistant mediated the parties’ efforts to reach agreement on a potential term sheet. The settlement
was reached based on a double-blind proposal made by Judge Phillips, which the parties accepted
within the time period he specified for response,

8. The expenses pertaining to this case are reflected in the books and records of this Firm.
These books and records are prepared from receipts, expense vouchers, check records and other
documents and are an accurate record of the expenses,

9. ‘The identification and background of my Firm and its partners is attached hereto as
Exhibit G,

I declare under penalty of perjury that the foregoing is true and correct, Executed this QT day

of April, 2017, at San Diego, California,

JAMES I. JACONETTE
Y

~6=

DECLARATION OF JAMES L. JACONETTE FILED ON BEHALF OF ROBBINS GELLER RUDMAN & DOWD
LLP IN SUPPORT OF APPLICATION FOR AWARD OF ATTORNEYS’ FI AND EXPENSES
12443911EXHIBIT AEX]

HIBIT A.

Time Report — Inception through March 10, 2017

NAME HOURS | RATE LODESTAR
Boardman, Erin (P) 60.05 665 39,933.25
Daley, Joseph (@) 2.75 780 2,145.00
Hubachek, Steven (P) 3.00 890 2,670.00
Jaconette, James (P) 823.60 800 658,880.00
Light, Jeffrey (P)| 217.75 855 186,176.25
Pintar, Theodore (P) 25.30 890 22,517.00
Robbins, Darren (P) 0.50 955 477.50
Rudman, Samuel (P) 20.50 | 980 20,090.00
Walton, David (P) 4.40 | 930 4,092.00
Lacomb, Timothy (A) 39.40 460 18,124.00.
Blasy, Mary K. (OC) 48.25 720 34,740.00
Araya-Schraner, Natasha | (SA) 42.90 360 15,444.00
Black, Kelli (SA) 11.50 | 360 4,140.00
Mehta, Dharmi (SA) 3.00 | 360 1,080.00
Neiman, Shelley (SA) | 285.15 | 360 102,654.00
O'Donoghue, Nicola (SA) | 121.40 350 42,490.00
Tanner, Charles (SA) | 439.20 360 158,112.00
Barhoum, Anthony (EA) 23.00 | 430 9,890.00
Cabusao, Reggie (EA) 12.75 | 335 4,271.25
Uralets, Boris (EA) 4.00 415 1,660.00
Villalovas, Frank (EA) 1.50 420 630.00
Roelen, Scott (RA) 7.00 |__295 2,065.00
Brandon, Kelley @ 9.00 | 250 2,250.00
Browning, Aaron (LS) 2.75 290 797.50
Keita, C. Oumar (LS) 53.70 290 15,573.00
Paralegals 542.20 | 265-295 159,859.00
Document Clerks 172.40 150 25,860.00
Shareholder Relations 4.00 |_ 95-100 390.00

TOTAL 2,980.95 $_1,537,010.75
(P) Partner
(A) Associate
(OC) Of Counsel

(SA) Staff Attorney
(EA) Economic Analyst
(RA) Research Analyst
(I) Investigator

(LS) Litigation SupportEXHIBIT BEXHIBIT B
In re King Digital Entertainment ple Shareholder Litigation
Case No. CGC-15-544770

Firm Name: Robbins Geller Rudman & Dowd LLP
Reporting Period: Inception through March 10, 2017

Categories:

(1) Factual Investigation (6) Document Review

(2) Discovery (7) Legal Research

(3) Pleadings, Briefs & Pretrial Motions (8) Client / Sharcholder Communications
(4) Court Appearances (9) Litigation Strategy & Analysis

(5) Draft Initial or Amended Complaint (10) Settlement Negotiations, Stipulation, Plan of Allocation

Name 1 2 3 4 5 6 7 8
Boardman, Erin (P) : 59.80 7 7 7 7 7 7
Daley, Joseph (P) - 7 7 7 7 7 7 7
Hubachek, Steven (@) - - - - 7 - 7 7
Jaconette, James (P) 86.00 181.05 206.10 38.95 87.40 - : 28.95
Light, Jeffrey (P) - - - - a - 7
|Pintar, Theodore (P) - - - - 7 - - 7
Robbins, Darren (P) 0.50 7 - 7 7 7 7 7
Rudman, Samuel (P) 7.00 - - - 13.50 - - -
Walton, David (P) - - 1.50 - I - - 2.20
Lacomb, Timothy (A) 39.40 - - - - - - 7
Blasy, Mary K. (OC) 5.75 - - - 41.75 - - -
|Araya-Schraner, Natasha (SA) - - - - - - 37.20 -
Black, Kelli (SA) - 3.90 0.20 7.10 - - - -
Mehta, Dharmi (SA) - - - - 7 - 3.00 7
Neiman, Shelley (SA) : 43.35 66.75 - - 175.05 - -
O'Donoghue, Nicola (SA) - 121.40 - - - - - 7
Tanner, Charles (SA) - 181.75 18.75 - - 92.25 - -
Barhoum, Anthony (EA) 2.75 : - : 7 7 7 7
Cabusao, Reggie (EA) 12.75 - - - - - 7 7
Uralets, Boris (EA) 4.00. 7 - - - - - -
Villalovas, Frank (EA) : 7 7 7 7 7 7 7

Page 1 of 3

9

0.25
2.75
3.00
155.30

Current
Hours

60.05
2.75
3.00
823.60
217.75
25.30
0.50
20.50
4.40
39.40
48.25
42.90
11.50
3.00
285.15
121.40
439.20
23.00
12.75
4.00
1.50

$

Current

Lodestar
39,933.25
2,145.00
2,670.00
658,880.00
186,176.25
22,517.00
477.50
20,090.00
4,092.00
18,124.00
34,740.00
15,444.00
4,140.00
1,080.00
102,654.00
42,490.00
158,112.00
9,890.00
4,271.25
1,660.00
630.00Firm Name: Robbins Geller Rudman & Dowd LLP
Reporting Period: Inception through March 10, 2017

Categories:

(1) Factual Investigation

(2) Discovery

(3) Pleadings, Briefs & Pretrial Motions
(4) Court Appearances
(5) Draft Initial or Amended Complaint

In re King Digital Entertainment ple Shareholder Litigation
Case No. CGC-15-544770

(6) Document Review
(7) Legal Research
(8) Client / Sharcholder Communications

EXHIBIT B

(9) Litigation Strategy & Analysis

(10) Settlement Negotiations, Stipulation, Plan of Allocation

Name

Roelen, Scott
Brandon, Kelley
Browning, Aaron
Keita, C. Oumar
[Bacci, Melissa
Cook, Karen E.
Deem, Lavar
Horstman, Natalee J.
Kleinman, Jill
Kopko, Christina
Millan, Hector
Morris, Sarah
Patel, Sonal
Stark, Jaclyn
Stella, Christine
Tiffith, Pierre R.

Wallbrett, Michele M.

Williams, Susan
Brockwell, Daniel
Clark, Joseph
Hawkins, Riley

(RA)
(1)

(LS)
(LS)
(PL)
(PL)
(PL)
(PL)
(PL)
(PL)
(PL)
(PL)
(PL)
(PL)
(PL)
(PL)
(PL)
(PL)
(DC)
(DC)
(DC)

5 6
2.00 -
7.50 :

- 26.00

Page 2 of 3

10

0.50
153.00

Current
Hours

7.00
9.00
2.75
53.70
6.00
6.00
9.50
3.00
1.00
4.00
2.50
5.00
0.50
153.00
0.25
1.00
323.95
26.50
2.00
103.60
16.00

Rate

295
250
290
290
295
295
295
295
295
295
295
280
265
295
295
295
295
295
150
150
150

Current

Lodestar
2,065.00
2,250.00
797.50
15,573.00
1,770.00
1,770.00
2,802.50
885.00
295.00
1,180.00
737.50
1,400.00
132.50
45,135.00
73.75
295.00
95,565.25
7,817.50
300.00
15,540.00
2,400.00EXHIBIT B

In re King Digital Entertainment ple Shareholder Litigation
Case No. CGC-15-544770

Firm Name: Robbins Geller Rudman & Dowd LLP
Reporting Period: Inception through March 10, 2017

Categories:

(1) Factual Investigation (6) Document Review

(2) Discovery (7) Legal Research

(3) Pleadings, Briefs & Pretrial Motions (8) Client / Sharcholder Communications
(4) Court Appearances (9) Litigation Strategy & Analysis

(5) Draft Initial or Amended Complaint

(10) Settlement Negotiations, Stipulation, Plan of Allocation

Current Current
Name 1 2 3 4 5 6 7 8 Hours Rate Lodestar
Salumaa, Sven (DC) : 12.50 : - - - : : 12.50 150 1,875.00
Santana, Andres (DC) : 0.25 - - - - - - 0.25 150 37.50
Vega, Andrew (DC) : 23.30 : 14.75 - - : : 38.05 150 5,707.50
Gosling, T. Ron (SR) : : : - - - : 2.00 2.00 95 190.00
Weas, Amylu (SR) - ; - - 7 - - 1.00 1.00 100 100.00
Wood, Greg (SR) : : : - - - : 1.00 1.00 100 100.00
TOTAL: 197.65 883.55 479.55 62.30 152.15 293.30 40.20 36.15 2,980.95 $8 1,537,010.75
(P) Partner

(A) Associate

(OC) Of Counsel

(SA) Staff Attorney

(EA) Economic Analyst
(RA) Research Analyst

(I) Investigator

(LS) Litigation Support
(PL) Paralegal

(DC) Document Clerk
(SR) Shareholder Relations

Page 3 of 3EXHIBIT CEXHIBIT C

Expenses/Charges — Inception through February 28, 2017

CATEGORY TOTAL
Filing, Witness and Other Fees $11,275.15
Transportation, Hotels & Meals 12,761.27
Telephone, Facsimile 63.61
Postage 609.75
Messenger, Overnight Delivery $12.14
Court Hearing and Deposition Reporting, and Transcripts 6,598.70
Experts/Consultants/Investigators 84,143.85
Tasta Group dba Caliber Advisors, Inc. $ 54,150.00
L.R. Hodges & Associates, Ltd. 28,948.85
Seufert Strategy OU 525.00
Lily Haggerty 350.00
John L. Gaveollo 170.00
Photocopies 4,405.70
In-House B&W (19,778 copies at $0.15 per page) | $2,966.70
In-House Color (2,878 copies at $0.50 per page) 1,439.00
Online Legal and Financial Research 7,478.04
Database Management and Hosting 11,720.24
Database Analytics 213.00
Mediation Fees (Phillips ADR Enterprises, P.C.) 18,187.50
TOTAL $_157,968.95EXHIBIT DEXHIBIT D

Filing, Witness and Other Fees: $11,275.15

DATE

VENDOR

PURPOSE

03/20/15

Class Action Research & Litigation
Support Services, Inc.

Court Filing — File summons and complaint

03/24/15

Class Action Research & Litigation
Support Services, Inc.

Personal Service — Pacific Crest Securities
LLC; summons and complaint

Personal Service — Credit Suisse Securities;
summons and complaint

Personal Service — Raine Securities LLC;
summons and complaint

Personal Service — Wedbush Securities
Inc.; summons and complaint

Personal Service — Stifel, Nicolaus & Co.
Inc.; summons and complaint

Personal Service — Piper Jaffray & Co.;
summons and complaint

Personal Service — BMO Capital Markets
Corp.; summons and complaint

Personal Service — Deutsche Bank
Securities Inc.; summons and complaint

Personal Service — Barclays Capital Inc.;
summons and complaint

Personal Service — Merrill Lynch, Pierce,
Fenner & Smith Inc.; summons and
complaint

Personal Service — J.P. Morgan Securities
LLC; summons and complaint

03/31/15

Class Action Research & Litigation
Support Services, Inc.

03/24/15 Personal Service — RBC Capital
Markets LLC; summons and complaint

04/01/15

Class Action Research & Litigation
Support Services, Inc.

Personal Service ~ Cowen and Company
LLC; summons and complaint

04/03/15

File & ServeXpress LLC

Court Filing — Joint application for
approval of complex case designation

04/14/15

Class Action Research & Litigation
Support Services, Inc.

Personal Service — Credit Suisse Securities;
plaintiffs’ second set of requests for
production of documents to all defendants;DATE

VENDOR

PURPOSE

plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

Personal Service — RBC Capital Markets;
plaintiffs’ second set of requests for
production of documents to all defendants;
plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

Personal Service — Pacific Crest Securities;
plaintiffs’ second set of requests for
production of documents to all defendants;
plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

Personal Service — Raine Securities LLC;
plaintiffs’ second set of requests for
production of documents to all defendants;
plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

Personal Service — Wedbush Securities
Inc.; plaintiffs’ second set of requests for
production of documents to all defendants;
plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

Personal Service — JP Morgan Securities;
plaintiffs’ second set of requests for
production of documents to all defendants;
plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

Personal Service — Merrill Lynch, Pierce,
Fenner & Smith Inc.; plaintiffs’ second set
of requests for production of documents toDATE

VENDOR

PURPOSE

all defendants; plaintiffs’ first set of special
interrogatories to all defendants; plaintiffs’
first set of requests for production of
documents to all defendants

Personal Service — Barclays Capital Inc.;
plaintiffs’ second set of requests for
production of documents to all defendants;
plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

Personal Service — Deutsche Bank
Securities Inc.; plaintiffs’ second set of
requests for production of documents to all
defendants; plaintiffs’ first set of special
interrogatories to all defendants; plaintiffs’
first set of requests for production of
documents to all defendants

Personal Service - BMO Capital Markets
Corp.; plaintiffs’ second set of requests for
production of documents to all defendants;
plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

Personal Service — Piper Jaffray & Co.;
plaintiffs’ second set of requests for
production of documents to all defendants;
plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

Personal Service — Stifel Nicolaus & Co.
Inc.; plaintiffs’ second set of requests for
production of documents to all defendants;
plaintiffs’ first set of special interrogatories
to all defendants; plaintiffs’ first set of
requests for production of documents to all
defendants

04/21/15

File & ServeXpress LLC

04/16-21/15 Court Filing — Proof of service
of summons and complaint; joint
stipulation and proposed order relating and
consolidating cases and appointing leadDATE VENDOR PURPOSE
counsel; ex parte application to enter
stipulation regarding consolidation and
counsel coordination
04/29/15 File & ServeXpress LLC 04/23-29/15 Court Filing — Joint
application for approval of complex case
designation
04/29/15 Class Action Research & Litigation | Courtesy copy for chambers: joint
Support Services, Inc. application for approval of complex case
designation
04/30/15 Class Action Research & Litigation | Personal Service — Evaluate particular
Support Services, Inc. location for possible service of defendants
05/14/15 Class Action Research & Litigation | Personal Service — Returned not served: R.
Support Services, Inc. Zacconi; summons and complaint
05/18/15 Class Action Research & Litigation | 5/14/15 Personal Service — Returned not
Support Services, Inc. served: H. Cochran; summons and
complaint
05/19/15 Class Action Research & Litigation | Personal Service — H. Cochran; summons
Support Services, Inc. and complaint
06/05/15 Class Action Research & Litigation | Personal Service — Surveillance/
Support Services, Inc. investigative request on H. Cochran
06/16/15 File & ServeXpress LLC Court Filing — Filing of stipulation
06/18/15 File & ServeXpress LLC Court Filing — Filing of stipulation
06/25/15 File & ServeXpress LLC Court Filing — Filing of complaint
06/26/15 Class Action Research & Litigation | Courtesy copy for chambers: consolidation
Support Services, Inc. class action complaint
08/14/15 File & ServeXpress LLC Court Filing — First amended consolidated
class action complaint for violations of the
Securities Act of 1933
08/20/15 File & ServeXpress LLC 08/14-20/15 Court Filing — Affidavit of
service
10/07/15 File & ServeXpress LLC 10/07/15 & 10/23/15 Court Filing — Second
amended consolidated class action
complaint for violations of the Securities
Act of 1933
10/23/15 Class Action Research & Litigation | Courtesy copy for chambers: second
Support Services, Inc. amended consolidated complaint and notice
of lodgment of exhibits cited in plaintiffs’
second amended consolidated complaint
12/07/15 Class Action Research & Litigation | Courtesy copy for chambers: plaintiffs’

Support Services, Inc.

memorandum of points and authorities in
opposition to demurrer of King Digital
defendants to second amended complaint;
plaintiffs’ memorandum of points and
authorities in opposition to demurrer of
underwriter defendants to second amended
complaintDATE

VENDOR

PURPOSE

12/16/15

Class Action Research & Litigation
Support Services, Inc.

Courtesy copy for chambers: appendix of
non-California authorities and secondary
authorities

12/17/15

File & ServeXpress LLC

12/04-17/15 Court Filing — Plaintiffs’
memorandum of points and authorities in
opposition to demurrer of King Digital
defendants to second amended complaint;
plaintiffs’ memorandum of points and
authorities in opposition to demurrer of
underwriter defendants to second amended
complaint

02/27/16

CourtCall

02/26/16 Court Fee — Fee for telephonic
appearance for case management
conference #3

03/11/16

Class Action Research & Litigation
Support Services, Inc.

Court Filing — File and issue deposition
subpoena for production of business
records; New York subpoena

03/14/16

Class Action Research & Litigation
Support Services, Inc.

Personal Service — NetRoadshow Inc., New
York subpoena for production of business
records; schedule A

05/16/16

File & ServeXpress LLC

Court Filing — Declaration in support of
stipulation to dismiss the second cause of
action in the second amended consolidated
class action complaint with prejudice

05/19/16

CourtCall

05/18/16 Court Fee — Fee for telephonic
appearance for case management
conference hearing

05/25/16

Class Action Research & Litigation
Support Services, Inc.

12/30/15 Personal Service - Document
preparation — Fenwick & West LLP:
plaintiff's special interrogatories; requests
for admission; requests for production

12/30/15 Personal Service - Document
preparation — Sullivan & Cromwell, LLP:
plaintiff's special interrogatories; requests
for admission; requests for production

07/16/16

CourtCall

07/15/16 — Court Fee — Fee for telephonic
conference for hearing

07/31/16

Class Action Research & Litigation
Support Services, Inc.

03/25/16 Courtesy copy for chambers

03/15/16 Court Filing — File and issue
deposition subpoena for personal
appearance

03/16/16 Personal Service — Fred Alger
Management, Inc.: New York subpoena for
personal appearanceDATE

VENDOR

PURPOSE

08/26/16

CourtCall

08/25/16 — Court Fee — Fee for telephonic
case management conference hearing with
Judge Karnow

10/04/16

CourtCall

10/03/16 — Court Fee — Fee for telephonic
appearance for J. Jaconette

10/06/16

CourtCall

10/05/16 — Court Fee — Fee for telephonic
appearance for J. Light and case
management conference hearing
appearance

11/08/16

Class Action Research & Litigation
Support Services, Inc.

Courtesy copy for chambers: class
representatives notice of motion and
motion for preliminary approval of class
action settlement; memorandum of points
and authorities; joint declaration of J.
Jaconette and G. Johnson; declaration of
M. Joaquin regarding notice and
administration; stipulation of settlement;
proposed order

11/08/16

File & ServeXpress LLC

Court Filing — Class representatives’ notice
of motion and motion of preliminary
approval of class action settlement and
statutory filing fee

11/09/16

File & ServeXpress LLC

Court Filing — Declaration of J. Jaconette
regarding submission of class
representative City of Taylor

11/11/16

One Legal LLC

Court Filing — Notice of motion and motion
for preliminary approval of class action
settlement; joint declaration of J. Jaconette
and G.M. Johnson in support of motion for
preliminary approval of class action
settlement

12/28/16

File & ServeXpress LLC

12/28-12/30/16 Court Filing and statutory
filing fee — Joint notice of motion and
motion to file supplemental agreement
under seal

12/28/16

File & ServeXpress LLC

Court Filing — Notice of lodging
documents under seal; class
representatives’ response to the court’s
November 17, 2016 tentative ruling on
motion for preliminary of class action
settlement

12/29/16

File & ServeXpress LLC

Court Filing — Class representatives’
supplemental submission regarding class
representatives’ motion for preliminary
approval of class action settlement

12/31/16

Class Action Research & Litigation
Support Services, Inc.

12/28/16 Court Filing — Lodge under seal
filing; supplemental agreement (filed under
seal); class representatives’ supplementalDATE

VENDOR

PURPOSE

submission re preliminary approval (filed
under seal)

12/29/16 Court Filing — File under seal and
deliver courtesy copy to chambers: class
representatives’ supplemental submission
regarding preliminary approval (filed under
seal)

01/07/17

CourtCall

01/06/17 — Court Fee: Fee for telephonic
appearance for J. Jaconette

01/26/17

File & ServeXpress LLC

Court Filing — Proposed order preliminarily
approving settlement and providing of
notice authorized by J. Jaconette

01/31/17

File & ServeXpress LLC

Court Filing — Proposed order preliminarily
approving settlement and providing for
notice

02/10/17

Class Action Research & Litigation
Support Services, Inc.

01/31/17 Courtesy copy for chambers:
proposed order preliminarily approving
settlement and providing for noticeEXHIBIT EEXHIBIT E

Transportation, Hotels and Meals: $12,761.27

(Included in this total is $119.93 in local meal charges for lunch for all persons attending the
deposition of Gerard Taylor taken on February 26, 2016.)

NAME DATE CITY PURPOSE
Jaconette, James 07/26/15- | San Francisco, CA | Prepare for, appear and argue at
07/27/15 Case Management Conference
Jaconette, James 10/04/15- | San Francisco, CA | Prepare for and argue at hearing on
10/05/15 demurrer
Jaconette, James 12/17/15 | San Francisco, CA | Prepare for and argue at hearing on
demurrers
Jaconette, James 02/24/16- | San Francisco, CA | Prepare for and defend client
02/26/16 deposition
Taylor, Gerard 02/24/16- | San Francisco, CA | Attend deposition
02/28/16
Boardman, Erin 03/17/16 | New York, NY Prepare for and defend deposition
of Investment Manager Fred Alger
Management, Inc.
Jaconette, James 06/30/16- | Newport Beach, Prepare for and argue at mediation
07/02/16 | CA
Tanner, Charles 07/01/16 | Newport Beach, Prepare for and attend mediation
CA
Light, Jeffrey 11/16/16- | San Francisco, CA | Prepare for and attend preliminary
LI/17/16 approval hearing
Light, Jeffrey 01/12/17 | San Francisco, CA __| Prepare for and attend preliminary

approval hearingEXHIBIT FEXHIBIT F

Court Hearing and Deposition Reporting, and Transcripts: $6,598.70

DATE VENDOR PURPOSE

03/04/16 TSG Reporting, Inc. 02/26/16 City of Taylor deposition

03/08/16 Aptus Court Reporting, LLC 2014 Video recording of R. Zacconi, CEO
and co-founder of King Digital’s
presentation

03/17/16 TSG Reporting, Inc. B. Reynolds deposition

11/17/16 Aptus Court Reporting, LLC Hearing transcript re: plaintiffs’ motion for
preliminary approval of class action
settlement

O1/13/17 Scanlan Stone, Inc. 01/12/17 Hearing transcript re: plaintiffs’

motion for preliminary approval of class
action settlementEXHIBIT GRobbins Geller
Rudman s Dowd Lp
THE RIGHT CHOIGE

Firm ResumeTABLE OF CONTENTS

INTRODUCTION
PRACTICE AREAS AND SERVICES

Securities Fraud
Shareholder Derivative and Corporate Governance Litigation.
Options Backdating Litigation:
Corporate Takeover Litigation.
Insurance..
Antitrust...
Consumer Fraud
Intellectual Property.
Human Rights, Labor Practices and Public Polic
Environment and Public Health
Pro Bono.
E-Discovery...

INSTITUTIONAL CLIENTS

Public Fund Clients.
Multi-Employer Clients.
International Investors..
Additional Institutional Investors.

PROMINENT CASES, PRECEDENT-SETTING DECISIONS AND JUDICIAL COMMENDATIONS

PRECEDENT-SETTING DECISIONS

Investor and Shareholder Rights.
INSULANCE.. sete
Consumer Protection.
Additional Judicial Commendation:

ATTORNEY BIOGRAPHIES

Special Counsel.
Forensic Accountants.

25

34
38
38
39

44

95
110
111Introduction

Robbins Geller Rudman & Dowd LLP (“Robbins Geller” or the “Firm”) is a 200-lawyer firm with offices in Atlanta,
Boca Raton, Chicago, Manhattan, Melville, Nashville, San Diego, San Francisco, Philadelphia and Washington,
D.C. (www.rgrdlaw.com). The Firm is actively engaged in complex litigation, emphasizing securities, consumer,
antitrust, insurance, healthcare, human rights and employment discrimination class actions, as well as
intellectual property disputes. The Firm’s unparalleled experience and capabilities in these fields are based
upon the talents of its attorneys, who have successfully prosecuted thousands of class action lawsuits and
numerous individual cases, recovering billions of dollars.

This successful track record stems from our experienced attorneys, including many who came to the Firm from
federal or state law enforcement agencies. The Firm also includes several dozen former federal and state
judicial clerks.

The Firm currently represents more institutional investors, including public and multi-employer pension funds
and domestic and international financial institutions, in securities and corporate litigation than any other
plaintiffs’ securities law firm in the United States.

The Firm is committed to practicing law with the highest level of integrity in an ethical and professional manner.
We are a diverse firm with lawyers and staff from all walks of life. Our lawyers and other employees are hired
and promoted based on the quality of their work and their ability to treat others with respect and dignity.

We strive to be good corporate citizens and work with a sense of global responsibility. Contributing to our
communities and environment is important to us. We often take cases on a pro bono basis and are committed
to the rights of workers, and to the extent possible, we contract with union vendors. We care about civil rights,
workers’ rights and treatment, workplace safety and environmental protection. Indeed, while we have built a
reputation as the finest securities and consumer class action law firm in the nation, our lawyers have also
worked tirelessly in less high-profile, but no less important, cases involving human rights and other social issues.

Robbins Geller Rudman & Dowd LLP

1Practice Areas and Services

Securities Fraud

As recent corporate scandals demonstrate clearly, it has become all too common for companies and their
executives — often with the help of their advisors, such as bankers, lawyers and accountants — to manipulate the
market price of their securities by misleading the public about the company's financial condition or prospects
for the future. This misleading information has the effect of artificially inflating the price of the company's
securities above their true value. When the underlying truth is eventually revealed, the prices of these securities
plummet, harming those innocent investors who relied upon the company’s misrepresentations.

Robbins Geller is the leader in the fight to protect investors from corporate securities fraud. We utilize a wide
range of federal and state laws to provide investors with remedies, either by bringing a class action on behalf of
all affected investors or, where appropriate, by bringing individual cases.

The Firm's reputation for excellence has been repeatedly noted by courts and has resulted in the appointment
of Firm attorneys to lead roles in hundreds of complex class-action securities and other cases. In the securities
area alone, the Firm's attorneys have been responsible for a number of outstanding recoveries on behalf of
investors. Currently, Robbins Geller attorneys are lead or named counsel in hundreds of securities class action
or large institutional-investor cases. Some notable current and past cases include:

* Inre Enron Corp. Sec. Litig., No. H-01-3624 (S.D. Tex.). Robbins Geller attorneys and lead plaintiff
The Regents of the University of California aggressively pursued numerous defendants, including many
of Wall Street's biggest banks, and successfully obtained settlements in excess of $7.2 billion for the
benefit of investors. This is the largest aggregate class action settlement not only in a
securities class action, but in class action history.

« Jaffe v. Household Int’l, Inc., No. 02-C-05893 (N.D. Ill). As sole lead counsel, Robbins Geller
obtained a record-breaking settlement of $1.575 billion after 14 years of litigation, including a six-
week jury trial in 2009 that resulted in a securities fraud verdict in favor of the class. In 2015, the
Seventh Circuit Court of Appeals upheld the jury's verdict that defendants made false or misleading
statements of material fact about the company's business practices and financial results, but remanded
the case for a new trial on the issue of whether the individual defendants “made” certain false
statements, whether those false statements caused plaintiffs’ losses, and the amount of damages. The
parties reached an agreement to settle the case just hours before the retrial was scheduled to begin on
June 6, 2016. The $1.575 billion settlement, approved in October 2016, is the largest ever
following a securities fraud class action trial, the largest securities fraud settlement in
the Seventh Circuit and the seventh-largest settlement ever in a post-PSLRA securities
fraud case. According to published reports, the case was just the seventh securities fraud case tried
to a verdict since the passage of the PSLRA.

In re UnitedHealth Grp. Inc. PSLRA Litig., No. 06-CV-1691 (D. Minn.). Robbins Geller
represented the California Public Employees’ Retirement System (“CalPERS”) and demonstrated its
willingness to vigorously advocate for its institutional clients, even under the most difficult
circumstances. The Firm obtained an $895 million recovery on behalf of the UnitedHealth
shareholders, and former CEO William A. McGuire paid $30 million and returned stock options
representing more than three million shares to the shareholders, bringing the total recovery for the class
to over $925 million, the largest stock option backdating recovery ever, and a recovery that is more
than four times larger than the next largest options backdating recovery. Moreover,
Robbins Geller obtained unprecedented corporate governance reforms, including election of a

Robbins Geller Rudman & Dowd LLP

2Practice Areas and Services

shareholder-nominated member to the company's board of directors, a mandatory holding period for
shares acquired by executives via option exercise, and executive compensation reforms that tie pay to
performance.

« Alaska Elec. Pension Fund v. CitiGroup, Inc. (In re WorldCom Sec. Litig.), No. 03 Civ. 8269
(S.D.N.Y.). Robbins Geller attorneys represented more than 50 private and public institutions that
opted out of the class action case and sued WorldCom's bankers, officers and directors, and auditors
in courts around the country for losses related to WorldCom bond offerings from 1998 to 2001. The
Firm's attorneys recovered more than $650 million for their clients, substantially more than they would
have recovered as part of the class.

* Luther v. Countrywide Fin. Corp., No. 12-cv-05125 (C.D. Cal.). Robbins Geller attorneys secured
a $500 million settlement for institutional and individual investors in what is the largest RMBS
purchaser class action settlement in history, and one of the largest class action securities settlements
of all time. The unprecedented settlement resolves claims against Countrywide and Wall Street banks
that issued the securities. The action was the first securities class action case filed against originators
and Wall Street banks as a result of the credit crisis. As co-lead counsel Robbins Geller forged
through six years of hard-fought litigation, oftentimes litigating issues of first impression, in order to
secure the landmark settlement for its clients and the class.

* In re Wachovia Preferred Sec. & Bond/Notes Litig., No. 09-cv-06351 (S.D.N.Y.). On behalf of
investors in bonds and preferred securities issued between 2006 and 2008, Robbins Geller and co-
counsel obtained a significant settlement with Wachovia successor Wells Fargo & Company and
Wachovia auditor KPMG LLP. The total settlement — $627 million — is one of the largest credit-
crisis settlements involving Securities Act claims and one of the 20 largest securities
class action recoveries in history. The settlement is also one of the biggest securities class action
recoveries arising from the credit crisis. The lawsuit focused on Wachovia's exposure to “pick-a-pay”
loans, which the bank's offering materials said were of “pristine credit quality,” but which were actually
allegedly made to subprime borrowers, and which ultimately massively impaired the bank's mortgage
portfolio. Robbins Geller served as co-lead counsel representing the City of Livonia Employees’
Retirement System, Hawaii Sheet Metal Workers Pension Fund, and the investor class.

* In re Cardinal Health, Inc. Sec. Litig., No. C2-04-575 (S.D. Ohio). As sole lead counsel
representing Cardinal Health shareholders, Robbins Geller obtained a recovery of $600 million for
investors on behalf of the lead plaintiffs, Amalgamated Bank, the New Mexico State Investment Council,
and the California Ironworkers Field Trust Fund. At the time, the $600 million settlement was the tenth-
largest settlement in the history of securities fraud litigation and is the largest-ever recovery in a
securities fraud action in the Sixth Circuit.

* AOL Time Warner Cases | & II, JCCP Nos. 4322 & 4325 (Cal. Super. Ct., Los Angeles Cty.).
Robbins Geller represented The Regents of the University of California, six Ohio state pension funds,
Rabo Bank (NL), the Scottish Widows Investment Partnership, several Australian public and private
funds, insurance companies, and numerous additional institutional investors, both domestic and
international, in state and federal court opt-out litigation stemming from Time Warner's disastrous 2001
merger with Internet high flier America Online. After almost four years of litigation involving extensive
discovery, the Firm secured combined settlements for its opt-out clients totaling over $629 million just
weeks before The Regents’ case pending in California state court was scheduled to go to trial. The
Regents’ gross recovery of $246 million is the largest individual opt-out securities recovery in history.

* In re HealthSouth Corp. Sec. Litig., No. CV-03-BE-1500-S (N.D. Ala.). As court-appointed co-

lead counsel, Robbins Geller attorneys obtained a combined recovery of $671 million from
HealthSouth, its auditor Ernst & Young, and its investment banker, UBS, for the benefit of stockholder

Robbins Geller Rudman & Dowd LLP | 3.

Practice Are

plaintiffs. The settlement against HealthSouth represents one of the larger settlements in securities
class action history and is considered among the top 15 settlements achieved after passage of the
PSLRA. Likewise, the settlement against Ernst & Young is one of the largest securities class action
settlements entered into by an accounting firm since the passage of the PSLRA.

Jones v. Pfizer Inc., No. 1:10-cv-03864 (S.D.N.Y.). Lead plaintiff Stichting Philips Pensioenfonds
obtained a $400 million settlement on behalf of class members who purchased Pfizer Inc. common
stock during the January 19, 2006 to January 23, 2009 class period. The settlement against Pfizer
resolves accusations that it misled investors about an alleged off-label drug marketing scheme. As sole
lead counsel, Robbins Geller attorneys helped achieve this exceptional result after five years of hard-
fought litigation against the toughest and the brightest members of the securities defense bar by
litigating this case all th