FEI TRIBE SECURITIES SETTLEMENT

Superior Court of the State of California County of San Francisco
Case No. CGC-22-598995

Welcome to the Settlement Website for the FEI TRIBE Securities Settlement

IMPORTANT UPDATE: Settlement payments are scheduled to commence the week starting Monday, November 27, 2023. Please allow sufficient time for your payments to be transmitted, received, and cleared by your local financial institutions, payment apps, and/or mail delivery systems where/if applicable.

If you have not received a payment or other notification by Friday, December 1, 2023, please contact the Claims Administrator at info@FEITRIBESecuritiesSettlement.com for status information and/or questions.

The Settlement affects individuals and entities who, directly or through an intermediary, purchased the digital assets “FEI” and “TRIBE” in exchange for ETH as part of the Genesis Group between March 31, 2021 and April 3, 2021 (the “Genesis Event”), including those who “pre-swapped” their Genesis Group FEI token allocation for TRIBE tokens (see FAQ5).

The Settlement seeks to fully resolve a securities class action (the “Litigation”) pending in the Superior Court of California in the County of San Francisco (the “Court”), alleging that Defendants Fei Labs, Inc. (“Fei Labs”), Joseph Santoro, Brianna Montgomery and Sebastian Delgado (the “Individual Defendants,” and together with Fei Labs, “Defendants”) failed to comply with the registration requirements of the Securities Act of 1933 (the “Securities Act”) in conducting the sale of FEI and TRIBE tokens through the Fei Protocol during the Genesis Event. The Settlement creates a fund of $17,850,000.00 (the “Settlement Fund”) that will pay the claims (“Claims”) of individuals or entities (“Claimants”) who timely submit a valid Proof of Claim, after deduction of fees, costs, taxes, and other items as ordered by the Court.

Your legal rights will be affected whether you act or do not act. Please read the Notice of Proposed Class Action Settlement and Frequently Asked Questions (FAQs) carefully.

YOUR LEGAL RIGHTS AND OPTIONS

SUBMIT A CLAIM FOR PAYMENT

If you purchased FEI or TRIBE tokens during the Genesis Event between March 31, 2021 and April 3, 2021, then you must submit a Proof of Claim by October 1, 2023 in order to receive a payment under the Settlement. If you do not submit a valid Proof of Claim, you will not be eligible to share in the distribution of the net proceeds of the Settlement, but you will still be bound by any judgments or orders entered by the Court in the Litigation.

More information available at Submit a Proof of Claim.

October 1, 2023

EXCLUDE YOURSELF

You can request to exclude yourself from the Settlement by September 6, 2023, in accordance with the instructions set forth in this Notice. If you properly exclude yourself from the Settlement, you will not be bound by any judgments or orders entered by the Court, and you will not be eligible to share in the proceeds of the Settlement.

More information available at FAQ17.

September 6, 2023

OBJECT TO THE SETTLEMENT

You can write to the Court about why you do not like the Settlement by October 1, 2023, by following the instructions below. If you object to the Settlement, you will still be bound by any judgments or orders entered by the Court in the Litigation.

More information available at FAQ21.

October 1, 2023

GO TO A HEARING

You can ask to speak to the Court about the fairness of the Settlement. This final “Settlement Hearing,” to determine whether the Settlement should be approved, will take place on October 27, 2023 at 10:00 a.m.

More information available at FAQ23.

October 27, 2023 at 10:00 a.m.

If you fail to timely submit a Proof of Claim or fail to timely submit a request to exclude yourself from the Settlement, you will not receive any payment from the Settlement, you will be giving up your legal right to sue or continue to sue Defendants for claims related to this Litigation, and you will be bound by any judgments or orders entered by the Court in the Litigation.

The Court in charge of this case still must decide whether to approve the Settlement. Settlement benefits will be available if the Court approves the Settlement and after any potential appeals are resolved. Please be patient and check this Settlement Website for current information.

Upcoming Important Dates