Model N Securities Litigation
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Welcome to the Model N Securities Litigation Website

This website has been established to provide general information related to the proposed settlement of the Model N, Inc. (“Model N”) Securities Litigation (the "Settlement"). The capitalized terms used on this website, and not defined herein, shall have the same meanings ascribed to them in the Stipulation of Settlement dated November 20, 2015 (the “Stipulation”), which can be found and downloaded by clicking on the Case Documents tab above. 

This is a securities class action litigation currently pending before the Honorable Marie S. Weiner in the Superior Court of California, County of San Mateo (the “Court”), known as Plymouth County Retirement System v. Model N, Inc., et al., Master Case No. CIV530291.

On March 6, 2015, Plaintiffs filed a Consolidated Amended Class Action Complaint for Violations of the Securities Act of 1933 (“Complaint”). Plaintiffs brought the action on behalf of all persons who purchased or otherwise acquired the common stock of Model N pursuant or traceable to the Registration Statement and Prospectus (collectively, the “Registration Statement”) issued in connection with the Company’s March 20, 2013 IPO. On March 25, 2013, Model N completed the initial public offering ("IPO") and issued 7.551 million shares for $15.50 per share, raising approximately $108 million. Plaintiffs allege that the Model N Defendants and the Underwriter Defendants violated Sections 11 and 12(a)(2) of the Securities Act of 1933 (the “Securities Act”) and that the Model N Defendants violated Section 15 of the Securities Act because the Registration Statement contained untrue statements of material fact and omitted other facts necessary to make the statements made therein not misleading.

Plaintiffs allege that the Registration Statement violated the Securities Act by failing to disclose that, at the time of the IPO, Model N was experiencing sales execution challenges – the inability to close and book sales – that were reasonably likely to (and in fact did) reverse the growing bookings and revenue trends reported in the Registration Statement and cause future bookings and revenues to decline.

Defendants have denied and continue to deny each and all charges of wrongdoing or liability against them arising out of any of the conduct, statements, acts, or omissions alleged in the Complaint.

In August 2015, the parties agreed to participate in a mediation with Robert A. Meyer, Esq. On October 1, 2015, the Settling Parties exchanged mediation statements and also submitted them to the mediator. On October 8, 2015, the Settling Parties participated in the mediation but did not reach an agreement at that time. Settlement discussions continued with the assistance of the mediator, and on November 4, 2015, the parties agreed to settle the action for $8,550,000.

The Class is defined as all Persons who purchased or otherwise acquired the common stock of Model N pursuant or traceable to the Registration Statement issued in connection with Model N’s March 20, 2013 IPO.

The Class Period is defined as the period beginning on March 20, 2013 and ending on September 16, 2013.

The Settlement, if approved, will result in the creation of a cash settlement amount of $8,550,000 (the “Settlement Amount”). The Settlement Amount, plus accrued interest (the “Settlement Fund”) and minus the costs associated with the administration of the Settlement, as well as attorneys’ fees and expenses, and the payment of Plaintiffs’ time and expenses in representing the Class, as approved by the Court (the “Net Settlement Fund”), will be distributed to Class Members pursuant to the Plan of Allocation.

The Court appointed the law firms of Robbins Geller Rudman & Dowd LLP and Labaton Sucharow LLP to represent you and other Class Members. These lawyers are called Lead Counsel.

Although the information on this website is intended to assist you, it does not replace the information contained in the Notice of Proposed Settlement of Class Action (the "Notice") and the Stipulation, both of which can be found and downloaded from this website. We recommend that you read the Notice and other relevant case documents carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

SUBMIT A CLAIM FORM If you are a Class Member and do not exclude yourself from the Class, the only way to get a payment is to submit a Proof of Claim
EXCLUDE YOURSELF Get no payment. This is the only option that allows you to participate in another lawsuit against the Defendants.
OBJECT You may object to the terms of the Settlement; the requested attorneys' fees, costs, and expenses; the payment to Plaintiffs for their time and expenses; and/or the Plan of Allocation by filing a written statement, accompanied by proof of class membership, with the Court.
GO TO A HEARING You may ask to speak in Court about the fairness of the Settlement, the request for attorneys’ fees and expenses, or the Plan of Allocation.
DO NOTHING If you do nothing, you will not receive any payment, will not be allowed to object to the Settlement, and will give up your right to participate in another lawsuit against the Defendants for the legal claims in this action.

IMPORTANT DATES & DEADLINES

Submit a Claim Form: March 28, 2016
Request Exclusion: March 14, 2016
File an Objection: March 14, 2016
Court Hearing on Fairness of Settlement: April 4, 2016 at 2:00 p.m.