The information contained on this website is only a summary of the information presented in more detail in the Notice of (I) Pendency of Class Action and Proposed Settlement; (II) Settlement Hearing; and (III) Motion for Attorneys’ Fees and Litigation Expenses. Because this website is just a summary, you should review the Notice for additional details.

Summary of the Action and Settlement

This Website relates to a proposed Settlement of claims in a pending securities class action brought by investors alleging that Defendants violated the Securities Act by disseminating offering materials for the March 2021 secondary public offering of ViacomCBS Inc. (“Viacom”) Class B common stock and the March 2021 initial public offering of Viacom 5.75% Series A Mandatory Convertible Preferred Stock (collectively, the “Offering Materials”) that contained false and misleading statements and omitted required disclosures.

The plaintiffs, Camelot Event Driven Fund, A Series of Frank Funds Trust (“Camelot”) and Municipal Police Employees’ Retirement System (“MPERS”; and together with Camelot, “Plaintiffs”), on behalf of themselves and the Class, have reached a settlement of the Action for $120,000,000 in cash that, resolves all claims in the Action (the “Settlement”). After the Effective Date of the Settlement occurs, the “Net Settlement Fund” (that is, the Settlement Fund less: (i) Court-awarded attorneys’ fees; (ii) Notice and Administration Costs; (iii) any required Taxes; (iv) Court-awarded Litigation Expenses; and (v) any other fees or expenses approved by the Court) will be distributed to Class Members who submit valid Claim Forms by the August 22, 2025 deadline, in accordance with the Plan of Allocation.

On August 5, 2025, the Court held a hearing to consider final approval of the Settlement and other matters. Following the hearing, the Court signed the Judgment and Order Granting Final Approval of Class Action Settlement.

If you are a member of the Class, you are subject to the Settlement. The Class consists of:

All persons and entities who purchased or otherwise acquired (i) the Class B Common Stock of 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.

Excluded from the Class are (i) Defendants, the Former Underwriter Defendants, the Officers, directors, and affiliates of Defendants and Former Underwriter Defendants at all relevant times, members of their Immediate Families, their legal representatives, heirs, successors or assigns, and any entity in which any Defendant or Former Underwriter Defendant has or had a controlling interest; (ii) Viacom, now known as Paramount Global, its Officers, directors, and affiliates at all relevant times, including the Former Individual Defendants, and members of their Immediate Families, their legal representatives, heirs, successors or assigns; and (iii) Archegos and the Officers, directors, and affiliates of Archegos at all relevant times, including Sung Kook “Bill” Hwang (“Hwang”), members of their Immediate Families, their legal representatives, heirs, successors or assigns, and any entity in which Hwang has or had a controlling interest. Notwithstanding anything to the contrary set forth in this provision, any Investment Vehicle shall not be excluded from the Class.

Please read the Notice to fully understand your rights and options. Copies of the Notice and Claim Form can be found in the menu at the top of this page.

The deadline to submit a Claim Form to be eligible to participate in the Settlement was August 22, 2025.

Payments to eligible claimants will be made only after the completion of all claims processing. Please be patient, as this process will take some time to complete.

How do I obtain more information?

Detailed information about the Settlement is contained in the Notice, a copy of which can be found in the menu at the top of this page. Additional information can also be obtained by contacting the Claims Administrator by calling toll-free 866-287-0741, emailing info@ViacomArchegosSecuritiesLitigation.com or mailing a letter to:

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

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