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Robbins Geller Rudman & Dowd LLP Announce Proposed Settlement in the Cyan Securities Litigation

January 31, 2019

SAN FRANCISCO--(BUSINESS WIRE)--Jan 31, 2019--The following statement is being issued by Robbins Geller Rudman & Dowd LLP regarding the Cyan Securities Litigation:

YOU ARE HEREBY NOTIFIED that a hearing will be held on June 5, 2019, at 9:00 a.m., before the Honorable A.C. Massullo at the Superior Court of California, County of San Francisco (the “Court”), located at 400 McAllister Street, San Francisco, CA 94102, to determine whether: (1) the proposed settlement (the “Settlement”) of the above-captioned action as set forth in the Amended Stipulation of Settlement (“Stipulation”) 1 for $15,000,000 in cash should be approved by the Court as fair, reasonable and adequate; (2) the Plan of Allocation should be approved by the Court as fair, reasonable and adequate; (3) to award Class Counsel attorneys’ fees and expenses out of the Settlement Fund (as defined in the Notice of Proposed Settlement of Class Action (“Notice”), which is discussed below); and (4) to pay Class Representatives’ service awards for the time and expenses they incurred in representing the Class out of the Settlement Fund.

This Action is a securities class action brought on behalf of those Persons who purchased or acquired the common stock of Cyan pursuant or traceable to the Registration Statement and Prospectus for Cyan’s May 9, 2013 initial public offering (“IPO”) and against Cyan, certain of its key executives, directors, and the underwriters of Cyan’s IPO (collectively, “Defendants”) for, among other things, allegedly misstating and omitting material facts from the Registration Statement filed with the U.S. Securities and Exchange Commission in connection with the IPO. Class Representatives allege that Defendants failed to adequately warn investors that Cyan revenue depended on two limited-life projects, a broadband stimulus project and a fiber-to-the-tower installation project, and that both projects were in the process of winding down. Class Representatives allege that these purportedly false and misleading statements inflated the price of the Company’s stock, resulting in damage to Class Members when the truth was revealed. Defendants deny all of Class Representatives’ allegations. Defendants expressly have denied and continue to deny all charges of wrongdoing or liability against them arising out of any of the conduct, statements, acts, or omissions alleged, or that could have been alleged, in the Action, and also have denied and continue to deny the allegations that Plaintiffs or Class Members have suffered damage, or were otherwise harmed by the conduct alleged in the Action. The Court has not ruled on the merits of Plaintiffs’ claims or Defendants’ defenses.

IF YOU PURCHASED OR ACQUIRED CYAN COMMON STOCK BETWEEN MAY 9, 2013 THROUGH AND INCLUDING NOVEMBER 4, 2013, YOUR RIGHTS WILL BE AFFECTED BY THE SETTLEMENT OF THIS ACTION.

To share in the distribution of the Net Settlement Fund, you must establish your rights by submitting a Proof of Claim and Release form (“Proof of Claim”) by mail (postmarked no later than May 24, 2019) or electronically (no later than May 24, 2019) at. Your failure to submit your Proof of Claim by May 24, 2019, will subject your claim to possible rejection and may preclude you from receiving any of the recovery in connection with the Settlement of this Action. If you are a member of the Class and did not request exclusion therefrom in connection with the Notice of Pendency of Class Action provided in 2015, you will be bound by the Settlement and any judgment and release entered in the Action, including, but not limited to, the Final Judgment, whether or not you submit a Proof of Claim. Class Counsel represents you and other Members of the Class. If you want to be represented by your own lawyer, you may hire one at your expense.

If you have not received a copy of the Notice, which includes the precise Class definition and exceptions to Class membership and more completely describes the Settlement and your rights thereunder (including your right to object to the Settlement), and a Proof of Claim, you may obtain these documents, as well as a copy of the Stipulation (which, among other things, contains definitions for the defined terms used in this Summary Notice), the other briefs and declarations submitted to the Court in support of preliminary approval of the Settlement, the Court’s Order Preliminarily Approving Settlement and Providing for Notice, and the operative complaint filed in the Action, online at www.CyanSecuritiesLitigation.com, or by writing to:

Cyan Securities Litigation c/o Gilardi & Co. LLC P.O. Box 404098 Louisville, KY 40233-4098

In addition, the papers in support of final approval of the Settlement will be posted to the website after they are filed on March 25, 2019.

Inquiries should NOT be directed to Defendants, the Court, or the Clerk of the Court.

Inquiries, other than requests for the Notice or for a Proof of Claim, may be made to a representative of Class Counsel:

ROBBINS GELLER RUDMAN & DOWD LLP Ellen Gusikoff Stewart 655 West Broadway, Suite 1900 San Diego, CA 92101 Telephone: 800/449-4900

ALL MEMBERS OF THE CLASS WHO DID NOT REQUEST EXCLUSION FROM THE CLASS IN 2015 WILL BE BOUND BY THE SETTLEMENT EVEN IF THEY DO NOT SUBMIT A TIMELY PROOF OF CLAIM.

IF YOU ARE A CLASS MEMBER, YOU HAVE THE RIGHT TO OBJECT TO THE SETTLEMENT, THE PLAN OF ALLOCATION, THE REQUEST BY CLASS COUNSEL FOR AN AWARD OF ATTORNEYS’ FEES AND EXPENSES, AND/OR THE PAYMENT TO CLASS REPRESENTATIVES FOR THEIR TIME AND EXPENSES. ANY OBJECTIONS MUST BE SENT TO CLASS COUNSEL SUCH THAT IT IS POSTMARKED NO LATER THANAPRIL 25, 2019, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE.

Questions? Call toll-free 1-866-276-1239 or visit www.CyanSecuritiesLitigation.com.

1 The Stipulation, and other relevant documents related to the Settlement can be viewed and/or obtained at www.CyanSecuritiesLitigation.com.

View source version on businesswire.com:https://www.businesswire.com/news/home/20190131005011/en/

CONTACT: Robbins Geller Rudman & Dowd LLP

Shareholder Relations

Rick Nelson

1-619-231-1058

KEYWORD: UNITED STATES NORTH AMERICA CALIFORNIA

INDUSTRY KEYWORD: PROFESSIONAL SERVICES LEGAL

SOURCE: Robbins Geller Rudman & Dowd LLP

Copyright Business Wire 2019.

PUB: 01/31/2019 11:00 AM/DISC: 01/31/2019 11:00 AM

http://www.businesswire.com/news/home/20190131005011/en

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