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Foreign Exchange Reimbursements were sent on March 23, 2024 by Interac
e-transfer to approved claims. In parallel, an email was sent to approved claims
with a 4 digit password to deposit the Interac e-transfer. Please email
ticketfx@velvetpayments.com if you did not receive your e-transfer or password.



Case name
Vivid Seats American Currency Charges Class Action

Quebec Superior Court file #
500-06-000891-172 (Montreal)

AUTHORIZATION OF THE CLASS ACTION

On November 16, 2017, a class action was commenced in Quebec against Vivid Seats
LLC ("Vivid Seats") alleging that Vivid Seats did not properly disclose that
event tickets were being sold in US Dollars, rather than Canadian Dollars. The
Plaintiff was asking the Court to determine whether this alleged conduct
infringed the Quebec Consumer Protection Act.

On September 6, 2018, the Honourable Benoît Moore of the Superior Court of
Québec authorized the bringing of this class action against the Defendant on
behalf of the following class:


All consumers within the meaning of the Quebec’s Consumer Protection Act who
purchased a ticket from Vivid Seats web site or application since November 16th,
2014.

On or around February 26, 2019, Vivid Seats sent you a notice of the
authorization judgment pursuant to the Court’s judgment of February 1, 2019.

PROPOSED SETTLEMENT OF THE CLASS ACTION

The parties to this class action have reached a proposed settlement (the
"Settlement Agreement"), subject to obtaining the approval of the Superior Court
of Quebec. The Settlement Agreement has a total settlement maximum of CAD
$530,250, which includes the payment of administration expenses, and the payment
of Class Counsel fees and disbursements in the amount of $120,000 in fees and
disbursements (plus GST & QST) plus $12,090.55 (including taxes) to reimburse
the Fonds d’aide aux actions collectives.

The Settlement Agreement, if approved by the Court, provides that the Defendant
will offer foreign exchange reimbursements, meaning a reimbursement of, at
maximum, 30% of the ticket order, to the following group:


All consumers in Quebec who purchased a ticket from Vivid Seats:


 * On its website between November 16, 2014 and December 29, 2017; or
 * On its mobile application between November 16, 2014 and January 15, 2018

("Class" or "Class Members")

If a Class Member made more than one admissible Ticket Order, the first
chronological order made by the Class Member will be the one eligible for a
reimbursement. The reimbursement will be paid via Interac e-Transfer.

A maximum amount of $360,000 has been allotted to make these reimbursements. In
the event that the total number of valid claims exceeds this amount, they will
be paid pro rata, proportionate to the value of the claim. Two percent (2%) of
the reimbursement will be withheld and paid as a levy to the Fonds d’aide aux
actions collectives as required by law.

In order to make a valid claim, Class Member claimants must submit a valid and
timely online claim form attesting that when concluding their Ticket Order, they
did not realize that the purchase they were making was in US Dollars.

In return for providing the reimbursements, the Defendant will receive a release
from all Settlement Class Members and a declaration of a settlement out of court
of the Class Action. The settlement is a compromise of disputed claims and is
not an admission of liability, wrongdoing or fault on the part of the Defendant.

SETTLEMENT APPROVAL HEARING

A hearing before the Superior Court of Québec will be held on September 13,
2023, at 9:00 a.m., at the Montreal courthouse located at 1, Notre-Dame East
Street, Montreal, Quebec, in room 2.08, or via a TEAMS link. This date may be
subject to adjournment by the Court without further publication notice to the
Class Members, other than such notice which will be posted on Class Counsel’s
website lpclex.com/vividseats or on this website.

Class Members who do not oppose the proposed Settlement Agreement do not need to
appear at any hearing or take any other action to indicate their desire to
support the proposed Settlement Agreement.

If you wish to object to the terms of the proposed Settlement Agreement:

If you disagree with the Settlement Agreement, you can object to the Settlement
Agreement by delivering a written submission on or before June 30, 2023, filed
with the Court or Class Counsel in accordance with the proposed Settlement
Agreement and containing the following information:


 * A heading referring to this proceeding (Nicolas v. Vivid Seats LLC, case no.
   500-06-000891-172).
 * Your name, current address, and telephone number and, if represented by
   counsel, the name of your counsel.
 * A statement that you reside in Quebec and purchased a ticket from Vivid Seats
   LLC, either on their website between November 16, 2014 and December 29, 2017,
   or on their application between November 16, 2014 and January 15, 2018.
 * A statement whether you intend to appear at the settlement approval hearing,
   either in person or through counsel.
 * A statement of the objection and the grounds supporting the objection.
 * Copies of any papers, briefs, or other documents upon which the objection is
   based.
 * Your signature.

You must send your letter by registered mail, with a copy by email to Class
Counsel (jzukran@lpclex.com), at the following address:


Clerk of the Superior Court of Québec
File: 500-06-000891-172
Montreal Courthouse
1, Notre-Dame East Street, Suite 1.120, Montréal (Québec), H2Y 1B6

Please note that the Court cannot change the terms of the Settlement Agreement.
Any objections will be used by the Court to consider whether to approve the
Settlement Agreement or not.

If the Settlement Agreement is approved, another notice to Class Members will be
sent explaining the how and by when to complete your online Claim.

As a Class Member, you have the right to intervene in the present Class Action,
in the manner provided for by law. No Class Member other than the representative
plaintiff or an intervenor may be required to pay legal costs arising from the
class action.

For further information or details about the proposed Settlement Agreement, you
may contact class counsel identified below. Your name and any information
provided will be kept confidential. Please do not contact Vivid Seats LLC, or
the judges of the Superior Court.

Mtre Joey Zukran
LPC Avocats
276 rue Saint-Jacques, Suite 801
Montréal, Québec, H2Y 1N3
Email: jzukran@lpclex.com
Website: www.lpclex.com

You may also contact the Claims Administrator:

Velvet Payments
5900 Andover Ave. Suite 1
Montreal, Quebec, H4T 1H5
Tel: 1-888-770-6892 (toll-free)
Email: ticketfx@velvetpayments.com



IMPORTANT DATES

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March 23, 2024
Foreign Exchange Reimbursements Distributed

--------------------------------------------------------------------------------

February 19, 2024
Claim Form Deadline

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September 13, 2023
Settlement Approval Hearing

--------------------------------------------------------------------------------

June 30, 2023
Objection Deadline

CLASS COUNSEL

--------------------------------------------------------------------------------


LPC Avocats
276 Saint-Jacques Street, Suite 801
Montreal, Quebec, H2Y 1N3
Tel: (514) 379-1572
Email: jzukran@lpclex.com

CLAIMS ADMINISTRATOR

--------------------------------------------------------------------------------


Velvet Payments
5900 Andover Ave. Suite 1
Montreal, Quebec
H4T 1H5
Tel: 1-888-770-6892 (toll free)
Email: ticketfx@velvetpayments.com


Step 1: Register your email
Step 2: Submit a claim form

You will be notified by e-mail when the claim form opens, following the
settlement approval hearing on February 15, 2023.
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