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SEPTEMBER 20, 2024 UPDATE: Please note that the Settlement Hearing will take place remotely via Zoom. For instructions on how to participate, please see the Court’s order here. If you intend to appear in the hearing, please contact Plaintiff’s Counsel at lsolish@glancylaw.com AND settlements@glancylaw.com by noon, Pacific, on Wednesday, September 25, 2024. The Zoom link and access information is:

https://cand-uscourts.zoomgov.com/j/1606745157?pwd=Q1FSb2lwcitwS1BYUDc0L2VXekR0UT09
Webinar ID: 160 674 5157
Password: 271988

JUNE 25, 2024 UPDATE: The Court has rescheduled the Settlement Fairness Hearing for September 27, 2024 at 9:00 a.m. Requests for exclusion must now be mailed or delivered such that they are received by September 6, 2024.  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 September 6, 2024. 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 September 6, 2024.

Notice of Pendency of Class Action:  Please be advised that your rights may be affected by the above-captioned securities class action (the “Action”) pending in the United States District Court for the Northern District of California (the “Court”), if, during the period between August 8, 2017 and March 4, 2019, inclusive (the “Settlement Class Period”), you purchased or otherwise acquired the publicly traded common stock of Adamas Pharmaceuticals, Inc. (“Adamas” or the “Company”)[1] and were damaged thereby (the “Settlement Class”).[2]

Notice of Settlement:  Please also be advised that the Court-appointed lead plaintiff, Ralph Martinez (“Lead Plaintiff”), on behalf of himself and the Settlement Class (as defined in ¶26 of the Notice), has reached a proposed settlement of the Action for $4,650,000 in cash that, if approved, will resolve all claims in the Action (the “Settlement”).

PLEASE READ THIS NOTICE CAREFULLY.  This Notice explains important rights you may have, including the possible receipt of cash from the Settlement.  If you are a member of the Settlement 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 Adamas, Supernus, the Defendant in the Action (as defined below), or his counsel.  All questions should be directed to Lead Counsel or the Claims Administrator (see ¶89 of the Notice).  

1. Description of the Action and the Settlement Class:  This Notice relates to a proposed Settlement of claims in a pending securities class action brought by investors alleging, among other things, that defendant Richard A. King, as former Chief Operating Officer of Adamas, (“Defendant”) violated the federal securities laws by a making an allegedly false and misleading statement regarding anticipated payer reimbursement for GOCOVRI. A more detailed description of the Action is set forth in paragraphs 11-25 below.  As noted, Defendant has denied and continues to deny all claims and allegations of wrongdoing asserted against him in the Action.  The proposed Settlement, if approved by the Court, will settle claims of the Settlement Class, as defined in paragraph 26 of the Notice.

2. Statement of the Settlement Class’s Recovery:  Subject to Court approval, Lead Plaintiff, on behalf of himself and the Settlement Class, has agreed to settle the Action in exchange for a settlement payment of $4,650,000 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 (a) any Taxes, (b) any Notice and Administration Costs, (c) any Litigation Expenses awarded by the Court, and (d) any attorneys’ fees awarded by the Court) will be distributed in accordance with a plan of allocation that is approved by the Court, which will determine how the Net Settlement Fund shall be allocated among members of the Settlement Class.  The proposed plan of allocation (the “Plan of Allocation”) is set forth on pages 11-15 of the Notice.

3. Estimate of Average Amount of Recovery Per Share:  Based on Lead Plaintiff’s damages expert’s estimates of the number of shares of Adamas publicly traded common stock purchased during the Settlement Class Period that may have been affected by the conduct at issue in the Action and assuming that all Settlement 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) per eligible share is $0.27.  Settlement Class Members should note, however, that the foregoing average recovery per share is only an estimate.  Some Settlement Class Members may recover more or less than this estimated amount depending on, among other factors, the number of shares of Adamas publicly traded common stock they purchased, when and at what prices they purchased/acquired or sold their Adamas common stock, and the total number of valid Claim Forms submitted.  Distributions to Settlement Class Members will be made based on the Plan of Allocation set forth in the Notice (see pages 11-15 below) or such other plan of allocation as may be ordered by the Court.

4. Average Amount of Damages Per Share:  Lead Plaintiff and Defendant (collectively the “Parties”) do not agree on the average amount of damages per share that would be recoverable if Lead Plaintiff was to prevail in the Action.  Among other things, Defendant does not agree with the assertion that he violated the federal securities laws or that any damages were suffered by any members of the Settlement Class as a result of his conduct.

5. Attorneys’ Fees and Expenses Sought:  Plaintiff’s Counsel, which have been prosecuting the Action on a wholly contingent basis since its inception in 2019, have not received any payment of attorneys’ fees for their representation of the Settlement Class and have advanced the funds to pay expenses necessarily incurred to prosecute this Action.  Court-appointed Lead Counsel, Glancy Prongay & Murray LLP, will apply to the Court for an award of attorneys’ fees for all Plaintiff’s Counsel in an amount not to exceed 33⅓% of the Settlement Fund.  In addition, Lead Counsel will apply for reimbursement of Litigation Expenses paid or incurred in connection with the institution, prosecution and resolution of the claims against the Defendant, in an amount not to exceed $120,000, which may include an application for reimbursement of the reasonable costs and expenses incurred by Lead Plaintiff directly related to his representation of the Settlement Class in an amount not to exceed $10,000.  Any fees and expenses awarded by the Court will be paid from the Settlement Fund.  Settlement Class Members are not personally liable for any such fees or expenses.  Estimates of the average cost per affected share of Adamas common stock, if the Court approves Lead Counsel’s fee and expense application, is $0.098 per eligible share.

6. Identification of Attorneys’ Representatives:  Lead Plaintiff and the Settlement Class are represented by Leanne H. Solish, Esq. of Glancy Prongay & Murray LLP, 1925 Century Park East, Suite 2100, Los Angeles, CA 90067, (888) 773-9224, settlements@glancylaw.com.

7. Reasons for the Settlement:  Lead Plaintiff’s principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation.  Moreover, the substantial cash benefit 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.  Defendant, who denies all allegations of wrongdoing or liability whatsoever, is entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation. 

YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT:

[1] On or about November 24, 2021, Adamas was acquired by Supernus Pharmaceuticals, Inc. (“Supernus”).

[2] 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 February 29, 2024 (the “Stipulation”), which is available on the Important Documents page.