City of Sarasota Firefighters v. Inovalon Holdings Shareholder Action

In the Court of Chancery of the State of Delaware, Case No. 2022-0698-KSJM

NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF STOCKHOLDER CLASS ACTION, SETTLEMENT HEARING, AND RIGHT TO APPEAR

The Court of Chancery of the State of Delaware authorized this Settlement website. This is not a solicitation from a lawyer.

TO: All record and beneficial holders of Inovalon Holdings, Inc. (“Inovalon” or the “Company”) Class A common stock as of November 24, 2021 who received $41.00 in exchange for each share of Inovalon common stock converted in connection with the Transaction (defined below), together with their respective successors and assigns excluding (i) Defendants and Former Defendants; (ii) any parent, subsidiary, affiliate, partner, executive officer, director, or controlling person of any of the foregoing; (iii) members of the immediate families of any of the  foregoing; and (iv) any entity in which any of the foregoing has or had a controlling interest on November 24, 2021 (“Class”).

 

Contact Us

Notice of Pendency of Stockholder Class Action: Please be advised that your rights will be affected by the above-captioned stockholder class action (“Action”) pending in the Court of Chancery of the State of Delaware (“Court”) if you held Inovalon Class A common stock as of November 24, 2021 and received $41.00 in exchange for each share of Inovalon common stock converted in connection with the take-private transaction whereby shareholders of Inovalon were bought out by a consortium of private equity investors led by Nordic Capital Epsilon SCA, SICAV-RAIF (together with its affiliates, “Nordic”) (“Transaction”).
 

Notice of Settlement: Please be advised that plaintiffs City of Sarasota Firefighters’ Pension Fund, Steamfitters Local 449 Pension Fund, and Steamfitters Local 449 Retirement Security Fund (collectively, “Plaintiffs”), on behalf of themselves and the Court-certified Class; (ii) defendants Keith R. Dunleavy, Meritas Group, Inc., Meritas Holdings, LLC, Dunleavy Foundation, Mark A. Pulido, William D. Green, and William J. Teuber (collectively, “Defendants”); and (iii) the Former Defendants2 have reached a proposed settlement of the Action for $44,000,000 in cash (“Settlement”). If approved, the Settlement will resolve all claims in the Action. Neither Defendants Keith R. Dunleavy, Meritas Group, Inc., Meritas Holdings, LLC, Dunleavy Foundation, nor any other Defendant will contribute to the proposed Settlement Amount.
 

PLEASE READ THIS SETTLEMENT WEBSITE CAREFULLY AND IN ITS ENTIRETY. This Settlement website explains how members of the Class (“Class Members,” and each, a “Class Member”) will be affected by the Settlement. The following table provides a brief summary of the rights you have as a Class Member and the relevant deadlines, which are described in more detail on the FAQ page of this Settlement website.

CLASS MEMBERS’ LEGAL RIGHTS IN THE SETTLEMENT: 
RECEIVE A PAYMENT FROM THE SETTLEMENT. CLASS MEMBERS DO NOT NEED TO SUBMIT A CLAIM FORM.If you are a Class Member, you may be eligible to receive a pro rata distribution from the Settlement proceeds. Eligible Class Members (as defined in FAQ 6) do not need to submit a claim form in order to receive a distribution from the Settlement, if approved by the Court. If you are eligible for a distribution from the Settlement, it will be paid to you directly. See FAQ 6 for further discussion.
OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN NOVEMBER 10, 2026.If you are a member of the Class and would like to object to the proposed Settlement, the proposed Plan of Allocation, and/or Plaintiffs’ Counsel’s application for an award of attorneys’ fees and Litigation Expenses, including Plaintiffs’ application for Incentive Awards, you may write to the Court and explain the reasons for your objection(s).
CLASS MEMBERS’ LEGAL RIGHTS IN THE SETTLEMENT: 
ATTEND A HEARING ON DECEMBER 4, 2026, AT 11:00 A.M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN NOVEMBER 18, 2026.Filing a written objection and notice of intention to appear that is received by November 18, 2026, allows you to speak in Court, at the discretion of the Court, about your objection. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.

This website is authorized by the Court, supervised by Lead Counsel for Lead Plaintiffs and the Settlement Class, and controlled by the Settlement Administrator approved by the Court. This is the only authorized website for this case.


For more information, please use the Contact Us page, or call (833)-453-3554. You may also write to:

 

Inovalon Holdings Shareholder Action
c/o Kroll Settlement Administration
PO Box 225391
New York, NY 10150-5391

City of Sarasota Firefighters v. Inovalon Holdings Shareholder Action