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OCTOBER 10, 2024 UPDATE: This case has been reassigned to the Honorable Ted Stewart. The Settlement Hearing will be held on February 4, 2025 at 10:30 a.m. before Judge Stewart at the U.S. District Court for the District of Utah, Orrin G. Hatch U.S. Courthouse, Courtroom 8.300, 351 South West Temple, Salt Lake City, UT 84101.

SEPTEMBER 4, 2024 UPDATE: The Court has rescheduled the Settlement Hearing for February 4, 2025 at 10:30 a.m. Requests for exclusion must now be mailed or delivered such that they are received by January 14, 2025.  Written objections must be filed with the Clerk of the Court at the address set forth in the Notice such that they are filed no later than January 14, 2025. If you timely file a written objection and wish to be heard orally at the hearing, you must also file a notice of appearance with the Clerk’s Office at the address set forth Notice on or before January 14, 2025.

NOTICE OF PENDENCY OF CLASS ACTION: Please be advised that your rights may be affected by a securities class action (the “Action”) pending in the U.S. District Court for the District of Utah (the “Court”), if, during the period from January 16, 2019 to July 31, 2019, inclusive (the “Class Period”), you purchased or otherwise acquired the Class A common stock of Pluralsight, Inc. (“Pluralsight” or the “Company”) and were damaged thereby.^[1]

NOTICE OF SETTLEMENT: Please also be advised that the Court-appointed Lead Plaintiffs, Indiana Public Retirement System (“INPRS”) and the Public School Teachers’ Pension and Retirement Fund of Chicago (“CTPF”), on behalf of themselves and the other members of the Class (as defined in ¶ 17 of the Notice of (I) Proposed Settlement of Class Action and Plan of Allocation; (II) Settlement Hearing; and (III) Motion for an Award of Attorneys’ Fees and Litigation Expenses (the “Notice”)), have reached a proposed settlement of the Action for $20,000,000 in cash.

PLEASE READ THIS NOTICE CAREFULLY. This Notice explains important rights you may have, including the possible receipt of a payment from the Settlement. If you are a member of the Class, your legal rights will be affected whether or not you act.

 If you have any questions about this Notice, the proposed Settlement, or your eligibility to participate in the Settlement, please DO NOT contact the Court, Pluralsight, the other Defendants in the Action, or their counsel. All questions should be directed to Lead Counsel or the Claims Administrator (see ¶ 60 of the Notice).

1. Description of the Action and the Class: This Notice relates to a proposed settlement of claims in a pending securities class action brought by investors alleging, among other things, that Pluralsight, Pluralsight’s co-founder and former Chief Executive Officer Aaron Skonnard, and Pluralsight’s former Chief Financial Officer James Budge (the “Individual Defendants,” and, with Pluralsight, “Defendants”) violated the federal securities laws by making a false and misleading statement about Pluralsight’s sales force productivity and future billings growth. A more detailed description of the Action is set forth in ¶¶ 11-16 of the Notice. The proposed Settlement, if approved by the Court, will settle claims of the Class, as defined in ¶ 17 of the Notice.
2. Statement of the Class’s Recovery: Subject to Court approval, Lead Plaintiffs, on behalf of themselves and the Class, have agreed to settle the Action in exchange for $20,000,000 in cash (the “Settlement Amount”) to be deposited into an escrow account. The Net Settlement Fund (i.e., the Settlement Amount plus any and all interest earned thereon (the “Settlement Fund”) less (i) any Taxes; (ii) any Notice and Administration Costs; (iii) any Litigation Expenses awarded by the Court; (iv) any attorneys’ fees awarded by the Court; and (v) any other costs or fees approved by the Court) will be distributed in accordance with a plan of allocation that is approved by the Court. The proposed plan of allocation (the “Plan of Allocation”) is set forth in Appendix A of the Notice. The Plan of Allocation will determine how the Net Settlement Fund shall be allocated among members of the Class.
3. Estimate of Average Amount of Recovery Per Share: Based on Lead Plaintiffs’ damages expert’s estimate of the number of shares of Pluralsight Class A common stock purchased during the Class Period that may have been affected by the conduct at issue in the Action, and assuming that all Class Members elect to participate in the Settlement, the estimated average recovery (before the deduction of any Court-approved fees, expenses, and costs as described herein) is $0.36 per affected share. Class Members should note, however, that the foregoing average recovery is only an estimate. Some Class Members may recover more or less than this estimated amount depending on, among other factors, when and at what prices they purchased/acquired or sold their Pluralsight shares, the total number and value of valid Claim Forms submitted, the amount of Notice and Administration Costs, and the amount of attorneys’ fees and Litigation Expenses awarded by the Court. Distributions to Class Members will be made based on the Plan of Allocation set forth herein (see Appendix A of the Notice) or such other plan of allocation as may be ordered by the Court.
4. Average Amount of Damages Per Share: The Parties do not agree on the average amount of damages per share that would be recoverable if Lead Plaintiffs were to prevail in the Action. Among other things, Defendants do not agree with the assertion that they violated the federal securities laws or that any damages were suffered by any members of the Class as a result of their conduct.
5. Attorneys’ Fees and Expenses Sought: Court-appointed Lead Counsel, Cohen Milstein Sellers & Toll PLLC, has been prosecuting the Action on a wholly contingent basis since their appointment as Lead Counsel in March 2020, have not received any payment of attorneys’ fees for their representation of the Class, and have advanced the funds to pay expenses necessarily incurred to prosecute this Action. Lead Counsel, on behalf of Plaintiffs’ Counsel,^[2] will apply to the Court for an award of attorneys’ fees in an amount not to exceed 20% of the Settlement Fund. In addition, Lead Counsel will apply for payment of Litigation Expenses incurred in connection with the institution, prosecution, and resolution of the Action in an amount not to exceed $350,000, which may include an application for reimbursement of the reasonable costs (including lost wages) and expenses incurred by Lead Plaintiffs directly related to their representation of the Class, pursuant to the Private Securities Litigation Reform Act of 1995 (“PSLRA”). Any fees and expenses awarded by the Court will be paid from the Settlement Fund. Class Members are not personally liable for any such fees or expenses. The estimated average cost for such fees and expenses, if the Court approves Lead Counsel’s fee and expense application, is $0.08 per affected share of Class A common stock. Class Members should note that this amount is only an estimate.
6. Identification of Attorney Representatives: Lead Plaintiffs and the Class are represented by Carol V. Gilden, 190 S. LaSalle St., Suite 1705, Chicago, IL 60603, (312) 357-0370.
7. Reasons for the Settlement: Lead Plaintiffs’ principal reason for entering into the Settlement is the substantial and certain recovery for the Class without the risk or the delays inherent in further litigation. Moreover, the substantial recovery provided under the Settlement must be considered against the significant risk that a smaller recovery—or indeed no recovery at all—might be achieved after contested motions, a trial of the Action, and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny that they have committed any act or omission giving rise to liability under the federal securities laws, are entering into the Settlement solely to eliminate the uncertainty, burden, and expense of further litigation.

[1] All capitalized terms used in this Notice that are not otherwise defined herein shall have the meanings ascribed to them in the Stipulation and Agreement of Settlement dated May 1, 2024 (the “Stipulation”), which is available at www.pluralsightsecuritieslitigation.com.

[2] Plaintiffs’ Counsel includes Lead Counsel and Clyde, Snow & Sessions P.C., the Court-appointed Liaison Counsel.