Sea Limited Securities Litigation Settlement
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Welcome to the Sea Limited Securities Litigation Settlement Website

This website has been established to provide general information related to the proposed settlement of the case known as Michael Plutte, Individually and on Behalf of All Others Similarly Situated vs. Sea Limited, Forrest Xiaodong Li, Gang Ye, Tony Tianyu Hou, Colleen A. De Vries, Yuxin Ren, Nicholas A. Nash, David Heng Chen Seng, Khoon Hua Kuok, Goldman Sachs (Asia) L.L.C., Morgan Stanley & Co. International PLC, Credit Suisse Securities (USA) L.L.C., CLSA Limited, Citigroup Global Markets Inc., Cowen and Company, LLC, Nomura Securities International, Inc., Piper Jaffray & Co., Stifel Nicolaus & Company, Incorporated, PT Madiri Sekuritas, Tudor, Pickering, Holt & Co. Securities, Inc., BDO Capital & Investment Corporation, Cathay Securities Corporation Offshore Securities Unit, DBS Bank Ltd., Viet Capital Securities JSC and Cogency Global Inc. (collectively, “Defendants”), Index No. 655436/2018 (the "Litigation"), pending before the Supreme Court of the State of New York, County of New York: Commercial Division (the "Court"). The capitalized terms used on this website, and not otherwise defined, shall have the same meanings ascribed to them in the Stipulation of Settlement (the "Stipulation") dated October 17, 2020, which can be found and downloaded by clicking on the Case Documents tab above. Your rights may be affected by the Settlement if you purchased or otherwise acquired Sea Limited ("Sea Ltd" or the "Company") American Depository Shares ("ADS") pursuant or traceable to the Registration Statement and Prospectus issued in connection with Sea Ltd.’s October 2017 initial public offering ("IPO" or "October 2017 IPO").

The law firm of Robbins Geller Rudman & Dowd LLP represents you and other Settlement Class Members. You will not be charged for these lawyers. They will be paid from the Settlement Fund to the extent the Court approves their application for fees and expenses. If you want to be represented by your own lawyer, you may hire one at your own expense.

WHAT IS THIS LAWSUIT ABOUT?

As more fully described in the Notice of Pendency and Proposed Settlement of Class Action (the "Notice"), the initial complaint in this action was filed on November 1, 2018. Plaintiff filed his amended complaint on January 25, 2019. On March 26, 2019, Defendants filed a joint motion to dismiss. On May 28, 2019, Plaintiff filed an opposition to the motion to dismiss. Defendants filed a reply in support of their motion to dismiss on July 12, 2019. Oral argument on the motion to dismiss was held on December 18, 2019.

Following oral argument on Defendants’ motion to dismiss, the Plaintiff and Defendants agreed to attempt to resolve the case. On May 14, 2020, counsel for Plaintiff and Defendants attended a Zoom mediation with Michelle Yoshida of Phillips ADR, a highly experienced mediator. The case did not settle following the mediation, but the Parties continued negotiations through Ms. Yoshida, and on July 15, 2020, reached an agreement in principle to settle the Action on the terms set forth herein, subject to the negotiation of a Stipulation of Settlement and approval by the Court. The Stipulation (together with the exhibits thereto) reflects the final and binding agreement between the Parties.

WHAT DOES THE SETTLEMENT PROVIDE?

The Settlement, if approved, will result in the creation of a cash settlement fund of $10,750,000.00 (the “Settlement Fund”). The Settlement Fund, plus accrued interest and minus the costs of the Notice and all costs associated with the administration of the Settlement Fund, as well as attorneys’ fees and expenses, and any award to Plaintiff for representing the Settlement Class, as approved by the Court (the “Net Settlement Fund”), will be distributed to eligible Settlement Class Members pursuant to the Plan of Allocation that is described in the Notice.

ADDITIONAL INFORMATION

Although the information in this website is intended to assist you, it does not replace the information contained in the Notice and Stipulation, both of which can be found and downloaded by clicking on the Case Documents tab above. We recommend that you read the Notice and other relevant case documents carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

SUBMIT A PROOF OF CLAIM The only way to be eligible to receive a payment from the Settlement. Proofs of Claim must be postmarked (if mailed) or received (if submitted online) on or before March 29, 2021.
EXCLUDE YOURSELF FROM THE SETTLEMENT BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION Get no payment. This is the only option that potentially allows you to ever be part of any other lawsuit against any of the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement. Should you elect to exclude yourself from the Settlement Class, you should understand that Defendants and the other Released Defendant Parties will have the right to assert any and all defenses they may have to any claims that you may seek to assert, including, without limitation, the defense that any such claims are untimely under applicable statutes of limitations and statutes of repose. Exclusions must be postmarked no later than March 11, 2021.
OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION Write to the Court about why you do not like the Settlement, the Plan of Allocation and/or the request for attorneys’ fees and expenses. You will still be a Member of the Settlement Class. Objections must be received by the Court and counsel for the Settling Parties on or before March 18, 2021.
GO TO THE HEARING ON APRIL 1, 2021, AND FILE A NOTICE TO APPEAR Ask to speak in Court about the fairness of the Settlement. Requests to speak must be received by the Court and counsel for the Settling Parties on or before March 18, 2021. If you submit a written objection, you may (but you do not have to) attend the hearing.
DO NOTHING Receive no payment. You will, however, still be a Member of the Settlement Class, which means that you give up your right to ever be part of any other lawsuit against the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement and you will be bound by any judgments or orders entered by the Court in the Litigation.

IMPORTANT DATES AND DEADLINES

Submit Proof of Claim: March 29, 2021
File Objection: March 18, 2021
Request Exclusion: March 11, 2021
File Notice of Intention to Appear: March 18, 2021
Court Hearing on Fairness of Settlement: April 1, 2021, at 11:30 a.m.