Settlement of Viswanath V. Shankar v. Imperva, Inc., et al.
Case No. 4:14-cv-01680-PJH

The parties have reached a settlement of this action, pending in the United States District Court for the Northern District of California, Oakland Division.  The settlement provides for the payment of $19,000,000 for the benefit of eligible Class Members.  Lead Plaintiff Delaware County Employees Retirement System alleged that Defendants violated Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) and that the Individual Defendants violated Section 20(a) of the Exchange Act, in connection with statements concerning, among other things, Imperva, Inc.’s (“Imperva”) success in competing against IBM.  Defendants deny these allegations.

The Class consists of all Persons and entities who purchased or otherwise acquired Imperva securities between May 2, 2013 and April 9, 2014, inclusive.  Excluded from the Class are the Defendants and their immediate families, the directors and officers of Imperva at all relevant times, and their legal representatives, heirs, successors or assigns.  Also excluded from the Class are those Persons who timely and validly request exclusion from the Class.

The settlement was preliminarily approved by the Court on October 11, 2017.  The Court has scheduled a final approval hearing for January 31, 2018, at 9:00 a.m.

If you are a Class Member, to receive a payment from the settlement proceeds, you must submit a claim form postmarked no later than January 22, 2018.  The claim form can be obtained by clicking on the Proof of Claim and Release link below.

Alternatively, you can submit your claim online.  Online claims must be submitted by January 22, 2018.  For more information, and to file your claim online, visit the Claims Administrator’s Imperva Litigation website at www.impervasecuritieslitigation.com.

If you have any questions about the settlement or the litigation, please contact Rick Nelson at 1-800-449-4900.


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