Bernstein Litowitz Berger & Grossmann LLP and Glancy Prongay & Murray LLP Announce Notice of Pendency and Proposed Settlement Involving Persons and Entities who Purchased or Otherwise Acquired Common Stock or Preferred Stock of ViacomCBS Inc. Issued in March 2021 Offerings

SEATTLE, May 8, 2025 /PRNewswire/ -- JND Legal Administration

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK: COMMERCIAL DIVISION

TO: All persons and entities who purchased or otherwise acquired (i) the Class B Common Stock of ViacomCBS Inc. ("Viacom") issued in Viacom's secondary public offering, which was announced on March 22, 2021, priced on March 23, 2021, and closed on March 26, 2021; and/or (ii) Viacom's 5.75% Series A Mandatory Convertible Preferred Stock issued in or traceable to Viacom's initial public offering of that Preferred Stock, which was announced on March 22, 2021, priced on March 23, 2021, and closed on March 26, 2021, and were damaged thereby (the "Class").¹

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

YOU ARE HEREBY NOTIFIED that a hearing (the "Settlement Hearing") will be held on August 5, 2025, at 10:00 a.m., before the Honorable Andrew Borrok of the Supreme Court of the State of New York, at the New York County Courthouse, 60 Centre Street, Courtroom 238, New York, New York 10007.  At the Settlement Hearing the Court will, among other things: (i) determine whether the proposed settlement of the above-captioned action (the "Action") for $120,000,000 in cash (the "Settlement") as set forth in the Stipulation is fair, reasonable, and adequate, and should be approved by the Court; (ii) determine whether the Judgment as provided under the Stipulation should be entered; (iii) determine whether the proposed Plan of Allocation for the distribution of the Net Settlement Fund should be approved by the Court as fair and reasonable; (iv) consider Class Counsel's application for an award of attorneys' fees and Litigation Expenses, including Plaintiffs' request for payment for their efforts in prosecuting this Action on behalf of the Class; (v) consider and rule upon such other matters as the Court may deem appropriate.  Any updates regarding the Settlement Hearing, including any changes to the date or time of the hearing or updates regarding in-person or remote appearances at the hearing, will be posted to the Settlement Website, www.ViacomArchegosSecuritiesLitigation.com.

This is a class action against Defendants Morgan Stanley & Co. LLC, Goldman Sachs & Co. LLC, and Wells Fargo Securities, LLC for alleged violations of sections 11 and12(a)(2) of the Securities Act of 1933 (the "Securities Act").  Plaintiffs claim that Defendants violated the Securities Act by reason of material misrepresentations and omissions in statements issued in connection with the initial and secondary offerings referenced above. The alleged misstatements and omissions relate to each Defendants' respective relationship with Archegos Capital Management, LP.  Defendants deny they have committed any act or omission giving rise to liability in this Action. 

IF YOU ARE A MEMBER OF THE CLASS, YOUR RIGHTS WILL BE AFFECTED BY THE SETTLEMENT OF THIS ACTION.

To share in the distribution of the Settlement Fund, you must establish your rights by submitting a Proof of Claim and Release Form (the "Claim Form") postmarked (if mailed), or submitted online using the Settlement Website, www.ViacomArchegosSecuritiesLitigation.com, no later than August 22, 2025. Your failure to post-mark your Claim Form or to submit it online using the Settlement Website by August 22, 2025, will subject your claim to rejection and preclude your receiving a recovery in connection with the Settlement of this Action.  If you are a member of the Class and do not request exclusion therefrom, you will be bound by the Settlement and any judgment and release entered in the Action, including, but not limited to, the Judgment, whether or not you submit a Claim Form.

If you have not received a copy of the full Notice of (I) Pendency of Class Action and Proposed Settlement; (II) Settlement Hearing; and (III) Motion for Attorneys' Fees and Litigation Expenses (the "Notice"), which more completely describes the Settlement and your rights thereunder (including your right to object to the Settlement), and a Claim Form, you may obtain these documents, as well as a copy of the Stipulation and other settlement documents, online at www.ViacomArchegosSecuritiesLitigation.com, by contacting the Claims Administrator by email at [email protected], or by writing to:

Viacom Archegos Securities Litigation
c/o JND Legal Administration
P.O. Box 91010
Seattle, WA 98111

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

Inquiries, other than requests for the Notice or Claim Form, may be made in writing to Class Counsel:

Bernstein Litowitz Berger & Grossmann LLP
Attn: John Rizio-Hamilton
1251 Avenue of the Americas
New York, NY 10020
Email: [email protected]

-or-

Glancy Prongay & Murray LLP
Attn: Daniella Quitt
745 Fifth Avenue, 5th Floor
New York, NY 10151
Email: [email protected]

If you are a member of the Class and wish to be excluded from the Class, you must submit a request for exclusion such that it is received no later than July 15, 2025, in the manner and form explained in the Notice.  If you properly exclude yourself from the Settlement Class, you will not be bound by any judgments or orders entered by the Court in the Action and you will not be eligible to share in the proceeds of the Settlement.

If you are a Class Member, you have the right to object to the Settlement, the Plan of Allocation, the request by Class Counsel for an award of attorneys' fees and Litigation Expenses and/or the awards to Plaintiffs for representing the Settlement Class. Any objections must be filed with the Court and sent to Class Counsel and Defendants' Counsel such that they are received no later than July 15, 2025, in the manner and form explained in the Notice.

BY ORDER OF THE SUPREME COURT OF NEW YORK,
COUNTY OF NEW YORK.
HONORABLE ANDREW BORROK, J.S.C.

¹ All capitalized terms used in this Summary Notice that are not otherwise defined herein shall have the meanings given to them in the Stipulation and Agreement of Settlement dated March 27, 2025 (the "Stipulation"), available at www.ViacomArchegosSecuritiesLitigation.com.

SOURCE JND Legal Administration