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Sealed Air Securities Litigation

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WELCOME TO THE SEALED AIR SECURITIES LITIGATION WEBSITE

This website has been established to provide general information related to the
proposed settlement of the case captioned UA Local 13 & Employers Group
Insurance Fund v. Sealed Air Corporation and William G. Stiehl, Civil Action No.
1:19-cv-10161-LLS-RWL (the "Litigation"), pending before the United States
District Court for the Southern District of New York (the "Court"). The
capitalized terms used on this website, and not otherwise defined, shall have
the same meanings ascribed to them in the Stipulation and Agreement of
Settlement (the "Stipulation") dated September 9, 2022, which can be found and
downloaded by clicking on the Case Documents tab above. Your rights may be
affected by the Settlement if you purchased or otherwise acquired Sealed Air
Corporation ("Sealed Air" or the "Company") common stock from November 17, 2014
to June 20, 2019, inclusive.

The law firm of Robbins Geller Rudman & Dowd LLP was appointed to represent all
Class Members. These lawyers are called Lead Counsel. You will not be separately
charged for the services of these lawyers. The Court will determine the amount
of Lead Counsel’s fees and expenses. Any fees and expenses awarded by the Court
will be paid from the Settlement Fund. If you want to be represented by your own
lawyer, you may hire one at your own expense.

WHAT IS THIS LAWSUIT ABOUT?

As more fully described in the Notice of Pendency and Proposed Settlement of
Class Action (the "Notice"), Plaintiffs alleged that Defendants Sealed Air and
William G. Stiehl violated Sections 10(b) and 20(a) of the Securities Exchange
Act of 1934. The Complaint alleged that Defendants violated the federal
securities law by allegedly misrepresenting and/or failing to make required
disclosures about the process by which the Company selected its independent
auditor in 2014 and Sealed Air’s financial reporting and disclosures.

On May 17, 2022, the parties participated in a mediation of the Action before
David M. Murphy, Esq., a nationally recognized mediator, but were unable to
reach an agreement. The Settling Parties continued good faith settlement
negotiations. The mediator made a mediator’s recommendation that the case be
settled for $12,500,000.00. On August 11, 2022, the parties agreed to accept the
mediator’s recommendation.

WHAT DOES THE SETTLEMENT PROVIDE?

The Settlement, if approved, will provide Twelve Million Five Hundred Thousand
Dollars ($12,500,000) (the “Settlement Amount”). The Settlement Amount and any
interest it earns constitute the “Settlement Fund.” The Settlement Fund, after
deduction of Court-approved attorneys’ fees and expenses, Notice and
Administration Expenses, Taxes, and any other fees or expenses approved by the
Court, is the “Net Settlement Fund.” If the Settlement is approved by the Court,
the Net Settlement Fund will be distributed to eligible Authorized Claimants.

ADDITIONAL INFORMATION

Although the information in this website is intended to assist you, it does not
replace the information contained in the Notice and Stipulation, both of which
can be found and downloaded by clicking on the Case Documents tab above. We
recommend that you read the Notice and other relevant case documents carefully.


YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

SUBMIT A PROOF OF CLAIM FORM POSTMARKED NO LATER THAN DECEMBER 27, 2022. This is
the only way to be potentially eligible to receive a payment from the
Settlement. EXCLUDE YOURSELF FROM THE CLASS BY SUBMITTING A WRITTEN REQUEST FOR
EXCLUSION POSTMARKED NO LATER THAN DECEMBER 30, 2022. Get no payment. This is
the only option that allows you to ever be part of any other lawsuit against the
Defendants concerning the claims that were, or could have been, asserted in this
case. It is also the only way for Class Members to remove themselves from the
Class. If you are considering excluding yourself from the Class, please note
that there is a risk that any new claims asserted against the Defendants would
be time-barred. You should talk to a lawyer before you request exclusion from
the Class for the purpose of bringing a separate lawsuit. See page 9 in the
Notice. OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS
RECEIVED NO LATER THAN DECEMBER 30, 2022. Write to the Court and explain why you
do not like the Settlement, the proposed Plan of Allocation, and/or the request
for attorneys’ fees and expenses or awards to the Plaintiffs. In order to
object, you must remain a Member of the Class, may not exclude yourself, and you
will be bound by the Court’s determinations. GO TO THE HEARING ON JANUARY 20,
2023 AT 2:00 P.M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS
RECEIVED NO LATER THAN DECEMBER 30, 2022. Ask to speak in Court about the
fairness of the Settlement, the proposed Plan of Allocation, or the request for
attorneys’ fees and expenses. DO NOTHING You will not be eligible to receive a
payment from the Settlement, you will give up your rights, and you will still be
bound by the Settlement.





IMPORTANT DATES AND DEADLINES

Submit Proof of Claim and Release: December 27, 2022 File Objection: December
30, 2022 Exclude Yourself: December 30, 2022 Court Hearing on Fairness of
Settlement: January 20, 2023, at 2:00 p.m.

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