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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 
						
                                
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SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
JOHN T. JASNOCH
707 Broadway, Suite 1000

San Diego, CA 92101 ELECTRONICALLY
Telephone: 619/233-4565 FILED
619/233-0508 (FAX) Superior Court of California,
jjasnoch@scott-scott.com County of San Francisco
05/05/2016
-and- Clerk of the Court
BY-MAURA RAMIREZ
Deputy Clerk

GEOFFREY M. JOHNSON (pro hac vice)
SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
12434 Cedar Road, Suite 12

Cleveland Heights, OH 44106

Telephone: 216/229-6088
gjohnson@scott-scott.com

Attorneys for Plaintiffs
[Additional Counsel in Signature Blocks]

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

IN RE KING DIGITAL ENTERTAINMENT Lead Case No.: CGC-15-544770
ple SHAREHOLDER LITIGATION
CLASS ACTION

PLAINTIFFS’ UNOPPOSED
SUPPLEMENTAL FILING IN SUPPORT

OF REVISED STIPULATION AND

This Document Relates To: [PROPOSED] ORDER CERTIFYING
ALL ACTIONS. SECTION 11 CLASS AND DISMISSING
SECTION 12 CLAIM

EXHIBIT B

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

PLAINTIFFS’ UNOPPOSED SUPPLEMENTAL LEAD CASE NO.: CGC-15-544770

FILING IN SUPPORT OF REVISED STIP. AND
[PROPOSED] ORDERw

wn

EXHIBIT B

PLAINTIFFS’ UNOPPOSED SUPPLEMENTAL 1
FILING IN SUPPORT OF REVISED STIP. AND
[PROPOSED] ORDER

CASE NO.: CGC-15-544770Firm Resume

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.

Practice Areas and Services

Robbins Geller
Rudman & Dowd up

TABLE OF CONTENTS

PRACTICE AREAS AND SERVICES 1.

Securities Fraud .. A

Shareholder Derivative and
Corporate Governance Litigation .5

Options Backdating Litigatior

Corporate Takeover Litigation .
Insurance...
Antitrust .....
Consumer Frau

Intellectual Property...

Human Rights, Labor Practices
and Public Policy

Environment and Public Health
Community...

E-Discovery.
INSTITUTIONAL CUBNTS aan

Public Fund Clients

Multi-Employer Clients...

International Investors..... a
Additional Institutional Investors.

PROMINENT CASES, PRECEDENT-

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.

SETTING DECISIONS AND JUDICIAL
COMMENDATIONS

Prominent Cases.

PRECEDENT-SETTING DECISIONS 27
Investor and Shareholder Rights 27

Insurance... . 30

Consumer Protection...

Additional Judicial
Commendations...

ATTORNEY BIOGRAPHIES

Partners
Of Counsel...
Special Counsel

Forensic Accountants.....

Robbins Geller Rudman & Dow! LLP Firm Resume | 1Robbins 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:

In re 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). Sole lead counsel Robbins Geller
obtained a jury verdict on May 7, 2009, following a six-week trial in the Northern District of Illinois, on
behalf of a class of investors led by plaintiffs PACE Industry Union-Management Pension Fund, the
International Union of Operating Engineers, Local No. 132 Pension Plan, and Glickenhaus &
Company. On October 17, 2013, U.S. District Judge Ronald A. Guzman entered a judgment of
$2.46 billion — the largest judgment following a securities fraud class action trial in history —
against Household International (now HSBC Finance Corporation) and three of its former top
executives, William Aldinger, David Schoenholz and Gary Gilmer. The judgment has been remanded
on appeal to retry certain aspects of the verdict. Since the enactment of the PSLRA in 1995, trials in
securities fraud cases have been rare. Only a handful of such cases have gone to 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 which
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
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 which 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.

Robbins Geller Rudman & Bawd LLP Firm Resume | 2In 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 the largest recovery
under the Securities Act of 1933 and one of the 15 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, JOCP 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
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 the way to trial.

In re Dynegy Inc. Sec. Litig., No. H-02-1571 (S.D. Tex.). As sole lead counsel representing The
Regents of the University of California and the class of Dynegy investors, Robbins Geller attorneys
obtained a combined settlement of $474 million from Dynegy, Citigroup, Inc. and Arthur Andersen
LLP for their involvement in a clandestine financing scheme known as Project Alpha. Most notably,
the settlement agreement provides that Dynegy will appoint two board members to be nominated by
The Regents, which Robbins Geller and The Regents believe will benefit all of Dynegy's stockholders.

In re Qwest Comme’ns Int'l, Inc. Sec. Litig., No. 01-cv-1451 (D. Colo.). In July 2001, the Firm
filed the initial complaint in this action on behalf of its clients, long before any investigation into
Qwest's financial statements was initiated by the SEC or Department of Justice. After five years of
litigation, lead plaintiffs entered into a settlement with Qwest and certain individual defendants that

Robbins Geller Rudman & Bawd LLP Firm Resume | 3provided a $400 million recovery for the class and created a mechanism that allowed the vast majority
of class members to share in an additional $250 million recovered by the SEC. In 2008, Robbins
Geller attorneys recovered an additional $45 million for the class in a settlement with defendants
Joseph P. Nacchio and Robert S. Woodruff, the CEO and CFO, respectively, of Qwest during large
portions of the class period.

Fort Worth Emps.' Ret. Fund v. J.P. Morgan Chase & Co., No. 1:09-cv-03701 (S.D.N.Y.).
Robbins Geller attorneys served as lead counsel for a class of investors and obtained court approval
of a $388 million recovery in nine 2007 residential mortgage-backed securities offerings issued by
J.P. Morgan. The settlement represents, on a percentage basis, the largest recovery ever achieved in
an MBS purchaser class action. The result was achieved after more than five years of hard-fought
litigation and an extensive investigation.

NECA-IBEW Health & Welfare Fund v. Goldman Sachs & Co., No. 1:08-cv-10783 (S.D.N.Y.).
As sole lead counsel, Robbins Geller obtained a $272 million settlement on behalf of Goldman
Sachs' shareholders. The settlement, subject to court approval, concludes one of the last remaining
mortgage-backed securities purchaser class actions arising out of the global financial crisis. The
remarkable result was achieved following seven years of extensive litigation. After the claims were
dismissed in 2010, Robbins Geller secured a landmark victory from the Second Circuit Court of
Appeals that clarified the scope of permissible class actions asserting claims under the Securities Act
of 1933 on behalf of MBS investors. Specifically, the Second Circuit's decision rejected the concept
of “tranche” standing and concluded that a lead plaintiff in an MBS class action has class standing to
pursue claims on behalf of purchasers of other securities that were issued from the same registration
statement and backed by pools of mortgages originated by the same lenders who had originated
mortgages backing the lead plaintiff's securities.

In re AT&T Corp. Sec. Litig., MDL No. 1399 (D.NJ.). Robbins Geller attorneys served as lead
counsel for a class of investors that purchased AT&T common stock. The case charged defendants
AT&T and its former Chairman and CEO, C. Michael Armstrong, with violations of the federal
securities laws in connection with AT&T's April 2000 initial public offering of its wireless tracking
stock, the largest IPO in American history. After two weeks of trial, and on the eve of scheduled
testimony by Armstrong and infamous telecom analyst Jack Grubman, defendants agreed to settle the
case for $100 million.

Silverman v. Motorola, Inc., No. 1:07-cv-04507 (N.D. Ill). The Firm served as lead counsel on
behalf of a class of investors in Motorola, Inc., ultimately recovering $200 million for investors just two
months before the case was set for trial. This outstanding result was obtained despite the lack of an
SEC investigation or any financial restatement.

Nieman v. Duke Energy Corp., No. 3:12-cv-00456 (W.D.N.C.). Robbins Geller, along with co-
counsel, obtained a $146.25 million settlement on behalf of Duke Energy Corporation investors. The
settlement resolves accusations that defendants misled investors regarding Duke's future leadership
following its merger with Progress Energy, Inc., and specifically, their premeditated coup to oust
William D. Johnson (CEO of Progress) and replace him with Duke's then-CEO, John Rogers. This
historic settlement represents the largest recovery ever in a North Carolina securities fraud action,
and one of the five largest recoveries in the Fourth Circuit.

Bennett v. Sprint Nextel Corp., No. 2:09-cv-02122 (D. Kan.). As co-lead counsel, Robbins Geller
obtained a $131 million recovery for a class of Sprint investors. The settlement, secured after five
years of hard-fought litigation, resolved claims that former Sprint executives misled investors
concerning the success of Sprint's ill-advised merger with Nextel and the deteriorating credit quality
of Sprint's customer base, artificially inflating the value of Sprint's securities.

Garden City Emps.’ Ret. Sys. v. Psychiatric Sols., Inc., No. 3:09-cv-00882 (M.D. Tenn.). In the
Psychiatric Solutions case, Robbins Geller represented lead plaintiff and class representative Central
States, Southeast and Southwest Areas Pension Fund in litigation spanning more than four years.
Psychiatric Solutions and its top executives were accused of insufficiently staffing their in-patient
hospitals, downplaying the significance of regulatory investigations and manipulating their malpractice

Robbins Geller Rudman & Bawd LLP Firm Resume | 4reserves. Just days before trial was set to commence, attorneys from Robbins Geller achieved a $65
million settlement which was the third-largest securities recovery ever in the district and the largest in
a decade.

= Inre St. Jude Med., Inc. Sec. Litig., No. 0:10-cv-00851 (D. Minn.). After four and one half years of
litigation and mere weeks before the jury selection, Robbins Geller obtained a $50 million settlement
on behalf of investors in medical device company St. Jude Medical. The settlement resolves
accusations that St. Jude Medical misled investors by utilizing heavily discounted end-of-quarter bulk
sales to meet quarterly expectations, which created a false picture of demand by increasing customer
inventory due of St. Jude Medical devices. The complaint alleged that the risk of St. Jude Medical's
reliance on such bulk sales manifested when it failed to meet its forecast guidance for the third
quarter of 2009, which the company had reaffirmed only weeks earlier.

Robbins Geller's securities practice is also strengthened by the existence of a strong appellate department,
whose collective work has established numerous legal precedents. The securities practice also utilizes an
extensive group of in-house economic and damage analysts, investigators and forensic accountants to aid in
the prosecution of complex securities issues.

Shareholder Derivative and Corporate Governance Litigation

The Firm's shareholder derivative and corporate governance practice is focused on preserving corporate
assets and enhancing long-term shareowner value. Shareowner derivative actions are often brought by
institutional investors to vindicate the rights of the corporation injured by its executives' misconduct, which can
effect violations of the nation’s securities, anti-corruption, false claims, cyber-security, labor, environmental
and/or health & safety laws.

Robbins Geller attorneys have aided Firm clients in significantly enhancing shareowner value by obtaining
hundreds of millions of dollars in financial clawbacks and successfully negotiating corporate governance
enhancements. Robbins Geller has worked with its institutional clients to address corporate misconduct such
as options backdating, bribery of foreign officials, pollution, off-label marketing, and insider trading and related
self-dealing. Additionally, the Firm works closely with noted corporate governance consultants Robert Monks,
Richard Bennett and their firm, ValueEdge Advisors LLC, to shape corporate governance practices that will
benefit shareowners.

Robbins Geller’s efforts have conferred substantial benefits upon shareowners, and the market effect of these
benefits measures in the billions of dollars. The Firm's significant achievements include:

= City of Westland Police and Fire Retirement System v. Stumpf (Wells Fargo Derivative
Litigation), No. 3:11-cv-02369 (N.D. Cal.). Prosecuted shareholder derivative action on behalf of
Wells Fargo & Co. alleging that Wells Fargo's executives allowed participation in the mass-
processing of home foreclosure documents by engaging in widespread robo-signing, i.e., the
execution and submission of false legal documents in courts across the country without verification of
their truth or accuracy, and failed to disclose Wells Fargo's lack of cooperation in a federal
investigation into the bank’s mortgage and foreclosure practices. In settlement of the action, Wells
Fargo agreed to provide $67 million in homeowner down-payment assistance, credit counseling and
improvements to its mortgage servicing system. The initiatives will be concentrated in cities severely
impacted by the bank's foreclosure practices and the ensuing mortgage foreclosure crisis.
Additionally, Wells Fargo agreed to change its procedures for reviewing shareholder proposals and a
strict ban on stock pledges by Wells Fargo board members.

* In re Ormat Techs., Inc. Derivative Litig., No. CV10-00759 (Nev. Dist. Ct., Washoe Cty.). Robbins
Geller brought derivative claims for breach of fiduciary duty and unjust enrichment against the
directors and certain officers of Ormat Technologies, Inc., a leading geothermal and recovered energy
power business. During the relevant time period, these Ormat insiders caused the company to
engage in accounting manipulations that ultimately required restatement of the company's financial
statements. The settlement in this action includes numerous corporate governance reforms designed
to, among other things: (i) increase director independence; (ii) provide continuing education to

Robbins Geller Rudman & Bawd LLP Firm Resume | 5directors; (iii) enhance the company’s internal controls; (iv) make the company’s board more
independent; and (iv) strengthen the company’s internal audit function.

In re Ormat Techs., Inc. Derivative Litig., No. CV10-00759 (Nev. Dist. Ct., Washoe Cty.). Robbins
Geller brought derivative claims for breach of fiduciary duty and unjust enrichment against the
directors and certain officers of Ormat Technologies, Inc., a leading geothermal and recovered energy
power business. During the relevant time period, these Ormat insiders caused the company to
engage in accounting manipulations that ultimately required restatement of the company's financial
statements. The settlement in this action includes numerous corporate governance reforms designed
to, among other things: (i) increase director independence; (ii) provide continuing education to
directors; (iii) enhance the company's internal controls; (iv) make the company’s board more
independent; and (iv) strengthen the company’s internal audit function.

In re Alphatec Holdings, Inc. Derivative S'holder Litig., No. 37-2010-00058586 (Cal. Super. Ct,
San Diego Cty.). Obtained sweeping changes to Alphatec’s governance, including separation of the
Chairman and CEO positions, enhanced conflict of interest procedures to address related-party
transactions, rigorous director independence standards requiring that at least a majority of directors
be outside independent directors, and ongoing director education and training.

In re Finisar Corp. Derivative Litig., No. C-06-07660 (N.D. Cal.). Prosecuted shareholder
derivative action on behalf of Finisar against certain of its current and former directors and officers for
engaging in an alleged nearly decade-long stock option backdating scheme that was alleged to have
inflicted substantial damage upon Finisar. After obtaining a reversal of the district court's order
dismissing the complaint for failing to adequately allege that a pre-suit demand was futile, Robbins
Geller lawyers successfully prosecuted the derivative claims to resolution obtaining over $15 million
in financial clawbacks for Finisar. Robbins Geller attorneys also obtained significant changes to
Finisar's stock option granting procedures and corporate governance. As a part of the settlement,
Finisar agreed to ban the repricing of stock options without first obtaining specific shareholder
approval, prohibit the retrospective selection of grant dates for stock options and similar awards, limit
the number of other boards on which Finisar directors may serve, require directors to own a minimum
amount of Finisar shares, annually elect a Lead Independent Director whenever the position of
Chairman and CEO are held by the same person, and require the board to appoint a Trading
Compliance officer responsible for ensuring compliance with Finisar’s insider trading policies.

Loizides v. Schramm (Maxwell Technology Derivative Litigation), No. 37-2010-00097953 (Cal.
Super. Ct., San Diego Cty.). Prosecuted shareholder derivative claims arising from the company’s
alleged violations of the Foreign Corrupt Practices Act of 1977 (“FCPA”). As a result of Robbins
Geller's efforts, Maxwell insiders agreed to adopt significant changes in Maxwell's internal controls
and systems designed to protect Maxwell against future potential violations of the FCPA. These
corporate governance changes included, establishing the following, among other things: a
compliance plan to improve board oversight of Maxwell's compliance processes and internal controls;
a clear corporate policy prohibiting bribery and subcontracting kickbacks, whereby individuals are
accountable; mandatory employee training requirements, including the comprehensive explanation of
whistleblower provisions, to provide for confidential reporting of FCPA violations or other corruption;
enhanced resources and internal control and compliance procedures for the audit committee to act
quickly if an FCPA violation or other corruption is detected; an FCPA and Anti-Corruption
Compliance department that has the authority and resources required to assess global operations
and detect violations of the FCPA and other instances of corruption; a rigorous ethics and
compliance program applicable to all directors, officers and employees, designed to prevent and
detect violations of the FCPA and other applicable anti-corruption laws; an executive-level position of
Chief Compliance Officer with direct board-level reporting responsibilities, who shall be responsible
for overseeing and managing compliance issues within the company; a rigorous insider trading policy
buttressed by enhanced review and supervision mechanisms and a requirement that all trades are
timely disclosed; and enhanced provisions requiring that business entities are only acquired after
thorough FCPA and anti-corruption due diligence by legal, accounting and compliance personnel at
Maxwell.

Robbins Geller Rudman & Bawd LLP Firm Resume | 6= In re SciClone Pharm., Inc. S’holder Derivative Litig., No. CIV 499030 (Cal. Super Ct., San Mateo
Cty.). Robbins Geller attorneys successfully prosecuted the derivative claims on behalf of nominal
party SciClone Pharmaceuticals, Inc., resulting in the adoption of state-of-the-art corporate
governance reforms. The corporate governance reforms included the establishment of an FCPA
compliance coordinator; the adoption of an FCPA compliance program and code; and the adoption of
additional internal controls and compliance functions.

= Policemen & Firemen Ret. Sys. of the City of Detroit v. Cornelison (Halliburton Derivative
Litigation), No. 2009-29987 (Tex. Dist. Ct., Harris Cty.). Prosecuted shareholder derivative claims
on behalf of Halliburton Company against certain Halliburton insiders for breaches of fiduciary duty
arising from Halliburton's alleged violations of the FCPA. In the settlement, Halliburton agreed,
among other things, to adopt strict intensive controls and systems designed to detect and deter the
payment of bribes and other improper payments to foreign officials, to enhanced executive
compensation clawback, director stock ownership requirements, a limitation on the number of other
boards that Halliburton directors may serve, a lead director charter, enhanced director independence
standards, and the creation of a management compliance committee.

= In re UnitedHealth Grp. Inc. PSLRA Litig., No. 06-CV-1691 (D. Minn.). In the UnitedHealth
case, our client, CalPERS, obtained sweeping corporate governance improvements, including the
election of a shareholder-nominated member to the company’s board of directors, a mandatory
holding period for shares acquired by executives via option exercises, as well as executive
compensation reforms that tie pay to performance. In addition, the class obtained $925 million, the
largest stock option backdating recovery ever and four times the next largest options backdating
recovery.

= In re Fossil, Inc. Derivative Litig., No. 3:06-cv-01672 (N.D. Tex.). The settlement agreement
included the following corporate governance changes: declassification of elected board members;
retirement of three directors and addition of five new independent directors; two-thirds board
independence requirements; corporate governance guidelines providing for “Majority Voting” election
of directors; lead independent director requirements; revised accounting measurement dates of
options; addition of standing finance committee; compensation clawbacks; director compensation
standards; revised stock option plans and grant procedures; limited stock option granting authority,
timing and pricing; enhanced education and training; and audit engagement partner rotation and
outside audit firm review.

«Pirelli Armstrong Tire Corp. Retiree Med. Benefits Trust v. Sinegal (Costco Derivative
Litigation), No. 2:08-cv-01450 (W.D. Wash.). The parties agreed to settlement terms providing for
the following corporate governance changes: the amendment of Costco's bylaws to provide “Majority
Voting” election of directors; the elimination of overlapping compensation and audit committee
membership on common subject matters; enhanced Dodd-Frank requirements; enhanced internal
audit standards and controls, and revised information-sharing procedures; revised compensation
policies and procedures; revised stock option plans and grant procedures; limited stock option
granting authority, timing and pricing; and enhanced ethics compliance standards and training.

= In re FS Networks, Inc. Derivative Litig., No. C-06-0794 (W.D. Wash.). The parties agreed to the
following corporate governance changes as part of the settlement: revised stock option plans and
grant procedures; limited stock option granting authority, timing and pricing; “Majority Voting” election
of directors; lead independent director requirements; director independence standards; elimination of
director perquisites; and revised compensation practices.

Options Backdating Litigation

As has been widely reported in the media, the stock options backdating scandal suddenly engulfed hundreds
of publicly traded companies throughout the country in 2006. Robbins Geller was at the forefront of
investigating and prosecuting options backdating derivative and securities cases. The Firm has recovered
over $1 billion in damages on behalf of injured companies and shareholders.

Robbins Geller Rudman & Bawd LLP Firm Resume | 7In re KLA-Tencor Corp. S'holder Derivative Litig., No. C-O6-03445 (N.D. Cal.). After successfully
opposing the special litigation committee of the board of directors’ motion to terminate the derivative
claims, Robbins Geller recovered $43.6 million in direct financial benefits for KLATencor, including
$33.2 million in cash payments by certain former executives and their directors’ and officers’
insurance carriers,

In re Marvell Technology Grp. Ltd. Derivative Litig., No. C-06-03894 (N.D. Cal.). Robbins Geller
recovered $54.9 million in financial benefits, including $14.6 million in cash, for Marvell, in addition to
extensive corporate governance reforms related to Marvell's stock option granting practices, board of
directors’ procedures and executive compensation.

In re KB Home S'holder Derivative Litig., No. 06-CV-05148 (C.D. Cal.). Robbins Geller served as
co-lead counsel for the plaintiffs and recovered more than $31 million in financial benefits, including
$21.5 million in cash, for KB Home, plus substantial corporate governance enhancements relating to
KB Home's stock option granting practices, director elections and executive compensation practices.

Corporate Takeover Litigation

Robbins Geller has earned a reputation as the leading law firm in representing shareholders in corporate
takeover litigation. Through its aggressive efforts in prosecuting corporate takeovers, the Firm has secured for
shareholders billions of dollars of additional consideration as well as beneficial changes for shareholders in the
context of mergers and acquisitions.

The Firm regularly prosecutes merger and acquisition cases post-merger, often through trial, to maximize the
benefit for its shareholder class. Some of these cases include:

In re Kinder Morgan, Inc. S'holders Litig., No. 06-C-801 (Kan. Dist. Ct, Shawnee Cty.). In the
largest recovery ever for corporate takeover litigation, the Firm negotiated a settlement fund of $200
million in 2010.

In re Dole Food Co., Inc. Stockholder Litig., No. 8703-VCL (Del. Ch.). Robbins Geller and co-
counsel went to trial in the Delaware Court of Chancery on claims of breach of fiduciary duty on
behalf of Dole Food Co., Inc. shareholders. The litigation challenged the 2013 buyout of Dole by its
billionaire Chief Executive Officer and Chairman, David H. Murdock. On August 27, 2015, the court
issued a post-trial ruling that Murdock and fellow director C. Michael Carter — who also served as
Dole’s General Counsel, Chief Operating Officer and Murdock’s top lieutenant — had engaged in
fraud and other misconduct in connection with the buyout and are liable to Dole's former stockholders
for over $148 million, the largest trial verdict ever in a class action challenging a merger transaction.

In re Rural Metro Corp. Stockholders Litig., No. 6350-VCL (Del. Ch.). Robbins Geller and co-
counsel were appointed lead counsel in this case after successfully objecting to an inadequate
settlement that did not take into account evidence of defendants’ conflicts of interest. In a post-trial
opinion, Delaware Vice Chancellor J. Travis Laster found defendant RBC Capital Markets, LLC liable
for aiding and abetting Rural/Metro's board of directors’ fiduciary duty breaches in the $438 million
buyout of Rural/Metro, citing “the magnitude of the conflict between RBC’s claims and the evidence.”
RBC was ordered to pay nearly $100 million as a result of its wrongdoing, the largest damage award
ever obtained against a bank over its role as a merger adviser. The Delaware Supreme Court issued
a landmark opinion affirming the judgment on November 30, 2015, RBC Capital Markets, LLC v.
Jervis, __ A3d___, 2015 Del. LEXIS 629 (Del. 2015).

In re Del Monte Foods Co. S'‘holders Litig., No. 6027-VCL (Del. Ch.). Robbins Geller exposed the
unseemly practice by investment bankers of participating on both sides of large merger and
acquisition transactions and ultimately secured an $89 million settlement for shareholders of Del
Monte. For efforts in achieving these results, the Robbins Geller lawyers prosecuting the case were
named Attorneys of the Year by California Lawyer magazine in 2012.

Robbins Geller Rudman & Bawd LLP Firm Resume | &= In re Chaparral Res., Inc. S'holders Litig., No. 2633-VCL (Del. Ch.). After a full trial and a
subsequent mediation before the Delaware Chancellor, the Firm obtained a common fund settlement
of $41 million (or 45% increase above merger price) for both class and appraisal claims.

= In re TD Banknorth S’holders Litig., No. 2557-VCL (Del. Ch.). After objecting to a modest recovery
of just a few cents per share, the Firm took over the litigation and obtained a common fund settlement
of $50 million.

= In re eMachines, Inc. Merger Litig., No. 01-CC-00156 (Cal. Super. Ct., Orange Cty.). After four
years of litigation, the Firm secured a common fund settlement of $24 million on the brink of trial.

= In re Prime Hospitality, Inc. S’holders Litig., No. 652-N (Del. Ch.). The Firm objected to a
settlement that was unfair to the class and proceeded to litigate breach of fiduciary duty issues
involving a sale of hotels to a private equity firm. The litigation yielded a common fund of $25 million
for shareholders.

= In re Dollar Gen. Corp. S'holder Litig., No. O7MD-1 (Tenn. Cir. Ct., Davidson Cty.). As lead
counsel, the Firm secured a recovery of up to $57 million in cash for former Dollar General
shareholders on the eve of trial.

= In re UnitedGlobalCom, Inc. S'holder Litig., No. 1012-VCS (Del. Ch.). The Firm secured a
common fund settlement of $25 million just weeks before trial.

= Harrah's Entertainment, No. A529183 (Nev. Dist. Ct., Clark Cty.). The Firm's active prosecution of
the case on several fronts, both in federal and state court, assisted Harrah's shareholders in securing
an additional $1.65 billion in merger consideration.

= In re Chiron S’holder Deal Litig., No. RG 05-230567 (Cal. Super. Ct., Alameda Cty.). The Firm’s
efforts helped to obtain an additional $800 million in increased merger consideration for Chiron
shareholders.

= In re PeopleSoft, Inc. S'holder Litig., No. RG-03100291 (Cal. Super. Ct., Alameda Cty.). The Firm
successfully objected to a proposed compromise of class claims arising from takeover defenses by
PeopleSoft, Inc. to thwart an acquisition by Oracle Corp., resulting in shareholders receiving an
increase of over $900 million in merger consideration.

= ACS S'holder Litig., No. CC-09-07377-C (Tex. Cty. Ct, Dallas Cty.). The Firm forced ACS’s
acquirer, Xerox, to make significant concessions by which shareholders would not be locked out of
receiving more money from another buyer.

Insurance

Fraud and collusion in the insurance industry by executives, agents, brokers, lenders and others is one of the
most costly crimes in the United States. Some experts have estimated the annual cost of white collar crime in
the insurance industry to be over $120 billion nationally. Recent legislative proposals seek to curtail anti-
competitive behavior within the industry. However, in the absence of comprehensive regulation, Robbins
Geller has played a critical role as private attorney general in protecting the rights of consumers against
insurance fraud and other unfair business practices within the insurance industry.

Robbins Geller attorneys have long been at the forefront of litigating race discrimination issues within the life
insurance industry. For example, the Firm has fought the practice by certain insurers of charging African-
Americans and other people of color more for life insurance than similarly situated Caucasians. The Firm
recovered over $400 million for African-Americans and other minorities as redress for civil rights abuses,
including landmark recoveries in McNeil v. American General Life & Accident Insurance Company, Thompson
v. Metropolitan Life Insurance Company; and Williams v. United Insurance Company of America.

The Firm's attorneys fight on behalf of elderly victims targeted for the sale of deferred annuity products with
hidden sales loads and illusory bonus features. Sales agents for life insurance companies such as Allianz Life
Insurance Company of North America, Midland National Life Insurance Company, and National Western Life

Robbins Geller Rudman & Bawd LLP Firm Resume | 9Insurance Company targeted senior citizens for these annuities with lengthy investment horizons and high
sales commissions. The Firm recovered millions of dollars for elderly victims and seeks to ensure that senior
citizens are afforded full and accurate information regarding deferred annuities.

Robbins Geller attorneys also stopped the fraudulent sale of life insurance policies based on
misrepresentations about how the life insurance policy would perform, the costs of the policy, and whether
premiums would “vanish.” Purchasers were also misled about the financing of a new life insurance policy,
falling victim to a “replacement” or “churning” sales scheme where they were convinced to use loans, partial
surrenders or withdrawals of cash values from an existing permanent life insurance policy to purchase a new

policy.

Brokerage “Pay to Play” Cases. On behalf of individuals, governmental entities, businesses, and
non-profits, Robbins Geller has sued the largest commercial and employee benefit insurance brokers
and insurers for unfair and deceptive business practices. While purporting to provide independent,
unbiased advice as to the best policy, the brokers failed to adequately disclose that they had entered
into separate “pay to play” agreements with certain third-party insurance companies. These
agreements provide additional compensation to the brokers based on such factors as profitability,
growth and the volume of insurance that they place with a particular insurer, and are akin to a profit-
sharing arrangement between the brokers and the insurance companies. These agreements create a
conflict of interest since the brokers have a direct financial interest in selling their customers only the
insurance products offered by those insurance companies with which the brokers have such
agreements.

Robbins Geller attorneys were among the first to uncover and pursue the allegations of these
practices in the insurance industry in both state and federal courts. On behalf of the California
Insurance Commissioner, the Firm brought an injunctive case against the biggest employee benefit
insurers and local San Diego brokerage, ULR, which resulted in major changes to the way they did
business. The Firm also sued on behalf of the City and County of San Francisco to recover losses
due to these practices. Finally, Robbins Geller represents a putative nationwide class of individuals,
businesses, employers, and governmental entities against the largest brokerage houses and insurers
in the nation. To date, the Firm has obtained over $200 million on behalf of policyholders and
enacted landmark business reforms.

Discriminatory Credit Scoring and Redlining Cases. Robbins Geller attorneys have prosecuted
cases concerning countrywide schemes of alleged discrimination carried out by Nationwide, Allstate,
and other insurance companies against African-American and other persons of color who are
purchasers of homeowner and automobile insurance policies. Such discrimination includes alleged
redlining and the improper use of “credit scores,” which disparately impact minority communities.
Plaintiffs in these actions have alleged that the insurance companies’ corporate-driven scheme of
intentional racial discrimination includes refusing coverage and/or charging them higher premiums for
homeowners and automobile insurance. On behalf of the class of aggrieved policyholders, the Firm
has recovered over $400 million for these predatory and racist policies.

Senior Annuities. Robbins Geller has prosecuted numerous cases against insurance companies and
their agents who targeted senior citizens for the sale of deferred annuities. Plaintiffs alleged that the
insurers misrepresented or failed to disclose to senior consumers material facts concerning the costs
associated with their fixed and equity indexed deferred annuities and enticed seniors to buy the
annuities by promising them illusory up-front bonuses. As a result of the Firm's efforts, hundreds of
millions of dollars in economic relief has been made available to seniors who have been harmed by
these practices. Notable recoveries include:

«Negrete v. Allianz Life Ins. Co. of N. Am., No. CV-05-6838 (C.D. Cal.). Robbins Geller
attorneys served as co-lead counsel on behalf of a nationwide RICO class consisting of over
200,000 senior citizens who had purchased deferred annuities issued by Allianz Life
Insurance Company of North America. In March 2015, after nine years of litigation, District
Judge Christina A. Snyder granted final approval of a class action settlement that made
available in excess of $250 million in cash payments and other benefits to class members. In

Robins Geller Rudman & Dowd LLP Firm Resume | 10Antitrust
Robbins

approving the settlement, the Court praised the effort of the Firm and noted that “counsel has
represented their clients with great skill and they are to be complimented.”

= In re Am. Equity Annuity Practices & Sales Litig., No. CV-05-6735 (C.D. Cal.). As co-
lead counsel, Robbins Geller attorneys secured a settlement that made available $129
million in economic benefits to a nationwide class of 114,000 senior citizens.

= In re Midland Nat'l Life Ins. Co. Annuity Sales Practices Litig., MDL No. 07-1825 (C.D.
Cal.). After four years of litigation, the Firm secured a settlement that made available $79.5
million in economic benefits to a nationwide class of 70,000 senior citizens.

«Negrete v. Fidelity & Guar. Life Ins. Co., No. CV-05-6837 (C.D. Cal.). The Firm's efforts
resulted in a settlement under which Fidelity made available $52.7 in benefits to 56,000
class members across the country.

= In re Nat'l Western Life Ins. Deferred Annuities Litig., No. 05-CV-1018 (S.D. Cal.). The
Firm litigated this action for more than eight years. On the eve of trial, the Firm negotiated a
settlement providing over $21 million in value to a nationwide class of 12,000 senior citizens.

Geller's antitrust practice focuses on representing businesses and individuals who have been the

victims of price-fixing, unlawful monopolization, market allocation, tying and other anti-competitive conduct.
The Firm has taken a leading role in many of the largest federal and state price-fixing, monopolization, market

allocatiot

n and tying cases throughout the United States.

In re Payment Card Interchange Fee and Merchant Discount Antitrust Litig., 05 MDL No. 1720
(E.D.N.Y.). Robbins Geller attorneys are co-lead counsel in a case that has resulted in the largest-
ever antitrust class action settlement. In December 2013, the district judge granted final approval of
a settlement that will provide approximately $5.7 billion to class members, in addition to injunctive
relief. Plaintiffs, merchants that accept Visa or MasterCard, alleged that the defendants’ collective
imposition of rules governing payment card acceptance violated federal and state antitrust laws. The
court commended class counsel for “achieving substantial value” for the class through their
“extraordinary efforts,” and said they litigated the case with “skill and tenacity.” The trial court's final
approval decision is currently on appeal.

Dahl v. Bain Capital Partners, LLC, No. 07-cv-12388-EFH (D. Mass). Robbins Geller attorneys
served as co-lead counsel on behalf of shareholders in this action against the nation’s largest private
equity firms who colluded to restrain competition to suppress prices paid to shareholders of public
companies in connection with leveraged buyouts. After nearly seven years of hard-fought litigation, in
March 2015, the court approved several settlements totaling $590.5 million. The aggregate
settlement is the largest class action antitrust settlement ever in which no civil or criminal government
action was taken.

Alaska Elec. Pension Fund v. Bank of America Corporation, No. 14-cv-07126-JMF (S.D.N.Y,).
Robbins Geller attorneys are prosecuting antitrust claims against 13 major banks and broker ICAP
pic who are alleged to have conspired to manipulate the ISDAfix rate, the key interest rate for a broad
range of interest rate derivatives and other financial instruments. The class action is brought on behalf
of investors and market participants who entered into an interest rate derivative transaction during an
eight-year period from 2006 to 2014.

In re Currency Conversion Fee Antitrust Litig., 01 MDL No. 1409 (S.D