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Nissan Securities Litigation

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WELCOME TO THE NISSAN SECURITIES LITIGATION WEBSITE

This website has been established to provide general information related to the
proposed settlement of the case known as Jackson County Employees’ Retirement
System v. Ghosn, et al., Civil Action No. 3:18-cv-01368 (the "Litigation"),
pending before the United States District Court for the Middle District of
Tennessee, Nashville Division (the "Court"). The capitalized terms used on this
website, and not otherwise defined, shall have the same meanings ascribed to
them in the Stipulation of Settlement dated April 22, 2022 (the "Stipulation"),
which can be found and downloaded by clicking on the Case Documents tab above.
Your rights may be affected by the Settlement if, between May 11, 2014 and
November 16, 2018, inclusive (the “Class Period”), you purchased or otherwise
acquired Nissan Motor Co., Ltd. ("Nissan" or the "Company") American Depositary
Receipts (“ADRs”) on the over-the-counter market (“OTC Market”) and/or if you
are a citizen or resident of the United States who, between May 11, 2014 and
November 16, 2018, inclusive, purchased or otherwise acquired Nissan common
stock.

The entities that lead the Litigation, Jackson County Employees’ Retirement
System and Providence Employees Retirement System, are referred to as the
“Plaintiffs.” The entity and individuals, Nissan, Carlos Ghosn, Greg Kelly,
Hiroto Saikawa, Hiroshi Karube, and Joseph G. Peter, that are being sued are
referred to as the “Defendants.”

The law firm of Robbins Geller Rudman & Dowd LLP (“Lead Counsel”) represent
Class Members. Class Members will not be charged for these lawyers. They will be
paid from the Settlement Fund to the extent the Court approves their application
for fees and expenses.


WHAT IS THIS LAWSUIT ABOUT?

As more fully described in the Notice of Proposed Settlement of Class Action
(the "Notice"), this class action alleges violations of the federal securities
laws and the Financial Instrument and Exchange Act of Japan, brought on behalf
of all Persons who purchased or acquired Nissan ADRs on the OTC Market and
United States citizens or residents who purchased or acquired Nissan common
stock during the Class Period. Plaintiffs allege that the Defendants violated
Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (“Exchange Act”)
and Nissan violated the Financial Instrument and Exchange Act of Japan (the
“FIEA”).

The Amended Complaint for Violations of the Federal Securities Laws (the
“Complaint”), filed on May 6, 2019, alleges that Defendants violated Sections
10(b) and 20(a) of the Exchange Act, as well as that Nissan violated the FIEA.
More specifically, Plaintiffs allege that throughout the Class Period,
Defendants engaged in a scheme to defraud and made materially false and
misleading statements and/or failed to disclose adverse information regarding
the Company’s business and operations, which caused the prices of the Company’s
securities to trade at artificially inflated prices, until the circumstances
concealed by the alleged fraud were revealed, and the Company’s stock prices
significantly declined. Defendants have asserted multiple defenses to
Plaintiffs’ allegations.

On September 15, 2021, Plaintiffs and Nissan participated in a voluntary
mediation with the Hon. Layn R. Phillips (Ret.) of Phillips ADR, an experienced
mediator. Nissan acted on behalf of Nissan and Defendants Saikawa and Peter. The
mediation was preceded by submission of mediation statements. Plaintiffs and
Nissan ultimately accepted the mediator’s proposal to resolve the Litigation as
against the Defendants, and on September 21, 2021, executed a Term Sheet
memorializing their agreement. The agreement includes, among other things, the
Settling Parties’ agreement to settle the Litigation between them in return for
a cash payment of $36,000,000 by Nissan for the benefit of the Class, subject to
the negotiation of the terms of a stipulation of settlement and approval by the
Court. The Stipulation (together with the Exhibits thereto) reflects the final
and binding agreement between the Settling Parties.

Throughout this Litigation, Nissan has maintained that it has multiple defenses
to the claims made by Plaintiffs against Nissan under Sections 10(b) and 20(a)
of the Exchange Act and the FIEA, such as lack of personal jurisdiction over
Nissan by the Court with regard to the FIEA claim. The Individual Defendants
have denied, and continue to deny, any and all of the claims alleged in the
Litigation, including any allegations of fault, liability, wrongdoing, or
damages whatsoever, including (i) that they have committed any act or made any
materially misleading statement giving rise to any liability under Sections
10(b) and 20(a) of the Exchange Act, (ii) that they engaged in a scheme to
defraud, (iii) that they made any material misstatement or omission, (iv) that
the prices of Nissan ADRs or Nissan common stock were artificially inflated as a
result, (v) that they acted with the requisite state of mind, (vi) that any
Class Members, including Plaintiffs, suffered any damages, or (vii) that any
Class Member, including Plaintiffs, were harmed by any conduct alleged in the
Litigation, or that could have been alleged therein.


WHAT DOES THE SETTLEMENT PROVIDE?

In exchange for the Settlement and the release of the Released Claims (defined
in the Stipulation) as well as dismissal of the Litigation, Defendants have
agreed that a payment of $36 million will be made by Nissan, on behalf of all
Defendants, to be divided, after taxes, fees, and expenses, among all Class
Members who send in a valid Proof of Claim.


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 CLAIM FORM This is the only way to be eligible to receive a payment.
Proofs of Claim must be postmarked or submitted online on or before September
14, 2022. EXCLUDE YOURSELF Receive no payment. This is the only option that
potentially allows you to ever be part of any other lawsuit against the
Defendants or any other Released Persons about the legal claims related to the
issues raised in this Litigation in the United States. Should you elect to
exclude yourself from the Class, you should understand that Defendants and the
other Released Defendant Parties will have the right to assert any and all
defenses they may have to any claims that you may seek to assert, including,
without limitation, the defense that such claims are untimely under applicable
statutes of limitation and statutes of repose. Exclusions must be received no
later than August 29, 2022. OBJECT Write to the Court about why you oppose the
Settlement, the Plan of Allocation, the request for attorneys’ fees and
expenses, and/or the expenses of Plaintiffs. You will still be a Member of the
Class. Objections must be received by the Court no later than September 2, 2022
and by counsel no later than August 29, 2022. If you submit a written objection,
you may (but do not have to) attend the hearing. GO TO THE HEARING ON SEPTEMBER
19, 2022 Ask to speak in Court about the fairness of the Settlement. Requests to
speak must be received by the Court and counsel on or before August 29, 2022.
You do not have to attend the hearing unless you wish to speak either in support
of the Settlement or in support of any objection you may have submitted. DO
NOTHING Receive no payment from the Settlement. However, you will be bound by
the Settlement, unless you have requested exclusion from the Class.





IMPORTANT DATES AND DEADLINES

Submit Proof of Claim: September 14, 2022 File Objection and Notice of Intention
to Appear, if applicable: To the Court: September 2, 2022, To Counsel: August
29, 2022 Request Exclusion: August 29, 2022 Court Hearing on Fairness of
Settlement: September 19, 2022, at 2:30 p.m.

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