Kahn Swick & Foti LLC & Block & Leviton LLP Announce Proposed Settlement of Class Action on Behalf of All Former Owners of Exabeam, Inc. Common Stock

NEW ORLEANS, Oct. 22, 2026 /PRNewswire/ -- 

SUMMARY NOTICE OF PENDENCY OF STOCKHOLDER CLASS ACTION AND
PROPOSED SETTLEMENT, SETTLEMENT HEARING, AND RIGHT TO APPEAR

TO:   ALL RECORD AND BENEFICIAL STOCKHOLDERS OF EXABEAM, INC. COMMON STOCK WHOSE SHARES WERE CANCELLED ON OR ABOUT JULY 2, 2024 IN CONNECTION WITH THOMA BRAVO, L.P.'S ACQUISITION OF EXABEAM, INC., TOGETHER WITH THEIR RESPECTIVE SUCCESSORS AND ASSIGNS, EXCEPT THE EXCLUDED PERSONS.

The purpose of this Notice is to inform you of the Settlement reached in connection with the putative class action lawsuit captioned Domingo Mihovilovic, et al. v. Exabeam, Inc., et al., pending in the Court of Chancery of the State of Delaware, Civil Action Number 2024-0976-PAF (the "Action") and the hearing to be held by the Court of Chancery ("Court") in connection with the proposed Settlement.

The hearing will be held by the Court at the Leonard L. Williams Justice Center, 500 North King Street, Wilmington, Delaware 19801, or remotely by Zoom (in the discretion of the Court), on December 9, 2026, at 3:15 p.m. (the "Settlement Hearing") for the purposes of determining, among other things:

(a) whether the Action may be finally maintained as a non-opt out class action and whether the Class should be finally certified, for purposes of the Settlement, pursuant to Court of Chancery Rules 23(a), 23(b)(1), and 23(b)(2);

(b) whether Domingo Mihovilovic, Nadav Lavy, Uri Ben-Dor, and Rajiv Taneja, as Trustee of the Taneja 2004 Family Trust ("Plaintiffs") may be finally appointed as Class Representatives and Kahn Swick & Foti, LLC and Block & Leviton LLP finally appointed as Class Counsel, and whether the Plaintiffs and Plaintiffs' Counsel have adequately represented the interests of the Class;

(c) whether the proposed Settlement on the terms and conditions provided for in the Stipulation is fair, reasonable, and adequate to the Class, and should be approved by the Court;

(d) whether the Order and Final Judgment should be entered dismissing the Action against Defendants with prejudice and releasing all Released Plaintiffs' Claims against Defendants and the Released Defendant Parties;

(e) whether the proposed Plan of Allocation of the Net Settlement Fund is fair and reasonable, and should therefore be approved;

(f) whether the application by Plaintiffs' Counsel for an award of attorneys' fees and expenses for Plaintiffs' Counsel and any incentive award should be approved; and

(g) hear and rule on any objections to the Settlement, the proposed Plan of Allocation, and/or to the application for an award of attorneys' fees and expenses.¹

IF YOU HELD EXABEAM COMMON STOCK AT ANY TIME FROM AND INCLUDING MAY 4, 2024, THROUGH AND INCLUDING JULY 2, 2024, INCLUSIVE OF BOTH DATES (THE "CLASS PERIOD"), YOUR RIGHTS MAY BE AFFECTED BY THE SETTLEMENT OF THIS LITIGATION, INCLUDING THE RELEASE AND EXTINGUISHMENT OF CLAIMS YOU MAY POSSESS RELATING TO YOUR PURCHASE OR OWNERSHIP OF EXABEAM COMMON STOCK DURING THE CLASS PERIOD. If you have not received a detailed Notice of Pendency of Stockholder Class Action and Proposed Settlement, Settlement Hearing, and Right to Appear ("Notice"), you may obtain copies by writing to Exabeam Stockholder Settlement c/o A.B. Data, Ltd., P.O. Box 170500, Milwaukee, WI 53217, 877-719-6140, or on the Internet at www.ExabeamStockholderSettlement.com 

Any Class Member who objects to the Stipulation, the Settlement, the class action determination, the Judgment to be entered in the Action, Plaintiffs' Counsel's application for attorneys' fees and expenses, or the application for an incentive award ("Objector"), or who otherwise wishes to be heard, may appear in person or by such Class Member's attorney at the Settlement Hearing and present evidence or argument that may be proper and relevant; provided, however, that, except for good cause shown or as the Court otherwise directs, no Objector shall be heard and no papers, briefs, pleadings, or other documents submitted by any Person shall be considered by the Court unless, not later than November 25, 2026 (fourteen (14) calendar days prior to the Settlement Hearing), such Objector files with the Register in Chancery, Court of Chancery of the State of Delaware, New Castle County, Leonard L. Williams Justice Center, 500 North King Street, Wilmington, Delaware 19801, and serves upon counsel (listed below) a written objection ("Objection"). Any Objection must: (i) identify the case name and civil action number, "Domingo Mihovilovic, et al. v. Exabeam, Inc., et al., C.A. No. 2024-0976-PAF"; (ii) state the name, address, and telephone number of the Objector and, if represented by counsel, the name, address, and telephone number of the Objector's counsel; (iii) be signed by the Objector; (iv) contain a specific, written statement of the objection(s) and the specific reason(s) for the objection(s), including any legal and evidentiary support the Objector wishes to bring to the Court's attention, and, if the Objector has indicated that he, she, or it intends to appear at the Settlement Hearing, the identity of any witnesses the Objector may call to testify and any exhibits the Objector intends to introduce into evidence at the hearing; and (v) include documentation sufficient to prove that the Objector is a member of the Class. Documentation establishing that an Objector is a member of the Class must consist of copies of monthly brokerage account statements or an authorized statement from the Objector's broker containing the transactional and holding information found in an account statement.

PLEASE DO NOT CONTACT THE COURT REGARDING THIS NOTICE. If you have any questions about the Settlement, you may contact Kahn Swick & Foti, LLC or Block & Leviton LLP, at the addresses listed above.

Source:
Kahn Swick & Foti, LLC
Block & Leviton LLP     

SOURCE Kahn Swick & Foti LLC and Block & Leviton LLP