In Re BlockFi, Inc. Securities Litigation

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• The Court will hold a Settlement Hearing on December 4, 2025, at 2:00 p.m. to decide whether to approve the Settlement. If approved by the Court, the Settlement will provide $13,250,000 gross (the “Settlement Amount”), plus interest as it accrues, minus attorneys’ fees, costs, compensatory awards to Plaintiffs and administrative expenses, net of any taxes on interest (the “Net Settlement Amount”), to pay claims of investors who invested, deposited, or otherwise acquired assets in BlockFi Interest-Bearing Accounts during the Settlement Class Period.
   

• Holders of BlockFi Interest-Bearing Accounts are eligible to receive a pro rata distribution from the Net Settlement Fund based on the value of their BlockFi Interest-Bearing Accounts as of November 28, 2022, or the day BlockFi filed for bankruptcy, as determined by their allowed claim associated with such account in the BlockFi Chapter 11 proceedings. The amount of payment each Settlement Class Member receives depends on the aggregate values of BlockFi Interest-Bearing Accounts of all Settlement Class Members participating in the Settlement. Distributions to Settlement Class Members will be made based on the Plan of Allocation set forth in the Notice or such other plan of allocation as may be ordered by the Court.
   

• To claim your share of the Settlement, you do not need to take any action. However, if you opted out of certain releases in BlockFi’s bankruptcy, you may exclude yourself or “opt out” of the Settlement by November 20, 2025. If you did not exclude yourself from or opt out of certain releases in BlockFi’s bankruptcy, and you are a Settlement Class Member, you may also exclude yourself or ‘opt out’ of the Settlement, provided however that opting out or excluding yourself from the Settlement does not affect your release in the bankruptcy. In other words, if you failed to opt out of the release in the bankruptcy, opting out of the settlement will mean that you will not receive payment as part of the settlement and will not have any claim against BlockFi or the defendants.
   

• Attorneys for Plaintiffs (“Lead Counsel”) intend to ask the Court to award them fees and expenses not to exceed $2.7 million, or 20.4% percent of the Settlement Amount, inclusive of litigation expenses and compensatory awards to Plaintiffs, plus interest. Since the Litigation’s inception, Lead Counsel have expended considerable time and effort in this litigation on a contingent-fee basis and have advanced the expenses of the litigation in the expectation that if they were successful in obtaining a recovery for the Settlement Class, they would be paid from such recovery. If approved by the Court, these amounts will be paid from the Settlement Fund.
   

• The Settlement resolves the Litigation concerning Plaintiffs’ allegations that Zachary Prince, Flori Marquez, Tony Lauro, Jennifer Hill, Amit Cheela, David Olsson, and Samia Bayou (collectively, “Defendants”) violated federal securities laws by allegedly issuing BlockFi Interest Accounts (“BIAs”) without registering them as securities; and/or making misrepresentations and/or omissions of material fact in public statements to the investing public concerning, inter alia: (1) the equivalence of BIAs to federally insured bank accounts; (2) whether cryptocurrency in “BlockFi Wallets” would transfer to BlockFi; (3) that BlockFi would not “concentrate” investments; (4) that loans or pledges of crypto assets were to safe institutional counterparties; and (5) the importance of risk management to BlockFi. Defendants have denied and continue to deny each, any, and all allegations of wrongdoing, fault, liability, or damage whatsoever asserted by Plaintiffs. Defendants have also denied, inter alia, the allegations that Plaintiffs or the Settlement Class have suffered damages or that Plaintiffs or the Settlement Class were harmed by the conduct alleged in the Litigation. Defendants continue to believe the claims asserted against them in the Litigation are without merit.
   

• The parties disagree on how much money, if any, could have been won if the investors won at trial in the Litigation.
   

• Your legal rights will be affected whether you act or do not act. If you do not act, you may permanently forfeit your right to pursue claims against Defendants and any other Releasees. Therefore, you should read the Notice carefully.