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 proposed settlement of the Action for $120,000,000 in cash that, if approved by the Court, will resolve all claims in the Action (the “Settlement”). If the Settlement is approved by the Court and the Effective Date 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 proposed Plan of Allocation or such other plan of allocation as the Court may approve.
If you are a member of the Class, you are subject to the Settlement, unless you timely request to be excluded. 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. Also excluded from the Class are any persons and entities that submit a request for exclusion from the Class that is accepted by the Court. 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.
Payments to eligible claimants will be made only if the Court approves the Settlement and a Plan of Allocation, only after any appeals are resolved, and after the completion of all claims processing. Please be patient, as this process will take some time to complete.
| YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT: |
| SUBMIT A CLAIM FORM POSTMARKED (IF MAILED) OR SUBMITTED ONLINE NO LATER THAN AUGUST 22, 2025. |
This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Class Member and you remain in the Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Plaintiffs’ Claims (defined in ¶ 47a of the Notice) that you have against Defendants and the other Defendants’ Releasees (defined in ¶ 47b of the Notice), so it is in your interest to submit a Claim Form. |
| EXCLUDE YOURSELF FROM THE CLASS BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS RECEIVED NO LATER THAN JULY 15, 2025. |
If you exclude yourself from the Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Defendants’ Releasees concerning the Released Plaintiffs’ Claims. |
| OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN JULY 15, 2025. |
If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys’ fees and Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation, or the fee and expense request unless you are a Class Member and do not exclude yourself from the Class. |
| GO TO A HEARING ON AUGUST 5, 2025, AT 10:00 A.M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN JULY 15, 2025. |
Filing a written objection and a notice of appearance by July 15, 2025 allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and Litigation Expenses. The Settlement Hearing will be held on August 5, 2025 at 10:00 a.m. either in person or by videoconference. If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection. |
| DO NOTHING. |
If you are a Class Member and you do not submit a valid Claim Form, you will not be eligible to receive any payment from the Settlement Fund. You will, however, remain a Class Member, which means that you give up your right to sue about the claims that are resolved by the Settlement and you will be bound by any judgments or orders entered by the Court in the Action. |
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.
© JND Legal Administration. All rights reserved.
