270 Legal [Sample Agreements]

STIPULATION AND AGREEMENT
OF COMPROMISE AND SETTLEMENT

IT IS STIPULATED AND AGREED by plaintiff Brian Wornow (“Wornow”) and defendant Register.com, Inc. (“Register.com”), subject to the approval of this Court, that the class action allegations asserted in the above-referenced action (the “Action”) are withdrawn without prejudice, or settled, as provided for werein. IT IS FURTHER STIPULATED AND AGREED by Wornow and Register.com that, subject to the approval of the Court, Wornow’s individual allegations asserted herein are dismissed with prejudice in accordance with the terms and conditions set forth herein, and that the parties will execute a mutual release of all actual or potential claims against one another.

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1.11 After more than two years of litigation in view of the foregoing, and after careful analysis, discussion, and deliberation, the parties are thoroughly familiar with the factual and legal issues presented by their respective claims and defenses, and recognize the uncertainties of the ultimate outcome of this litigation. In light of the substantial expense, inconvenience, and distraction of continued litigation of the Remaining Causes of Action, the parties wish to resolve the lawsuit expeditiously, based on the Remaining Causes of Action, on the terms and conditions set forth herein, subject to Court approval, which apply to a class of Register.com customers as described below.
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