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PROPOSED QUEBEC CLASS ACTION SETTLEMENT

STUBHUB TICKET PURCHASES MADE IN QUEBEC BEFORE MARCH 11, 2020 

FOR EVENTS WHICH WERE CANCELLED, POSTPONED OR RESCHEDULED AFTER MARCH 11, 2020

CLASS ACTION AUTHORIZED AND UPCOMING PROPOSED SETTLEMENT APPROVAL HEARING

A proposed settlement (“Settlement”) has been reached, subject to Court approval, between Mr. Patterson (the “Plaintiff”) and STUBHUB INC. and STUBHUB CANADA LTD. (“StubHub“) in the context of a class action instituted against several ticketing platforms including StubHub with respect to the purchase, prior to March 11, 2020, of tickets for events scheduled to take place after March 11, 2020, which events were subsequently either cancelled, postponed or rescheduled, without a full refund for the tickets purchased being provided (the “Class Action”). The Superior Court of Quebec authorized the Class Action, for settlement purposes, on May 10, 2022. This proposed Settlement may affect your rights, whether you act or not. Please read this notice carefully. Note: This proposed Settlement is only with regards to StubHub customers in Quebec. BASIC INFORMATION If you a Quebec resident and you have purchased before March 11, 2020 one or more tickets from StubHub for an event scheduled to take place after March 11, 2020, which event was subsequently either cancelled, postponed or rescheduled, without a full refund being provided by StubHub, you could be eligible to receive benefits under the Settlement, if approved by the Court. The purpose of this notice is to inform you that the Plaintiff and StubHub have reached a proposed Settlement putting an end to the Class Action (subject to Court approval). All concerned parties believe that the proposed Settlement is the best solution to dispose fairly and equitably of the dispute; they will ask the Superior Court of Quebec to approve it. The Superior Court of Quebec will hold a hearing to determine whether it will approve the proposed Settlement. You may attend the hearing, which will take place virtually on June 17, 2022 at 9:30 a.m. in room 16.02 of the Montreal Courthouse using the following Microsoft Teams link: https://url.justice.gouv.qc.ca/oCT0. According to the Plaintiff, StubHub committed a fault by modifying its “StubHub Marketplace Global User Agreement” by offering a 120% credit of the value of tickets instead of fully reimbursing Quebec residents for all amounts paid before March 11, 2020, regarding tickets for events scheduled after March 11, 2020, which events were subsequently cancelled.  Again, according to the Plaintiff, StubHub committed a fault by providing in its “StubHub Marketplace Global User Agreement” that it would not fully reimburse Quebec residents for all amounts paid before March 11, 2020 for event tickets, which events were subsequently either postponed or rescheduled after March 11, 2020. These allegations have not been proven in Court and are contested by StubHub, whose position is that they have complied at all times with all applicable legislation, including with respect to the modifications to its “StubHub Marketplace Global User Agreement”. You are a Group Member if you meet all of the following conditions: 1. You are a user of the StubHub Services that had a Quebec billing address associated with your Account at the time of purchase of the Ticket(s); 2. you have purchased before March 11, 2020 at least one ticket from StubHub to at least one event scheduled to take place after March 11, 2020, which event was subsequently cancelled and have opted to keep the 120% credit (“Credit”) instead of defaulting to a full refund; or you have purchased before March 11, 2020 at least one ticket from StubHub to at least one event scheduled to take place after March 11, 2020, which event was subsequently either postponed or rescheduled (“Ticket(s)”); 3. you have not already used the Ticket(s) to attend the event(s) to which the Ticket(s) grant access; and 4. you have not already received a refund or used in its entirety or in part the 120% Credit previously received for such Ticket(s).   SETTLEMENT SUMMARY Without any admission of liability, for the purpose of avoiding a trial and the additional costs and expenses related thereto, StubHub agrees to the following: 1. Each Eligible Member shall be entitled to, alternatively, (i) retain his or her Ticket(s); or (ii) cancel the contract by which he or she purchased his or her Ticket(s) and receive a benefit in the form of a credit in an amount equal to one hundred and twenty percent (120%) of the value of the Ticket(s) purchased (including all ticket prices paid, fees, taxes, additional services purchased such as parking, etc.); or (iii) cancel the contract by which he or she purchased his or her Ticket(s) and obtain the restitution of an amount equal to the value of the Ticket(s) purchased in cash (including all ticket prices paid, fees, taxes, additional services purchased such as parking, etc.), at the Eligible Member’s option; 2. Implement a business practice change regarding tickets to events that have been postponed or rescheduled, providing for a refund upon a request being made by a Quebec resident. If you meet the four conditions described above to be a Group Member, if you have not already used your Ticket(s) to attend the events to which the Tickets grant access and if you do not wish to retain your Ticket(s), you could be eligible to receive a benefit in the form of a credit in an amount equal to one hundred and twenty percent (120%) of the value of the Ticket(s) purchased (including all ticket prices paid, fees, taxes, additional services purchased such as parking, etc.), or an amount equal to the full value of the Ticket(s) purchased in cash (including all ticket prices paid, fees, taxes, additional services purchased such as parking, etc.) provided that you return your digital Ticket(s) to StubHub (physical event ticket need not be returned). Should the Settlement be approved by the Superior Court of Quebec, you will receive a Notice of Approval of the Transaction inviting you to submit your claim by responding electronically to said Notice within the allotted claim deadline. The Notice of Approval of the Transaction will set out the three (3) options available to you, namely (i) to retain your Ticket(s), (ii) to receive a credit or (iii) to receive a cash refund. If you do not submit your claim in a timely manner, you will be deemed to have elected to hold onto your Ticket(s) and you will no longer be eligible to receive benefits pursuant to this Settlement, but you will be bound by the remaining terms thereof. OPTING OUT If you do not wish to be bound by this Class Action (and this proposed Settlement) for any reason whatsoever, you must take steps to exclude yourself from the Settlement Class, which will result in your exclusion from the Class Action (and the proposed Settlement). If you exclude yourself from the Class Action: 1. You will not receive any benefits under the proposed Settlement (if approved by the Court); 2. You will not be bound by the Class Action; 3. You could exercise your valid rights of action independently against StubHub, at your own costs and with your own legal advisers (strict legal delays apply); and 4. You will not be able to object to this proposed If you do not exclude yourself from the Class Action: 1. You will be eligible to receive reparations under this proposed Settlement (if approved by the Court); 2. You will be bound by the Class Action; 3. You will give up the right to take your own legal action against the StubHub; and 4. You will be able to object to the proposed If you do not exclude yourself from the Class Action and the proposed Settlement is approved, you give up the right to take legal action against StubHub with respect to the purchase of Tickets from StubHub before March 11, 2020 to events scheduled to take place after March 11, 2020, which events were subsequently either cancelled, postponed or rescheduled. To exclude yourself from the Class Action (opt out), you must send to the clerk of the Superior Court of Quebec, a duly signed request for exclusion containing the following information: 1. The Court docket number of the Class Action: Patterson v. Ticketmaster et al. S.M. 500-06-001066-204; 2. Your name and contact information; 3. An affirmation that you used the StubHub services to purchase your ticket; 4. Your email address associated with your StubHub account. The request for exclusion must be sent by registered or certified mail before July 2, 2022 to the Court, at the following addresses: Greffe de la Cour supérieure du Québec Palais de justice de Montréal 1 Notre-Dame Street East Room 1.120 Montreal, Quebec  H2Y 1B5 Reference: Patterson v. Ticketmaster et al. – Class Action C.S.M.: 500-06-001066-204   With a copy to Class Counsel: Lex Group Inc. Mtre David Assor 4101 Sherbrooke St. W., Westmount, Quebec, H3Z 1A7 OBJECTION TO THE SETTLEMENT You can tell the Court that you do not agree with this proposed Settlement. To present your objection to the Court, you are required to inform Class Counsel in writing of the reasons for the Objection at least five (5) Days before the Approval Hearing, by communicating a document containing the following information:

• The Court and Court docket number of the Class Action: Patterson v. Ticketmaster et al. S.M. 500-06-001066-204;
• The name and contact information of the Settlement Class Member who is raising an Objection. If the objecting Settlement Class Member is represented by a lawyer, his or her contact information must be provided;
• An affirmation that the Settlement Class Member used the StubHub Services to purchase his or her Ticket;
• The Settlement Class Member’s email address that is associated with his or her Account;
• A declaration that the Settlement Class Member purchased the Ticket while being physically located in Quebec;
• A brief description of the reasons for the Settlement Class Member’s Objection; and

You cannot object to the proposed Settlement if you opt out of the Class Action. You can object to the Settlement without a lawyer. If you wish to be represented by a lawyer, you may hire one at your own expense. If, despite your objection, the Settlement is still approved by the Court and if you are eligible, you can still receive a credit or a cash refund or choose to retain your Ticket(s).   FOR MORE INFORMATION For more information and access to the text of the Settlement, the schedules, judgments, and the various forms, please consult the present webpage or go to the Settlement Website: www.stubhubsettlement.ca. You may also contact our firm. Please do not contact the Judges of the Superior Court of Quebec. If approved, another notice (email) will be published in accordance with the proposed Settlement and as eventually ordered by the Court. In case of discrepancies between this notice and the Settlement Agreement, the Settlement Agreement shall prevail.

PROPOSED QUEBEC CLASS ACTION SETTLEMENT

SEATGEEK TICKET PURCHASES MADE IN QUEBEC BEFORE MARCH 11, 2020 

FOR EVENTS WHICH WERE POSTPONED OR RESCHEDULED AFTER MARCH 11, 2020

CLASS ACTION AUTHORIZED AND UPCOMING PROPOSED SETTLEMENT APPROVAL HEARING

  A proposed settlement (“Settlement”) has been reached, subject to Court approval, between Mr. Patterson (the “Plaintiff”) and SEATGEEK, INC. (“SeatGeek“) in the context of a class action instituted against several ticketing platforms including SeatGeek with respect to the purchase, prior to March 11, 2020, of tickets for events scheduled to take place after March 11, 2020, which events were subsequently either postponed or rescheduled, without a full refund for the tickets purchased being provided (the “Class Action”). The Superior Court of Quebec authorized the Class Action, for settlement purposes, on April 13 2022 This proposed Settlement may affect your rights, whether you act or not. Please read this notice carefully. Note: This proposed Settlement is only with regards to SeatGeek clients in Quebec. BASIC INFORMATION If you are a Quebec resident and you have purchased before March 11, 2020 one or more tickets from SeatGeek for an event scheduled to take place after March 11, 2020, which event was subsequently either postponed or rescheduled, without a full refund being provided by SeatGeek, you could be eligible to receive benefits under the Settlement, if approved by the Court. The purpose of this notice is to inform you that the Plaintiff and SeatGeek have reached a proposed Settlement putting an end to the Class Action (subject to Court approval). All concerned parties believe that the proposed Settlement is the best solution to dispose fairly and equitably of the dispute; they will ask the Superior Court of Quebec to approve it. The Superior Court of Quebec will hold a hearing to determine whether it will approve the proposed Settlement. You may attend the hearing, which will take place virtually on June 17, 2022 at 9:30 a.m. in room 16.02 of the Montreal Courthouse using the following Microsoft Teams link: https://url.justice.gouv.qc.ca/oCT0. According to the Plaintiff, SeatGeek allegedly engaged in illegal conduct by modifying its “Buyer Guarantee” and Terms of Use and by failing to fully reimburse Quebec residents for all amounts paid before March 11, 2020 for event tickets, which events were subsequently either postponed or rescheduled after March 11, 2020. These allegations have not been proven in Court and are contested by SeatGeek, whose position is that they have complied at all times with all applicable legislation, including with respect to the modifications to its “Buyer Guarantee” and Terms of Use. You are a Group Member if you meet all of the following conditions:

1. You are a user of the SeatGeek Services that had a Quebec billing address associated with your Account at the time of purchase of the Ticket(s);
2. you have purchased before March 11, 2020 at least one ticket from SeatGeek to at least one event scheduled to take place after March 11, 2020, which event was subsequently either postponed or rescheduled (“Ticket(s)”);
3. you have not already used the Ticket(s) to attend the event(s) to which the Ticket(s) grant access; and
4. you have not already been granted a refund or a credit for such Ticket(s).

SETTLEMENT SUMMARY Without any admission of liability, for the purpose of avoiding a trial and the additional costs and expenses related thereto, SeatGeek agrees to the following:

1. Each Eligible Member shall be entitled to, alternatively, (i) retain his or her Ticket(s); or (ii) cancel the contract by which he or she purchased his or her Ticket(s) and receive a benefit in the form of a credit in an amount equal to one hundred and ten percent (110%) of the value of the Ticket(s)purchased (including all ticket prices paid, fees, taxes, additional services purchased such as parking, etc.); or (iii) cancel the contract by which he or she purchased his or her Ticket(s) and obtain the restitution of an amount equal to the value of the Ticket(s) purchased in cash (including all ticket prices paid, fees, taxes, additional services purchased such as parking, ), at the Eligible Member’s option;
2. Implement a business practice change regarding tickets to events that have been postponed or rescheduled, providing for a refund upon a request being made by a Quebec

If you meet the four conditions described above to be a Group Member, if you have not already used your Ticket(s) to attend the events to which the Tickets grant access and if you do not wish to retain your Ticket(s), you could be eligible to receive a benefit in the form of a credit in an amount equal to one hundred and ten percent (110%) of the value of the Ticket(s) purchased (including all ticket prices paid, fees, taxes, additional services purchased such as parking, etc), or an amount equal to the full value of the Ticket(s) purchased in cash (including all ticket prices paid, fees, taxes, additional services purchased such as parking, etc.) provided that you return your digital Ticket(s) to SeatGeek (physical event ticket need not be returned). Should the Settlement be approved by the Superior Court of Quebec, you will receive a Notice of Approval of the Transaction inviting you to submit your claim by responding electronically to said Notice within the allotted claim deadline. The Notice of Approval of the Transaction will set out the three (3) options available to you, namely (i) to retain your Ticket(s), (ii) to receive a credit or (iii) to receive a cash refund. If you do not submit your claim in a timely manner, you will be deemed to have elected to hold onto your Ticket(s) and you will no longer be eligible to receive benefits pursuant to this Settlement, but you will be bound by the remaining terms thereof. OPTING OUT If you do not wish to be bound by this Class Action (and this proposed Settlement) for any reason whatsoever, you must take steps to exclude yourself from the Settlement Class, which will result in your exclusion from the Class Action (and the proposed Settlement). If you exclude yourself from the Class Action:

1. You will not receive any benefits under the proposed Settlement (if approved by the Court);
2. You will not be bound by the Class Action;
3. You could exercise your valid rights of action independently against Seatgeek, at your own costs and with your own legal advisers (strict legal delays apply); and
4. You will not be able to object to this proposed Settlement.

If you do not exclude yourself from the Class Action:

1. You will be eligible to receive reparations under this proposed Settlement (if approved by the Court);
2. You will be bound by the Class Action;
3. You will give up the right to take your own legal action against the SeatGeek; and
4. You will be able to object to the proposed

If you do not exclude yourself from the Class Action and the proposed Settlement is approved, you give up the right to take legal action against SeatGeek with respect to the purchase of Tickets from SeatGeek before March 11, 2020 to events scheduled to take place after March 11, 2020, which events were subsequently either postponed or rescheduled. To exclude yourself from the Class Action (opt out), you must send to the clerk of the Superior Court of Quebec, a duly signed request for exclusion containing the following information:

1. The Court docket number of the Class Action: Patterson Ticketmaster et al. C.S.M. 500- 06-001066-204;
2. Your name and contact information;
3. An affirmation that you used the SeatGeek services to purchase your ticket;
4. Your email address associated with your SeatGeek

The request for exclusion must be sent by registered or certified mail before June 2, 2022, to the Court, at the following addresses: Greffe de la Cour supérieure du Québec PALAIS DE JUSTICE DE MONTRÉAL 1 Notre-Dame Street East Room 1.120 Montreal, Quebec H2Y 1B5 Reference: Patterson v. Ticketmaster et al. – Class Action C.S.M.: 500-06-001066-204   With a copy to Class Counsel: Lex Group Inc. Mtre David Assor 4101 Sherbrooke St. W. Westmount, Quebec, H3Z 1A7   OBJECTION TO THE SETTLEMENT You can tell the Court that you do not agree with this proposed Settlement. To present your objection to the Court, you are required to inform Class Counsel and Counsel for SeatGeek in writing of the reasons for the Objection by communicating, before June 2, 2022, a document containing the following information:

• The Court and Court docket number of the Class Action: Patterson Ticketmaster et al. C.S.M. 500-06-001066-204;
• The name and contact information of the Settlement Class Member who is raising an If the objecting Settlement Class Member is represented by a lawyer, his or her contact information must be provided;
• An affirmation that the Settlement Class Member used the SeatGeek Services to purchase his or her Ticket;
• The Settlement Class Member’s email address that is associated with his or her Account;
• A declaration that the Settlement Class Member purchased the Ticket while being physically located in Quebec;
• A brief description of the reasons for the Settlement Class Member’s Objection; and
• The Objection must be conveyed and received before the expiry of the Exclusion Period according to the relevant sections of the Settlement Agreement.

  You cannot object to the proposed Settlement if you opt out of the Class Action. You can object to the Settlement without a lawyer. If you wish to be represented by a lawyer, you may hire one at your own expense. If, despite your objection, the Settlement is still approved by the Court and if you are eligible, you can still receive a credit or a cash refund or choose to retain your Ticket(s).   FOR MORE INFORMATION For more information and access to the text of the Settlement, the schedules, judgments, and the various forms, please consult the present webpage or go to the Settlement Website: seatgeeksettlement.ca You may also contact our firm. Please do not contact the Judges of the Superior Court of Quebec. If approved, another notice (email) will be published in accordance with the proposed Settlement and as eventually ordered by the Court. In case of discrepancies between this notice and the Transaction Agreement, the Transaction Agreement shall prevail.  

 

Vivid Seats LLC – QUEBEC CLASS ACTION SETTLEMENT

NOTICE OF HEARING FOR SETTLEMENT APPROVAL AND OPT-OUT

QUEBEC CLASS ACTION

N° 500-06-001066-204

This notice is to all persons in Quebec, who purchased before March 11, 2020 one or more tickets from Vivid Seats LLC for an event scheduled to take place after March 11, 2020, which event was subsequently postponed or rescheduled, without a full refund being provided by Vivid Seats LLC. PLEASE READ THIS NOTICE CAREFULLY.  IT MAY AFFECT YOUR RIGHTS. THIS CLASS ACTION HAS BEEN SETTLED, SUBJECT TO COURT APPROVAL. AUTHORIZATION OF THE CLASS ACTION On July 10, 2020, a class action was commenced in Quebec against Vivid Seats LLC (“Vivid Seats”), as well as other online ticket marketplaces, alleging that they did not provide a timely refund to putative Class Members for tickets they bought before March 11, 2020 for events that were scheduled to take place after March 11, 2020, which event was subsequently postponed, rescheduled or cancelled. The Representative Plaintiff was asking the Court to determine whether Class members were entitled to full reimbursement of the purchase price of the tickets and other related services purchases, plus interest, as well as punitive damages. On 13, 2022, the Honourable Justice Pierre-C. Gagnon of the Superior Court of Québec authorized the bringing of this class action, for settlement purposes only, against the Defendant on behalf of the following amended class: All persons in Quebec, who purchased before March 11, 2020 one or more tickets from Vivid Seats LLC for an event scheduled to take place after March 11, 2020, which event was subsequently postponed or rescheduled, without a full refund being provided by Vivid Seats LLC. (the “Settlement Class” or “ Settlement Class Members”). PROPOSED SETTLEMENT OF THE CLASS ACTION The parties to this class action have reached a proposed settlement (the “Settlement Agreement”), subject to obtaining the approval of the Superior Court of Quebec. The Settlement Agreement, if approved by the Court, provides that the Defendant will offer to its Quebec customers (i) who purchased one or more tickets before March 11, 2020 for an event scheduled to take place after March 11, 2020, which event was subsequently postponed or rescheduled and has not occurred by the end of the Claims Period nd (ii) who have not received a full refund, not successfully pursued a chargeback or do not have an active chargeback in process (the “Refund Class”), the option to:

• Receive a full refund of their order, which could include event tickets or parking passes (including base price, service fees, delivery fees and taxes), less any previous refunds received, in exchange for the return of their valid ticket(s); OR
• Maintain their order (keep their ticket(s)).

The refund process will be done through a Claims Process on the website of the Claims Administrator. The refund will only be provided if the valid ticket(s) is returned to the Defendant by the end of the Claims Period, and at least 48 hours prior the event date. The refund will be credited to the method of payment used to purchase the tickets (in USD). If this method of payment has expired, you will be contacted to obtain a new method of payment to credit. This excludes the payment of Administration Fees, and also excludes the payment of Class Counsel Fees, which will be paid separately by the Defendant. Settlement Class Members will therefore not be asked to support or pay for any portion of these fees. In return for providing the reimbursements, the Defendant will receive a release from all Settlement Class Members and a declaration of settlement out of court of the Class Action. The settlement is a compromise of disputed claims and is not an admission of liability, wrongdoing or fault on the part of Defendant. If you wish to keep your event ticket(s), you have nothing to do. EVENTS SCHEDULED TO TAKE PLACE BETWEEN NOW AND APPROXIMATELY SEPTEMBER 4, 2022: Did you purchase event tickets from Vivid Seats before March 11, 2020, for an event scheduled to take place after March 11, 2020, that was subsequently postponed or rescheduled, and which event is scheduled to take place between NOW and approximately SEPTEMBER 4, 2022? If so, this section may apply to you as a member of the “Transition Refund Class”. If you wish to hold onto your ticket(s), you have nothing to do. If you wish to obtain a refund, which would involve returning your ticket(s) to Vivid Seats LLC, you may be able to receive it immediately – without awaiting a further Court Order in this case.  Certain conditions and strict deadlines apply so you must contact Vivid Seats LLC immediately as follows: Contact info Please do not contact Vivid Seats if your event is scheduled to take place after approximately SEPTEMBER 4, 2022 (after the Claims Period). Your claim for a refund will be dealt with during the claims process in this case. SETTLEMENT APPROVAL HEARING A hearing before the Superior Court of Québec will be held on June 17, 2022 at 9:30 a.m., at the Montreal courthouse located at 1, Notre-Dame East Street, Montreal, Quebec, in room 16.02, or via Microsoft TEAMS. This date may be subject to adjournment by the Court without further publication of notice to the Class Members, other than such notice which will be posted on the Settlement Website. If you wish to be included in the Class Action, you have nothing to do and nothing to pay. If you do not wish to participate in this class action: If you wish to exclude yourself from the Class Action, you will not be entitled to participate further in the Class Action, or to share in the distribution of funds received as a result of the Settlement Agreement. To exclude yourself, you must send a notice no later than June 2, 2022, by email to the Claims Administrator at the following address: [email protected].   You must also send the notice by registered mail to the Court at the following address: Clerk of the Superior Court of Québec File: 500-06-001066-204 Montreal Courthouse 1, Notre-Dame East Street, Suite 1.120, Montréal (Québec), H2Y 1B6   You must state that you wish to exclude yourself from the class action Patterson v. Vivid Seats LLC (case number 500-06-001066-204).   If you wish to object to the terms of the proposed Settlement Agreement: If you disagree with the Settlement Agreement, but you do not wish to opt out of the class action, you can object to the Settlement Agreement by delivering a written submission on or before June 2, 2022, filed with the Court or Class Counsel in accordance with the proposed Settlement Agreement and containing the following information:

• A heading referring to this proceeding (Patterson v. Vivid Seats LLC, case no. 500-06-001066-204).
• Your name, current address, email address and telephone number and, if represented by counsel, the name of your counsel.
• A statement that you purchased before March 11, 2020 one or more tickets from Vivid Seats LLC for an event scheduled to take place after March 11, 2020, which event was subsequently postponed or rescheduled, without a full refund being provided by Vivid Seats LLC.
• A statement whether you intend to appear at the settlement approval hearing, either in person or through counsel.
• A statement of the objection and the grounds supporting the objection.
• Copies of any papers, briefs, or other documents upon which the objection is based.
• Your signature.

  You must send your objection to Class Counsel, to their address detailed below. Please note that the Court cannot change the terms of the Settlement Agreement. Any objections will be used by the Court to consider whether to approve the Settlement Agreement or not. Class Members who do not oppose the proposed Settlement Agreement do not need to appear at any hearing or take any other action to indicate their desire to support the proposed Settlement Agreement (and they will not be charged any fees). If the Settlement Agreement is approved, another notice to Class Members will be sent advising you of this and explaining the process for obtaining a refund. As a Settlement Class Member, you also have the right to intervene to support the plaintiff in the present Class Action, in the manner provided for by law.  You have no obligation to intervene in the file. No Settlement Class Member (other than the representative plaintiff or an intervenor) may be required to pay legal costs arising from the class action. MORE INFORMATION For further information or details about the proposed Settlement Agreement, you may contact our office. Please do not contact Vivid Seats, or the judges of the Superior Court.  Class Counsel: Mtre David Assor Lex Group Inc. 4101 Sherbrooke Street West Westmount, QC, H3Z 1A7 Fax:              514-940-1605 Email:           [email protected] Website : www.lexgroup.ca   You may also contact the Claims Administrator at: [email protected]  

seats.com and tickets-center.com 

QUEBEC CLASS ACTION SETTLEMENT

NOTICE OF HEARING FOR SETTLEMENT APPROVAL AND OPT-OUT

 Internet Referral Services LLC

QUEBEC CLASS ACTION

N° 500-06-001066-204

  This notice is to all persons in Quebec, who purchased before March 11, 2020, one or more ticket(s) as a result of using one of Internet Referral Services LLC’s Websites (seats.com or tickets-center.com) for an event scheduled to take place after March 11, 2020, which event was subsequently postponed or rescheduled, without a full refund being provided by Internet Referral Services LLC.   PLEASE READ THIS NOTICE CAREFULLY.  IT MAY AFFECT YOUR RIGHTS. THIS CLASS ACTION HAS BEEN SETTLED, SUBJECT TO COURT APPROVAL.   AUTHORIZATION OF THE CLASS ACTION On July 10, 2020, a class action was commenced in Quebec against Internet Referral Services LLC (“IRS”), as well as other online ticket marketplaces, alleging that they did not provide a timely refund to putative Class Members for tickets they purchased before March 11, 2020, for events that were scheduled to take place after March 11, 2020, which event was subsequently postponed, rescheduled or cancelled. The Representative Plaintiff was asking the Court to determine whether Class members were entitled to full reimbursement of the purchase price of the tickets and other related services purchases, plus interest, as well as punitive damages.   IRS operates seats.com and tickets-center.com.   On April 13, 2022, the Honourable Justice Pierre-C. Gagnon of the Superior Court of Québec authorized the bringing of this class action, for settlement purposes only, against the Defendant on behalf of the following amended class: All persons in Quebec, who purchased before March 11, 2020 one or more ticket(s) as a result of using Internet Referral Services LLC Websites for an event scheduled to take place after March 11, 2020, which event was subsequently postponed or rescheduled, without a full refund being provided by Internet Referral Services LLC. (the “Settlement Class” or “Settlement Class Members”).   PROPOSED SETTLEMENT OF THE CLASS ACTION The parties to this class action have reached a proposed settlement (the “Settlement Agreement”), subject to obtaining the approval of the Superior Court of Quebec. The Settlement Agreement, if approved by the Court, provides that the Defendant will offer to its Quebec customers (i) who purchased one or more ticket(s) before March 11, 2020 for an event scheduled to take place after March 11, 2020, which event was subsequently postponed or rescheduled and has not occurred by the end of the Claims Period and (ii) who have not received a full refund, not successfully pursued a chargeback or do not have an active chargeback in process (the “Refund Class”), the option to:

• Receive a full refund of their Order, which could include event tickets including any add-on items purchased such as parking passes (including base price, service fees, delivery fees and taxes), less any previous refunds received, in exchange for the return of their valid ticket(s); OR
• Maintain their order (keep their ticket(s)).

The refund process will be done through a Claims Process on the website of the Claims Administrator. The refund will only be provided if the valid ticket(s) is returned to the Defendant by the end of the Claims Period, and at least 48 hours prior the event date. The refund will be credited to the method of payment used to purchase the tickets (in USD). If this method of payment has expired, you will be contacted to obtain a new method of payment to credit. No cheque will be issued. The Administration Fees and the Class Counsel Fees will be paid separately by the Defendant. Settlement Class Members will therefore not be asked to support or pay for any portion of these fees. In return for providing the reimbursements, the Defendant will receive a release from all Settlement Class Members and a declaration of settlement out of Court of the Class Action. The settlement is a compromise of disputed claims and is not an admission of liability, wrongdoing or fault on the part of the Defendant. If you wish to keep your event ticket(s), you have nothing to do. EVENTS SCHEDULED TO TAKE PLACE BETWEEN NOW AND APPROXIMATELY DATE: Did you purchase event tickets from IRS before March 11, 2020, for an event scheduled to take place after March 11, 2020, that was subsequently postponed or rescheduled, and which event is scheduled to take place between NOW and approximately DATE? If so, this section may apply to you as a “Transition Settlement Class Member”. If you wish to hold onto your ticket(s), you have nothing to do. If you wish to obtain a refund, which would involve returning your ticket(s) to IRS, you may be able to receive it immediately – without awaiting a further Court Order in this case. Certain conditions and strict deadlines apply so you must contact IRS immediately as follows: Contact info Please do not contact IRS if your event is scheduled to take place after approximately DATE (after the Claims Period). Your claim for a refund will be dealt with during the claims process in this case. SETTLEMENT APPROVAL HEARING A hearing before the Superior Court of Québec will be held on June 17, 2022, at 9:30 a.m., at the Montreal courthouse located at 1, Notre-Dame East Street, Montreal, Quebec, in room 16.02, or via Microsoft TEAMS. This date may be subject to adjournment by the Court without further publication of notice to the Class Members, other than such notice which will be posted on the Settlement Website.   If you wish to be included in the Class Action, you have nothing to do and nothing to pay.   If you do not wish to participate in this class action:   If you wish to exclude yourself from the Class Action, you will not be entitled to participate further in the Class Action, or to share in the distribution of funds received as a result of the Settlement Agreement. To exclude yourself, you must send a notice no later than June 2, 2022, by email to the Claims Administrator at the following address: [email protected] or [email protected]   You must also send the notice by registered mail to the Court at the following address: Clerk of the Superior Court of Québec File: 500-06-001066-204 Montreal Courthouse 1, Notre-Dame East Street, Suite 1.120, Montréal (Québec), H2Y 1B6   You must state that you wish to exclude yourself from the class action Patterson v. Internet Referral Services LLC et als. (case number 500-06-001066-204).   If you wish to object to the terms of the proposed Settlement Agreement:   If you disagree with the Settlement Agreement, but you do not wish to opt out of the class action, you can object to the Settlement Agreement by delivering a written submission on or before June 2, 2022, filed with the Court or Class Counsel in accordance with the proposed Settlement Agreement and containing the following information:

• A heading referring to this proceeding (Patterson v. Internet Referral Services LLC et als., case no. 500-06-001066-204).
• Your name, current address, email address and telephone number and, if represented by counsel, the name, address, telephone number and email address of your counsel.
• A statement that you purchased before March 11, 2020, one or more tickets from Internet Referral Services LLC for an event scheduled to take place after March 11, 2020, which event was subsequently postponed or rescheduled, without a full refund being provided by Internet Referral Services LLC.
• A statement whether you intend to appear at the settlement approval hearing, either in person or through counsel.
• A statement of the objection and the grounds supporting the objection.
• Copies of any papers, briefs, or other documents upon which the objection is based.
• Your signature.

  You must send your objection to Class Counsel, to their address detailed below.   Please note that the Court cannot change the terms of the Settlement Agreement. Any objections will be used by the Court to consider whether to approve the Settlement Agreement or not.   Class Members who do not oppose the proposed Settlement Agreement do not need to appear at any hearing or take any other action to indicate their desire to support the proposed Settlement Agreement (and they will not be charged any fees).   If the Settlement Agreement is approved, another notice to Class Members will be sent advising you of this and explaining the process for obtaining a refund.   As a Settlement Class Member, you also have the right to intervene to support the plaintiff in the present Class Action, in the manner provided for by law.  You have no obligation to intervene in the file.   No Settlement Class Member (other than the representative plaintiff or an intervenor) may be required to pay legal costs arising from the class action.   MORE INFORMATION   For further information or details about the proposed Settlement Agreement, you may contact our firm. Please do not contact Internet Referral Services LLC, or the Judges of the Superior Court.   Class Counsel: Mtre David Assor Lex Group Inc. 4101 Sherbrooke Street West Westmount, QC, H3Z 1A7 Fax:              514-940-1605 Email:           [email protected] Website : www.lexgroup.ca   You may also contact the Claims Administrator on the Settlement Website or by email at: [email protected] or [email protected]

On August 1, 2022, the Superior Court of Quebec authorized a Quebec Data Breach Class Action against Audi Canada Inc. (hereinafter “Audi”) regarding the Data Breach which involved the theft of personal information belonging to Audi’s current customers, potential customers and/or past customers.  The authorization judgment is available on this page. _________________________________________________________________________   Lex Group Inc. has launched a national class action against Audi Canada Inc. (hereinafter “Audi”) and Volkswagen Group Canada Inc. (hereinafter “Volkswagen”), regarding the Data Breach which involved the theft of personal information belonging to an estimated 3.3 million current customers, potential customers and/or past customers in North America. It is alleged that Audi and Volkswagen exposed personal data obtained between 2014 and 2019 during a period lasting approximately 2 years, namely from August 2019 to May 2021. It was not until March 10, 2021, that Audi and Volkswagen apparently learned of the Data Breach. Affected people residing in Canada could be receiving an email or a letter from Audi and/or Volkswagen. If you receive such correspondence, please retain it. The stolen personal information of the affected clients includes, without limitation:

• First and last name;
• Personal and/or professional mailing address;
• Email address;
• Phone number;
• Driver’s license number;
• Date of birth;
• Social security or social insurance number;
• Credit information;
• Account or loan numbers;
• Tax identification numbers; and
• Information about a vehicle purchased, leased or inquired about (such as the Vehicle Identification Number (VIN), make, model, year, color, and trim packages).

Accordingly, if you have received an email or a letter from Audi and/or Volkswagen or if you have provided your personal and/or personal information to Audi and/or Volkswagen between 2014 and 2019, your information may have been stolen or compromised and you may be part of the proposed Class defined by the class action initiated by our office. Should you be defined as a member of the class in this class action, you may be entitled to compensation should the Court authorize and grant the class action on the merits, or should a settlement be reached and approved by the Court. If you wish to be kept informed and/or receive notification of major judgments rendered or notices in this case, please complete the form below.  Please note that providing your information in the form below creates no financial obligation for you and it does not create a lawyer/client relationship between yourself and Lex Group Inc. (or any of its attorneys).  You will not be charged any fees or costs for signing up to this class action since our firm is only paid on a contingency basis from the potential compensation recovered in this file, if the class action is successful by way of final judgment or settlement approved by the Court. Please be advised that the group definition of the people to be included in this class action may be changed or modified in the future by Court decision or by way of amendment filed by our firm.  We will not inform you or other members of the public if and when the group definition is changed.  It is therefore your sole responsibility to ensure that your own personal rights and recourses are being protected at all times during the course of these proceedings.  You may therefore wish to seek independent legal counsel in order to determine whether it would be in your best interest to pursue independent litigation in this matter (or any other matter), and to determine if you can potentially be included in this case if a final judgment is rendered or if a settlement is reached and approved by the Court. By signing up to this class action, you are merely asking our firm to include you in our list of potential members in this class action, but our firm is not agreeing to represent your personal interests.  If a final judgment is rendered in this case, or if a settlement is reached (and approved by the Court), an e-mail may be sent to you and the relevant information may be posted on this website.  The Court will determine the manner and extent of any future notifications to class members. Be advised that the information you provide will be included in our list of potential class members for this case, which list may be shared with and disclosed to the Courts and/or other parties in this action (at our discretion).  Rest assured that any such disclosure will be done in such a manner as to protect your personal information and confidentiality from unauthorized use, disclosure or publication. Finally, be advised that the above-description and summary of the case is being posted on this website for your convenience.  However, in case of conflict between the information on this website and the actual proceedings, documents, and/or judgments in the Court record of this case, the official Court record documents will prevail.  We have for your convenience posted on this webpage certain scanned copies of the several relevant documents from the Court record, including the initial application for authorization to institute a class action which describes the case in much more detail.  You should therefore consult these documents as well as consult this website periodically in order to be kept informed.

Lex Group Inc. is investigating a possible class action against FCA Canada inc. and FCA US LLC, on behalf of all persons residing in Quebec who own, owned, lease and/or leased an FCA vehicle equipped with a 2.4L 14 Multiair Engine, a 2.4L I4 PZEV Multiair Engine, a 2.4L I4 PZEV Multiair Engine w/ESS, or a 2.4L Multiair Engine w/ESS (also known as the “2.4L engine”, the “2.4L Turbo engine” or the “2.4L Tigershark engine”).   The Affected Vehicles are the following:

Model Year(s)	Affected Vehicles
2015-2017	Chrysler 200
2013-2016	Dodge Dart
2014-2020	Jeep Cherokee
2015-2020	Jeep Renegade
2015-2020	RAM ProMaster City
2017-2020	Jeep Compass
2016-2020	Fiat 500X

  It is believed that the Affected Vehicles suffer from a defect that causes them to burn off and/or consume abnormally high amounts of oil, leading to vehicle stalling or shutting down while in use without any warning and/or alert because of the dangerously low oil level in the vehicle. Accordingly, if you reside in Quebec and you owned, own, leased and/or lease one or more of the FCA vehicle models enumerated above, please fill out the form below and one of our lawyers may contact you for more information. Please note that providing your information in the form below created no financial obligation for you and does not create a lawyer/client relationship between yourself and Lex Group Inc. (or any of its attorneys).

Lex Group Inc. has launched a class action against the Coopérative de services enfancefamille.org, who also operates under the names La Place 0-5 and The Place 0-5, and against the Government of Quebec (the Procureur général du Québec – Ministère de la famille), regarding the May 8, 2021 Data Breach which involved the theft of personal information belonging to an estimated 86,948 La Place 0-5 users.  Certain affected persons may have received an email from The Place 0-5 on May 13, 2021. The Place 0-5 is the organization mandated by the Government of Quebec to manage the only public gateway service to recognized Quebec daycares. The stolen personal information includes, without limitation, The Place 0-5 user name, the child’s name, the email address, the postal address, the telephone number, the date of birth, the NIREC (the registration number on the birth certificate and with the Directeur de l’état civil) and the registration number. The stolen information concerned the parents of the registered children and possibly the personal information of the children themselves, such as their date of birth and their NIREC. Accordingly, if you received an email from La Place 0-5 on May 13, 2021 or if you provided your personal information to The Place 0-5, your personal information may have been stolen or compromised in the May 8, 2021 Data Breach and you may be part of the proposed Class defined by the class action initiated by our office. Should you be defined as a member of the class in this class action, you may be entitled to compensation should the Court authorize and grant the class action on the merits, or should a settlement be reached (and approved by the Court). If you wish to be kept informed and/or receive notification of major judgments rendered or notices in this case, please complete the form below.  Please note that providing your information in the form below creates no financial obligation for you and it does not create a lawyer/client relationship between yourself and Lex Group Inc. (or any of its attorneys).  You will not be charged any fees or costs for signing up to this class action since our firm is only paid on a contingency basis from the potential compensation recovered in this file, if the class action is successful by way of final judgment or settlement approved by the Court. Please be advised that the group definition of the people to be included in this class action may be changed or modified in the future by Court decision or by way of amendment filed by our firm.  We will not inform you or other members of the public if and when the group definition is changed.  It is therefore your sole responsibility to ensure that your own personal rights and recourses are being protected at all times during the course of these proceedings.  You may therefore wish to seek independent legal counsel in order to determine whether it would be in your best interest to pursue independent litigation in this matter (or any other matter), and to determine if you can potentially be included in this case if a final judgment is rendered or if a settlement is reached and approved by the Court. By signing up to this class action, you are merely asking our firm to include you in our list of potential members in this class action, but our firm is not agreeing to represent your personal interests.  If a final judgment is rendered in this case, or if a settlement is reached (and approved by the Court), an e-mail may be sent to you and the relevant information may be posted on this website.  The Court will determine the manner and extent of any future notifications to class members. Be advised that the information you provide will be included in our list of potential class members for this case, which list may be shared with and disclosed to the Courts and/or other parties in this action (at our discretion).  Rest assured that any such disclosure will be done in such a manner as to protect your personal information and confidentiality from unauthorized use, disclosure or publication. Finally, be advised that the above-description and summary of the case is being posted on this website for your convenience.  However, in case of conflict between the information on this website and the actual proceedings, documents, and/or judgments in the Court record of this case, the official Court record documents will prevail.  We have for your convenience posted on this webpage certain scanned copies of the several relevant documents from the Court record, including the initial application for authorization to institute a class action which describes the case in much more detail.  You should therefore consult these documents as well as consult this website periodically in order to be kept informed.