Zuora Securities Litigation

The Federal Action asserts claims under Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5 promulgated thereunder against Zuora, Inc., Tien Tzuo, and Tyler Sloat (collectively, “Federal Action Defendants”). The Federal Action is brought by class representative New Zealand Methodist Trust Association (“Federal Class Representative”). The action alleges that between April 12, 2018 and May 30, 2019, Federal Action Defendants issued allegedly false and misleading statements and omissions about the functionality of Zuora’s products.

The State Action asserts claims under Sections 11 and 15 of the Securities Act of 1933 against Zuora, Inc., Tien Tzuo, Tyler Sloat, Peter Fenton, Kenneth A. Goldman, Timothy Haley, Jason Pressman, Michelangelo Volpi, Magdalena Yesil, Goldman Sachs & Co. LLC, Morgan Stanley & Co. LLC, Allen & Company LLC, Jefferies LLC, Canaccord Genuity LLC, and Needham & Company, LLC (collectively, “State Action Defendants”) (the Federal Action Defendants and the State Action Defendants are collectively referred to as “Defendants”). The State Action is brought by class representative Aric Olsen (“State Class Representative”). The action alleges that the registration statement and prospectus issued in connection with Zuora’s April 12, 2018 initial public offering allegedly contained false and misleading statements and omissions about the functionality of Zuora’s products.

By order dated March 15, 2021, the court presiding over the Federal Action certified the action as a class action on behalf of the following class: “All persons or entities who purchased or otherwise acquired publicly-traded common stock of defendant Zuora, Inc. during the period from April 12, 2018 to May 30, 2019 and who were damaged” (“Federal Class”).

Separately, the state court also certified the State Action as a class action. You are a member of the State Class if you purchased or otherwise acquired shares of Zuora common stock pursuant or traceable to the Registration Statement and Prospectus issued in connection with Zuora’s April 12, 2018 initial public offering (“State Class”)

You may be included in the classes if you (1) purchased or otherwise acquired publicly-traded common stock of Zuora, Inc. during the period from April 12, 2018 to May 30, 2019 and/or (2) purchased or otherwise acquired shares of Zuora, Inc. common stock pursuant or traceable to the Registration Statement and Prospectus issued in connection with Zuora’s April 12, 2018 initial public offering.

This website (and the Notice sent to potential Class Members) is only to apprise you of the pendency of the Class Actions and the fact that both actions have been certified as class actions. There have been no settlements or resolutions on the merits of Plaintiffs' claims and there is no Claim Form to submit. There has been no admission by Defendants or any expression by the Court on the validity of the claims.

No. There have been no settlements and the courts have not made any determination on the validity of the plaintiffs’ claims. As such, there is no money or other benefits available now.

There is no guarantee that money or any other benefit will ever be obtained.

If you choose to remain in the Classes and if there is any recovery, either through trial(s) or settlement(s), then you will be notified about how to ask for your share.

A class action is a type of lawsuit in which one or several individuals or entities prosecute claims on behalf of all members of a group of similarly situated persons and entities to obtain monetary or other relief for the benefit of the entire group. Class actions avoid the necessity of each class member having to file his, her, or its own separate lawsuit to obtain relief. Class actions are used to decide legal and factual issues that are common to all members of the class.

The federal court certified the Federal Action as a class action. You are a member of the Federal Class if you purchased or otherwise acquired publicly-traded common stock of Zuora during the period from April 12, 2018 to May 30, 2019 and were damaged.

Separately, the state court also certified the State Action as a class action. You are a member of the State Class if you purchased or otherwise acquired shares of Zuora common stock pursuant or traceable to the Registration Statement and Prospectus issued in connection with Zuora’s April 12, 2018 initial public offering.

You may be a member of both the Federal Class and the State Class.

As a member of a class, you have two options available to you, as explained in FAQ 7 below.

A. Do nothing and remain as a member of the Federal Class and the State Class

If you are a member of the Federal Class, the State Class, or both, you can choose to do nothing. If you do that, you will remain in the Federal Class and the State Class and will be bound by all orders and judgments in the actions, whether favorable or unfavorable. If the Classes prevail on the common issues, or if a settlement is reached later on in the actions, you may be entitled to some recovery. If Defendants prevail or if a settlement is reached, you will not be able to pursue a lawsuit on your own behalf with regard to any of the issues or claims at issue in these actions.

Your interests in the Federal Action are being represented by the Federal Class Representative and the Federal Class Counsel. Your interests in the State Action are being represented by the State Class Representative and the State Class Counsel. Both the Federal Class Counsel and the State Class Counsel are representing the Classes on a contingent fee basis, which means that they will be awarded attorneys’ fees and costs only if the Class Representatives succeed in obtaining a recovery from one or more Defendants. Any attorneys’ fees and costs will be awarded by the court(s) from the settlement or judgment, if any, obtained on behalf of the Classes. You will not be separately responsible for any such fees or costs.

You may remain a member of the Classes and elect to be represented by counsel of your own choosing. If you retain separate counsel, you will be responsible for that counsel’s fees and expenses, and such counsel must enter an appearance on your behalf.

If at a later date the parties decide to settle, then you will have another opportunity to exclude yourself from the cases. Absent settlement, however, you will not be able to exclude yourself from the Classes or subsequent orders and judgments if you do nothing at this time.

B. Exclude yourself from the Federal Class, the State Class, or both

If you want to pursue your own lawsuit or claims against Defendants about the alleged conduct in these actions, do not want to be bound by what the Courts do in these actions, or if you simply do not want to be a part of the Classes pursuing claims against Defendants, you must ask to be excluded. If you choose to exclude yourself from the Federal Class, the State Class, or both, you will not be bound by any orders or judgments in that action(s), nor will you be eligible to share in any recovery that might be obtained in that action(s).

Should you choose to be excluded or, in other words, “opt out” of the Federal Action, the State Action, or both, you may be able to individually pursue claims against Defendants. However, please note that if you request exclusion from the Classes and decide to pursue your own action individually, you may not be able to pursue certain claims because of the applicable statutes of limitation or repose. You may want to consult with an attorney to determine whether any claim that you wish to pursue individually against Defendants may be time-barred.

You may request exclusion from either the Federal Class, the State Class, or both.

If you wish to be excluded from the Federal Class and the State Class, you must send a signed letter by mail stating that you “request exclusion” from the Federal Class in Roberts v. Zuora, Inc., Case No. 3:19-cv-03422-SI (N.D. Cal.), and from the State Class in Olsen v. Zuora, Inc., Lead Case No. 20-CIV-01918 (Cal. Super. Ct., Cnty. of San Mateo).

If you wish to be excluded only from the Federal Class, you must send a signed letter by mail stating that you “request exclusion” only from the Federal Class in Roberts v. Zuora, Inc., Case No. 3:19-cv-03422-SI (N.D. Cal.).

Alternatively, if you wish to be excluded only from the State Class, you must send a signed letter by mail stating that you “request exclusion” only from the State Class in Olsen v. Zuora, Inc., Lead Case No. 20-CIV-01918 (Cal. Super. Ct., Cnty. of San Mateo).

Be sure to include: (1) the name, address, and telephone number of the person or entity seeking to be excluded from the Class or Classes, (2) the amount of Zuora common stock purchased or otherwise acquired between April 12, 2018 and May 30, 2019, including the dates and prices of each purchase and acquisition, and the amount of Zuora common stock sold between April 12, 2018 and the present, including the dates and prices of each sale; and (3) the signature of the person or entity requesting exclusion or an authorized representative.

Your request for exclusion must contain all of the above information to be effective.

You must mail your exclusion request, postmarked no later than October 30, 2022, to:

Zuora, Inc. Securities Litigation
c/o Epiq
EXCLUSIONS
P.O. Box 5530
Portland, OR 97228-5530

You cannot exclude yourself by telephone or email.

If your request for exclusion is timely mailed and includes all of the required information set forth in FAQ 8 above, you will not be a member of the Class(es) and you will not be eligible to share in any later recovery, if any, in these actions. Only request exclusion if you do not wish to participate in these actions and do not wish to share in any potential recovery that the Classes may obtain.

Your interests in the Federal Action are being represented by the Federal Class Representative and the Federal Class Counsel. Their contact information is:

Federal Class Counsel
Steve Berman Hagens Berman Sobol Shapiro llp 1301 Second Avenue Suite 2000 Seattle, WA 98101  Telephone: 206-623-7292 206-623-7292  Facsimile: 206-623-0594 206-623-0594  steve@hbsslaw.com	Lucas E. Gilmore Hagens Berman Sobol Shapiro llp 715 Hearst Avenue Suite 300 Berkeley, CA 94710  Telephone: 510-725-3000 510-725-3000  Facsimile: 510-725-3001 510-725-3001  lucasg@hbsslaw.com

Your interests in the State Action are being represented by the State Class Representative and the State Class Counsel. Their contact information is:

State Class Counsel
Francis A. Bottini, Jr. Yury A. Kolesnikov Bottini & Bottini, inc. 7817 Ivanhoe Avenue Suite 102 La Jolla, CA 92037  Telephone: 858-914-2001 858-914-2001  Facsimile: 858-914-2002 858-914-2002  fbottini@bottinilaw.com  ykolesnikov@bottinilaw.com

If you want to be represented by your own attorney, you may hire one at your own expense. If you do retain your own attorney, such counsel must enter an appearance on your behalf by filing a notice of appearance in both actions by October 30, 2022. Any notice of appearance filed by your counsel must also be mailed to the Federal Class Counsel and the State Class Counsel (as the case may be) at the addresses listed above by October 30, 2022.

This Website (and the Notice) provides only a summary of the Federal Action and the State Action and the claims asserted by the Class Representatives in each action. You can obtain more detailed information, including case documents and other information from the Important Documents section of this website. You may also contact the Federal Class Counsel or the State Class Counsel at the addresses listed above in FAQ 10.