The Notice was provided pursuant to an Order of a U.S. District Court because you or someone in your family or an investment account for which you serve as custodian may have purchased Class A common stock of VMware, Inc. (n/k/a VMware LLC) (“VMware” or the “Company”) between August 24, 2018 and February 27, 2020, inclusive (the “Class Period”). The Notice explains the class action lawsuit, the Settlement, Class Members’ legal rights in connection with the Settlement, what benefits are available, who is eligible for them, and how to get them.

The Court in charge of the Litigation is the United States District Court for the Northern District of California, and the case is known as Lamartina v. VMware, Inc., et al., Case No. 5:20-cv-02182-EJD. The case has been assigned to the Honorable Judge Edward J. Davila. The entity representing the Class is the Lead Plaintiff, and the company and individuals it sued and who have now settled are called the Defendants.

A brief background of this case is provided on pages 4-5 of the Notice, and is also summarized on the case website. We do not have any more information regarding the background of this case beyond what is provided in the Notice and posted case documents.

The Court directed that everyone who fits this description is a Class Member: all persons who purchased the publicly tracked Class A common stock of VMware during the period from August 24, 2018 through February 27, 2020, inclusive, and were damaged thereby.

Excluded from the Class are Individual Defendants and their immediate family members. Also excluded from the Class are any persons or entities who exclude themselves by submitting a request for exclusion in connection with the Notice that is accepted by the Court.

Please Note: Receipt of the Notice or the Postcard Notice does not necessarily mean that you are a Class Member or that you are entitled to receive proceeds from the Settlement. If you wish to be potentially eligible to receive a distribution of the Settlement proceeds, you must complete, sign, and submit the Claim Form to be received or submitted online no later than March 17, 2025.

We are unable to advise regarding claim eligibility prior to receiving and processing a Proof of Claim submission. We cannot be more specific than the information which has been included in the Notice and cannot interpret how the Notice or Plan of Allocation may apply to a specific claim prior to processing.

Please read the Notice and Class definition carefully and decide whether or not you wish to submit a Proof of Claim. If you are still not certain of eligibility and want for us to determine eligibility, you will need to submit a Proof of Claim along with supporting documentation for your transactions.

Email is not an acceptable submission method and claims submitted via email will not be reviewed for eligibility. As indicated in the general instructions for the Proof of Claim and Release, you must submit your claim via the online form on the File Claim tab or you can mail your completed and signed Proof of Claim and Release addressed as follows:

VMware Securities Litigation
Claims Administrator
c/o Gilardi & Co. LLC
P.O. Box 301170
Los Angeles, CA 90030-1170

If submitting via the online form, there is a link on the website which allows a claimant to complete the Proof of Claim. The link is found on the “File Claim” under the header “Submit Your Proof of Claim Online.”

Note that the online link may be disabled at any time after the filing deadline and you will only be able to submit via mail to the address above.

The Settlement provides that, in exchange for the release of the Released Claims (defined in the Notice), Defendants will cause to be paid $102,500,000 in cash into an escrow account. The Net Settlement Fund (the Settlement Fund less Taxes, Tax Expenses, Notice and Administration Costs, and Court-approved attorneys’ fees and expenses) will be distributed to Class Members who send in a valid Proof of Claim form pursuant to the Court-approved Plan of Allocation. The Plan of Allocation is described in more detail at the end of the Notice.

Your share of the Net Settlement Fund will depend on several things, including the total value of VMware Class A common stock represented by the valid Proof of Claim forms that Class Members send in, compared to the value of your claim, all as calculated under the Plan of Allocation discussed in the Notice.

To be eligible to receive a payment from the Settlement, you must timely complete and submit a Proof of Claim form. A Proof of Claim may be downloaded at the Case Documents tab above. Read the instructions carefully, fill out the Proof of Claim, include all the documents the form asks for, sign it, and mail or submit it online so that it is received or submitted online no later than March 17, 2025. If you do not submit a timely Proof of Claim form with the required information, you will not receive a payment from the Net Settlement Fund; however, unless you expressly exclude yourself from the Class as described in the Notice, you will still be bound by the Settlement, the Judgment, and the releases contained therein.

The Plan of Allocation explains how the Net Settlement Fund will be allocated among purchasers of VMware Class A common stock and how claimants’ “Recognized Claim” will be calculated. By following the instructions in the Plan of Allocation, you can calculate your Recognized Claim. However, the payment you receive will reflect your Recognized Loss Amount in relation to the Recognized Loss Amount of all persons submitting valid Claim Forms. Because the total of all Recognized Loss Amounts is expected to exceed the amount of the Net Settlement Fund, your Recognized Claim is not the amount of the payment that you will receive but will (together with all other Class Members’ Recognized Loss Amounts) be used to calculate your (and other Authorized Claimants’) pro rata share of the Net Settlement Fund.

The Court ordered that the law firm of Robbins Geller Rudman & Dowd LLP represent the Class Members, including you. These lawyers are called Lead Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense.

The Settlement Hearing will be held on March 31, 2025, at 9:00 a.m., before the Honorable Edward J. Davila, at the United States District Court, Northern District of California, San Jose Courthouse, Courtroom 4—5th Floor, 280 South 1st Street, San Jose, CA 95113. The Court reserves the right to approve the Settlement or the Plan of Allocation, Lead Counsel’s motion for an award of attorneys’ fees and expenses, and/or any other matter related to the Settlement at or after the Settlement Hearing without further notice to the members of the Class.

If you do not wish to object in person to the proposed Settlement, the proposed Plan of Allocation, and/or the application for attorneys’ fees and litigation expenses, you do not need to attend the Settlement Hearing. You can object to or participate in the Settlement without attending the Settlement Hearing.

If you object to the Settlement, the Plan of Allocation, and/or the fee and expense application, you may ask the Court for permission to speak at the Settlement Hearing. To do so, you must include with your objection (see page 15 of the Notice) a statement of whether the objector intends to appear at the Settlement Hearing, and the objector’s signature, even if represented by counsel. Persons who intend to object to the Settlement, the Plan of Allocation, and/or any attorneys’ fees and expenses to be awarded to Lead Counsel or Lead Plaintiff and desire to present evidence at the Settlement Hearing must include in their written objections the identity of any witnesses they may call to testify and copies of any exhibits they intend to introduce into evidence at the Settlement Hearing. Your notice of intention to appear must be received no later than March 10, 2025, and addressed to the Office of the Clerk or by filing them in person at any location of the United States District Court for the Northern District of California

You cannot speak at the hearing if you exclude yourself from the Class.

We do not hold stock records here. Gilardi & Company, LLC is a third-party administrator appointed by the Court to notify potential claimants. We are provided with names and addresses of potential claimants in order to notify individuals of settlements but do not have access for your investment records. We recommend you contact the institution where you held your shares and request proof or supporting documentation for your claim.

One Claim Form should be submitted for each separate legal entity. Separate Claim Forms should be submitted for each separate legal entity (e.g., a claim from joint owners should not include separate transactions of just one of the joint owners, and an individual should not combine his or her IRA transactions with transactions made solely in the individual’s name). Conversely, a single Claim Form should be submitted on behalf of one legal entity that includes all transactions made by that entity, no matter how many separate accounts that entity has (e.g., a corporation with multiple brokerage accounts should include all transactions made in all accounts on one Claim Form).

When filing on behalf of a deceased beneficial owner or their estate, you can submit a claim in the name of the individual, or, if an estate exists, you can submit on behalf of the estate. Note that any settlement proceeds will be made payable to the estate if that is how you submit that claim. The same rule applies for IRA's and other account types.

The claim submission should include a copy of the death certificate as well as proof of authority to file. As you are submitting a claim form as a representative on behalf of someone else (e.g. as an executor, administrator, trustee or other representative), you must document your authority to file on their (or their estate’s) behalf. Proof of authority can include a copy of the Last Will and Testament, Letters Testamentary, evidence of probate, proof of authority as executor or beneficiary and/or any other testamentary provisions of the deceased person. Do not send originals as any documents submitted with your claim will not be returned.

Depending on whether you submit on behalf of the individual on behalf of the estate, please provide the appropriate TIN or SSN. Then sign the Claim Form.

The claim must be submitted for the benefit of the actual beneficial owner/purchaser of the shares or their estate. Do not submit the claim in the name of the deceased person’s family or other heirs. We must issue the check to the actual beneficial owner/purchaser of the shares. We cannot issue any applicable check in the name of the deceased person’s family, beneficiaries or other heirs.

Sufficient documentation will provide all of the required transaction information. Typically, the required detail is transaction date, number of shares and total transaction price. Suggested forms of documentation are photocopies of stockbrokers' confirmation slips or stockbrokers' monthly statements reflecting your opening and closing balances for the months specified on the claim form, and in which transactions during the relevant period occurred.

Stock certificates are not considered a sufficient form of documentation as they do not provide the necessary trade date and transaction price information. We are also unable to accept handwritten documents, self-prepared tax forms or spreadsheets, tax forms with an adjusted reporting basis, or statements that are illegible due to document quality.

The Claims Administrator does not have the authority to grant extensions beyond the deadline. You are welcome to submit a Proof of Claim at this time understanding that it will be considered late. If you desire, you may also include a brief letter explaining why your claim is late.

We will process all late claims received, and as much as possible, include that information with our recommendations to Counsel. We generally recommend that late claims which are otherwise valid and eligible be considered for distribution, but it will be up to the Court and/or Counsel to determine whether or not late claims will receive consideration in this matter.

Processing time on our cases can take an average of 9 to 12 months from the filing deadline. Once processing is complete, we must then wait for authorization from Counsel and/or the Court before we can distribute the funds which can take several additional months.

Please understand that this is an estimated timeframe for processing based on our experience which does not guarantee that all case processing will be completed within nine months. Processing time varies from case to case and some cases may take more or less based on the specifics of that case settlement.

If your claim has been received and we have any questions or need additional information or documentation to assist in the processing of your claim, we will contact you by using one or more of the contact methods (phone, e-mail, mail) which you listed on your claim form submission.

We will not have the final claim payout amount available until we have processed all of the claims, calculated the total loss of claims filed and received approval from the Court and/or Counsel.

We appreciate your patience as accurate claims processing takes time.

If you do nothing, you will not receive any money from this Settlement. In addition, unless you exclude yourself, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendants and the other Released Defendants Parties about the Released Claims in this case.