The proposed settlement will provide the following benefits to Settlement Class Members:

Expense Reimbursement

                        Documented Ordinary Loss Expense Reimbursement: All Settlement Class Members who submit a valid claim using the Claim Form are eligible for the following documented ordinary loss expense reimbursement, up to $500 per person with third-party documentation. Ordinary Losses would include, without limitation and by way of example, lost time (explained below), professional fees including Attorneys’ Fees, accountants’ fees, and fees for credit repair services; costs associated with freezing or unfreezing credit with any credit reporting agency; credit monitoring costs that were incurred on or after mailing of the Notice of data breach, through the date of claim submission; and miscellaneous expenses such as notary, fax, postage, copying, mileage, and long-distance telephone charges. To receive reimbursement for any of the above-referenced documented ordinary loss expenses, Settlement Class Members must submit a valid and timely Claim Form, including necessary supporting documentation, to the Claims Administrator.

                        Lost Time Reimbursement: Settlement Class Members are eligible to receive reimbursement for up to four (4) hours of lost time spent dealing with the Data Security Incident (calculated at the rate of $20 per hour), for up to $80 per Settlement Class Member. Settlement Class Members may receive reimbursement for lost time if the Settlement Class Member attests that they spent the claimed time responding to issues raised by the Data Security Incident. Claims made for lost time can be combined with reimbursement for documented ordinary loss expense reimbursement and are subject to the same $500 cap for all Settlement Class Members.

                        Documented Extraordinary Loss Reimbursement: Settlement Class Members are also eligible to receive reimbursement for documented extraordinary losses, up to $4,500 per person with third-party documentation, if:  (i) the loss is an actual, documented, and unreimbursed monetary loss stemming from fraud or identity theft; (ii) the loss from fraud or identity theft was more likely than not caused by the Data Breach; (iii) the loss from fraud or identity theft was incurred after the date of the Data Breach; (iv) the loss from fraud or identity theft is not already covered by one or more of the other reimbursement categories; and (v) the Settlement Class Member made reasonable efforts to avoid, or seek reimbursement for, the loss, including but not limited to exhaustion of all available credit monitoring insurance and identity theft insurance.

Credit Monitoring: All Settlement Class Members can claim a free two-year membership to Experian, which provides 1-bureau credit monitoring, daily credit alerts, online and offline reports, customer and fraud resolution support, and identity theft insurance of $1 million.  A link and enrollment code will be emailed to Settlement Class Members who claim that benefit after final approval.  After the Effective Date of the Settlement, Settlement Class Members may use the link and enrollment code provided to activate the credit monitoring.  The Settlement Class Member must activate the service within 90 days from the date of final approval. Defendant will pay for the credit monitoring services separate and apart from other settlement benefits. The maximum amount to be paid by Joy Cone for Loss Reimbursement and Credit Monitoring is capped at no more than $300,000. In the unlikely event that the total amount of valid and timely claims exceeds $300,000, payments to Settlement Class Members who make those claims shall be reduced on a pro rata basis based on the number of claims made so the total does not exceed the overall $300,000 aggregate cap.