The Settlement includes all persons or entities who purchased or acquired shares of Groupon Inc (NASDAQ: GRPN) class A common stock, par value $0.0001 per share, in or traceable to Groupon Inc's Initial Public Offering (IPO) between November 4, 2011 and March 30, 2012 AND all such persons or entities who purchased or acquired shares of Groupon Inc (NASDAQ: GRPN) common stock between February 9, 2012 and March 30, 2012.

July 13, 2016 - The court approved the settlement.

April 8, 2016 - The court preliminarily approved the settlement.

March 25, 2016 - Parties filed a stipulation of settlement.

November 14, 2013 - The court granted the lead plaintiff's motion to withdraw count II of the consolidated complaint.

November 6, 2013 - The lead plaintiff filed a motion to withdraw count II of the consolidated complaint.

September 18, 2013 - The court denied the defendants' motion to dismiss.

January 18, 2013 - The defendants filed a motion to dismiss.

October 29, 2012 - The lead plaintiff filed an amended consolidated complaint on behalf of all persons who purchased or otherwise acquired the common stock of Groupon Inc between February 8, 2012 and March 30, 2012, and/or who acquired shares of Groupon Inc common stock pursuant or traceable to its Registration Statement and Prospectus issued in connection with its November 4, 2011 initial public offering (“IPO”), that Groupon Inc and certain of its officers and directors violated the Securities Act of 1933 and the Securities Exchange Act of 1934.

August 28, 2012 - The lead plaintiff and lead counsel were appointed and all cases were consolidated.

June 4, 2012 - Lead plaintiff motions were filed.

April 3, 2012 - Another investor filed a complaint.

April 3, 2012 - An investor in shares of Groupon Inc (NASDAQ: GRPN) filed a lawsuit in the U.S. District Court for the Northern District of Illinois against Groupon Inc over alleged violations of Federal Securities Laws in connection with certain allegedly false and misleading statements made between November 4, 2011 and March 30, 2012.

According to the complaint the plaintiff alleges on behalf of all persons who purchased or otherwise acquired the common stock of Groupon Inc between November 4, 2011 and March 30, 2012, and/or who acquired shares of Groupon Inc common stock pursuant or traceable to its Registration Statement and Prospectus issued in connection with its November 4, 2011 initial public offering (“IPO”), that Groupon Inc and certain of its officers and directors violated the Securities Act of 1933 and the Securities Exchange Act of 1934. Specifically, the plaintiff alleges, that between November 4, 2011 and March 30, 2012 defendants issued allegedly materially false and misleading statements regarding Groupon Inc’s business practices and financial result and/or defendants allegedly failed to disclose negative trends in Groupon Inc’s business and made false statements as to Groupon Inc’s financial results.

On November 3, 2011, Groupon Inc announced the pricing of its IPO of 35 million shares of common stock at $20 per share.

The plaintiff alleges that as part of the Prospectus and Registration Statement issued in connection with the November 4, 2011 IPO and November 4, 2011 and March 30, 2012, defendants represented that Groupon Inc had competitive advantages which would benefit its business and reported financial results which showed dramatic growth.

However, in February 2012, Groupon Inc reported its first earnings report since going public in November for the fourth quarter ended December 31, 2011. Groupon Inc reported that revenue increased 194% to $506.5 million in the fourth quarter compared to the fourth quarter of 2010, but also reported a net loss of $42.7 million, or 8 cents per share.

Then on March 30, 2012, Groupon Inc announced that it was revising its fourth quarter financial results for the year ending on December 31, 2011. Groupon Inc said that the revisions have an impact on both revenue and cost of revenue. As a result of the announced revisions, the Company's fourth quarter 2011 revenue was reduced by $14.3 million. In addition, Groupon Inc's fourth quarter operating income was reduced by $30.0 million, its net income by $22.6 million, and its earnings per share by $0.04.

In connection with an audit of Groupon Inc's financial statements for the year ended December 31, 2011 by its auditor, Ernst & Young LLP, Groupon Inc also said that “in conjunction with the completion of the audit of Groupon's financial statements for the year ended December 31, 2011 by its independent auditor, Ernst & Young LLP, the Company included a statement of a material weakness in its internal controls over its financial statement close process in its Annual Report on Form 10-K for year ended December 31, 2011.

On April 3, 2012, a media report said that according to a person familiar with the situation the Securities and Exchange Commission is examining Groupon Inc’s revision of its first set of financial results as a publicly traded company.

Shares of Groupon Inc (NASDAQ: GRPN), that traded on November 18, 2011 as high as $26.19 closed on April 3, 2012 at $15.02 per share.