Wong v. Arlo Technologies, Inc., et al.

NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION, MOTION FOR ATTORNEYS’ FEES AND EXPENSES, AND SETTLEMENT FAIRNESS HEARING

PLEASE READ THIS ENTIRE NOTICE CAREFULLY. IT CONTAINS IMPORTANT INFORMATION ABOUT YOUR RIGHTS CONCERNING A PROPOSED CLASS ACTION SETTLEMENT.

A Federal Court authorized this Notice. This is not a solicitation from a lawyer.

If you purchased common stock of Arlo Technologies, Inc. (“Arlo”) between August 3, 2018 through December 2, 2018, inclusive (“Class Period”), you could get a payment from a class action settlement.¹

The Settlement, if approved by the Court, would provide $1,250,000 in cash for the benefit of the Settlement Class (described below).

The Settlement resolves claims by Matis Nyman (“Lead Plaintiff”) in a class action against Arlo, certain of its current and former officers and directors, certain investment banks that served as underwriters in Arlo’s initial public offering, and a former Arlo stockholder. Lead Plaintiff alleges that Defendants made materially false or misleading statements concerning Arlo’s ability to innovate new products and the availability of such products.

Defendants Arlo; Matthew McRae; Christine M. Gorjanc; Patrick C.S. Lo; Andrew W. Kim (the “Individual Defendants,” and together with Arlo, the “Arlo Defendants”); and Merrill Lynch, Pierce, Fenner & Smith Incorporated; Deutsche Bank Securities Inc.; Guggenheim Securities LLC; Raymond James & Associates, Inc.; Cowen and Company, LLC; and Imperial Capital, LLC (the “Underwriter Defendants”); and NETGEAR, Inc. (“Netgear”) deny all allegations of misconduct. Defendants also deny that Lead Plaintiff or any member of the Settlement Class suffered damages. The Court has not decided in favor of any party in the litigation.

Class Counsel intends to seek attorneys’ fees not to exceed 25% of the Settlement Fund, as well as for reimbursement of litigation expenses, which will include a reimbursement request for Lead Plaintiff pursuant to the Private Securities Litigation Reform Act of 1995 (the “PSLRA”). If approved by the Court, these amounts will be deducted from the $1,250,000 amount. The estimated average recovery, after deducting attorneys’ fees and expenses, administrative costs, and an award of reasonable costs and expenses to Lead Plaintiff would be approximately $0.0684 per allegedly damaged share.

The parties do not agree on the average amount of damages per share that would be recoverable if Lead Plaintiff were to prevail in the litigation. The issues on which the parties disagree are many, but include the extent to which certain public statements made by defendants – that Lead Plaintiff claims were false or misleading – influenced (if at all) the price of Arlo’s common stock.

The Court has not yet approved the Settlement. Payments will be made only if the Court approves the Settlement and after any appeals are resolved. Please be patient.

If you are a member of the Settlement Class, your legal rights will be affected by this Settlement whether you act or do not act. Read this notice carefully.

YOUR LEGAL RIGHTS AND OPTIONS WITH REGARD TO THIS SETTLEMENT
MAIL IN A PROOF OF CLAIM AND RELEASE FORM BY FEBRUARY 25, 2021	This is the only way to get a payment. (See Question 9.)
EXCLUDE YOURSELF FROM THE CLASS BY FEBRUARY 18, 2021	You will get no payment and cannot object or speak at the hearing. This is the only way you can ever be a part of any other lawsuit against Defendants concerning the subject matter of this case. (See Question 11.)
OBJECT BY FEBRUARY 18, 2021	Write to the Court about why you do not like the Settlement, the Plan of Allocation, or the request for attorneys’ fees. You can still mail in a Proof of Claim form. If the Court approves the Settlement, you will be bound by it. (See Question 13.)
ATTEND THE FINAL APPROVAL HEARING ON MARCH 11, 2021	Ask to speak in Court about the fairness of the Settlement. If the Court approves the Settlement, you will be bound by it. (See Question 21.) The Court may postpone the hearing without prior notice on the date scheduled for the hearing.
DO NOTHING	You will get no payment AND give up your rights to bring your own individual action. (See Question 15.)

These rights and options, and the deadlines to exercise them, are explained in further detail later in this Notice.

Further Information: Lead Plaintiff and the Settlement Class are represented by Aaron Zigler of Keller Lenkner LLC. Further information regarding the Action, the Settlement, and this Notice may be obtained by contacting Class Counsel at Arlo Securities Litigation, c/o Keller Lenkner LLC, 150 N. Riverside Plaza, Suite 4270, Chicago, IL 60606, (312) 776-2920, arloclaims@klclientservices.com, or the Settlement Administrator at Arlo Securities Litigation, c/o Settlement Administrator, 1650 Arch Street, Suite 2210, Philadelphia, PA 19130, (844) 983-1303, info@ArloSecuritiesLitigation.com.