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Updates Related to Class Action

March 2026, Quebec:

A class action instituted by Mr. Dahan against MGM was filed before the Superior Court of Québec, district of Montréal, bearing court file number 500-06-001280-235 (the “Dahan Class Action”). Class members are all persons in Canada (including estates, executors, and personal representatives) whose personal and/or financial information was lost by or stolen from MGM in the September 11, 2023 Confidentiality Incident.

A class action instituted by Mr. Zuckerman against MGM was filed before the Superior Court of Québec, district of Montréal, bearing court file number 500-06-001078-209 (the “Zuckerman Class Action”). Class members are all persons in Québec (including estates, executors, and personal representatives) whose personal and/or financial information was lost by or stolen from MGM in the July 7, 2019 Confidentiality Incident (the “Class” or “Class Members”). The Superior Court of Quebec authorized the Zuckerman Class Action on August 3, 2022 and appointed Mr. Zuckerman as a representative on behalf of the Class.

The Superior Court of Québec scheduled a hearing to decide whether to approve the Settlement on May 20, 2026 at 9:30 am in room 15.02 of the Superior Court of Québec in Montreal, located at 1 Notre-Dame Street E., Montreal, Quebec, H2Y 1B6. Please find the relevant short-form and long-form notices for those actions attached.

Settlement Pre-approval Judgment

Long Form Preapproval Notice 1

Avis préapprobation détaillé

Short Form Preapproval Notice 1

Avis préapprobation abrégé 1

Long Form Preapproval Notice 2

Avis préapprobation détaillé 2

Short Form Preapproval Notice 2

Avis préapprobation abrégé 2

March 2026, British Columbia:

On November 26, 2025, as corrected on March 6, 2026, the Supreme Court of British Columbia certified, for settlement purposes only, the Thandi Class Action against MGM and scheduled a hearing to decide whether to approve the settlement agreement. That hearing will take place on May 25, 2026, at 10:00 A.M. in the Supreme Court of British Columbia in Vancouver, located at 800 Smithe Street, Vancouver, British Columbia.

Under the terms of the Settlement, MGM has agreed to pay CAD $4,000,000.00. After deductions for class counsel fees, disbursements, and administrative costs, the remaining funds will be distributed to Class Members through:

(i) reimbursement for one year of credit monitoring (including up to $1,000,000 CAD of fraud/identity theft insurance);
(ii) substantiated losses of up to CAD $20,000.00 with supporting documentation; and
(iii) unsubstantiated losses of CAD $150 (First Group) or CAD $300 (Second Group), with potential increases up to CAD $500 and CAD $1,000 respectively if funds remain.

All payments are subject to pro rata adjustments based on the total value of approved claims relative to the Settlement Fund.

Please refer to the Short Form and Long Form Notice for more information about the proposed settlement.

Short Form Notice

Long Form Notice

December 2023:

We write to provide you with a further update beyond the update provided in July 2023. We are working towards a certification motion, which will be held on March 4, 5, and 6, 2024. For your information, a certification motion is where the court allows the action to proceed as a class action. To date, we have filed and served our certification application materials.

July 2023:

We write to provide you with a further update beyond the update provided in March 2023. We are working towards a certification motion, which will be held on March 4, 5, and 6, 2024. For your information, a certification motion is where the court allows the action to proceed as a class action. To date, we have filed and served our certification application materials.

March 2023:

We write to provide you with an update. We are working towards a certification motion. For your information, a certification motion is where the court allows the action to proceed as a class action. To date, we have filed and served our certification application materials and will be working with opposing counsel in scheduling the certification hearing.

December 2022:

We write to provide you with an update. We are working towards a certification motion. For your information, a certification motion is where the court allows the action to proceed as a class action. To date, we have filed and served our certification application materials and will be working with opposing counsel in scheduling the certification hearing.