Robbins Geller Rudman & Dowd LLP Announces Proposed Settlement in the Nissan Securities Litigation

By: Robbins Geller Rudman & Dowd LLP via Business Wire

June 24, 2022 at 08:00 AM EDT

The following statement is being issued by Robbins Geller Rudman & Dowd LLP regarding the Nissan Securities Litigation:

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF TENNESSEE

NASHVILLE DIVISION

JACKSON COUNTY EMPLOYEES’

RETIREMENT SYSTEM, Individually and

on Behalf of All Others Similarly Situated,

Plaintiffs,

vs.

CARLOS GHOSN, et al.,

Defendants.

)

Civil Action No. 3:18-cv-01368

CLASS ACTION

Hon. William L. Campbell Jr.

Magistrate Judge Alistair Newbern

SUMMARY NOTICE OF PROPOSED

SETTLEMENT OF CLASS ACTION

TO: ALL PERSONS WHO, BETWEEN MAY 11, 2014 AND NOVEMBER 16, 2018, INCLUSIVE, PURCHASED OR OTHERWISE ACQUIRED NISSAN MOTOR CO., LTD. (“NISSAN” OR THE “COMPANY”) AMERICAN DEPOSITARY RECEIPTS (“ADRS”) ON THE OVER-THE-COUNTER MARKET (“OTC MARKET”) AND ALL CITIZENS AND RESIDENTS OF THE UNITED STATES WHO, BETWEEN MAY 11, 2014 AND NOVEMBER 16, 2018, INCLUSIVE, PURCHASED OR OTHERWISE ACQUIRED NISSAN COMMON STOCK (“CLASS” OR “CLASS MEMBERS”)

THIS NOTICE WAS AUTHORIZED BY THE COURT. IT IS NOT A LAWYER SOLICITATION. PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY.

YOU ARE HEREBY NOTIFIED that a hearing will be held on September 19, 2022, at 2:30 p.m., before the Honorable William J. Campbell Jr. at the United States District Court, Middle District of Tennessee, Fred D. Thompson United States Courthouse, 719 Church Street, Nashville, TN 37203 to determine whether: (1) the proposed settlement (the “Settlement”) of the above-captioned Litigation as set forth in the Stipulation of Settlement (“Stipulation”)¹ for $36,000,000 in cash should be approved by the Court as fair, reasonable and adequate; (2) the Judgment as provided under the Stipulation should be entered dismissing the Litigation with prejudice; (3) to award Lead Counsel attorneys’ fees and expenses out of the Settlement Fund (as defined in the Notice of Proposed Settlement of Class Action (“Notice”), which is discussed below) and, if so, in what amount; (4) to pay Plaintiffs for their costs and expenses in representing the Class out of the Settlement Fund and, if so, in what amount; and (5) the Plan of Allocation should be approved by the Court as fair, reasonable and adequate.

IF YOU PURCHASED OR OTHERWISE ACQUIRED NISSAN ADRs ON THE OTC MARKET OR ARE A UNITED STATES CITIZEN WHO PURCHASED OR OTHERWISE ACQUIRED NISSAN COMMON STOCK BETWEEN MAY 11, 2014 AND NOVEMBER 16, 2018, INCLUSIVE, YOUR RIGHTS ARE AFFECTED BY THE SETTLEMENT OF THIS LITIGATION.

To share in the distribution of the Settlement Fund, you must establish your rights by submitting a Proof of Claim and Release form (“Proof of Claim”) by mail (postmarked no later than September 14, 2022) or electronically (no later than September 14, 2022). Your failure to submit your Proof of Claim by September 14, 2022, will subject your claim to rejection and preclude your receiving any of the recovery in connection with the Settlement of this Litigation. If you purchased or acquired Nissan ADRs on the OTC Market or Nissan common stock between May 11, 2014 and November 16, 2018, inclusive, and do not request exclusion from the Class, you will be bound in the United States by the Settlement and any judgment and release entered in the Litigation, including, but not limited to, the Judgment, whether or not you submit a Proof of Claim.

If you have not received a copy of the Notice, which more completely describes the Settlement and your rights thereunder (including your right to object to the Settlement or seek exclusion from the Class), and a Proof of Claim, you may obtain these documents, as well as a copy of the Stipulation (which, among other things, contains definitions for the defined terms used in this Summary Notice) and other settlement documents, online at www.NissanSecuritiesLitigation.com, or by writing to:

Nissan Securities Litigation

Claims Administrator

c/o Gilardi & Co. LLC

P.O. Box 43304

Providence, RI 02940-3304

Inquiries should NOT be directed to Defendants, the Court, or the Clerk of the Court.

Inquiries, other than requests for the Notice or for a Proof of Claim, may be made to Lead Counsel:

ROBBINS GELLER RUDMAN & DOWD LLP

Ellen Gusikoff Stewart

655 West Broadway, Suite 1900

San Diego, CA 92101

Telephone: 1-800-449-4900

settlementinfo@rgrdlaw.com

IF YOU DESIRE TO BE EXCLUDED FROM THE CLASS, YOU MUST SUBMIT A REQUEST FOR EXCLUSION SUCH THAT IT IS RECEIVED BY AUGUST 29, 2022, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE. ALL CLASS MEMBERS WILL BE BOUND BY THE SETTLEMENT EVEN IF THEY DO NOT SUBMIT A TIMELY PROOF OF CLAIM.

IF YOU ARE A CLASS MEMBER, YOU HAVE THE RIGHT TO OBJECT TO THE SETTLEMENT, THE PLAN OF ALLOCATION, THE REQUEST BY LEAD COUNSEL FOR AN AWARD OF ATTORNEYS’ FEES UP TO ONE-THIRD (33-1/3%) OF THE $36,000,000 SETTLEMENT AMOUNT AND EXPENSES NOT TO EXCEED $250,000, AND/OR THE PAYMENT TO PLAINTIFFS FOR THEIR COSTS AND EXPENSES NOT TO EXCEED $25,000 IN THE AGGREGATE. ANY OBJECTIONS MUST BE FILED WITH THE COURT BY SEPTEMBER 2, 2022 AND SENT TO LEAD COUNSEL AND DEFENDANTS’ COUNSEL BY AUGUST 29, 2022, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE.

Dated: May 26, 2022

BY ORDER OF THE COURT

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF TENNESSEE

¹ The Stipulation can be viewed and/or obtained at www.NissanSecuritiesLitigation.com

View source version on businesswire.com: https://www.businesswire.com/news/home/20220624005002/en/

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Media:

Robbins Geller Rudman & Dowd LLP

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Greg Wood

(619) 231-1058

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Robbins Geller Rudman & Dowd LLP Announces Proposed Settlement in the Nissan Securities Litigation

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