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IHC Stockholder Litigation

1-877-354-3840

This official website is maintained by the Settlement Administrator under the supervision of the Plaintiff’s Counsel for Class Members in the Stockholder Class Action entitled Lawrence Bass v. Geneve Holdings, Inc. et al., C.A. No. 2022-0778-JTL (Delaware Court of Chancery)

The information contained on this web page is only a summary of information presented in more detail in the Notice of Pendency and Proposed Settlement of Stockholder Class Action, Settlement Hearing, and Right to Appear, which you can access by clicking here. Because this website is just a summary, you should review the Notice for additional details.

Notice of Pendency of Class Action: Please be advised that your rights will be affected by the above-captioned stockholder class action (the “Action”) pending in the Court of Chancery of the State of Delaware (the “Court”) if you were a record holder or beneficial owner of Independence Holding Company (“IHC” or the “Company”) common stock (NYSE: “IHC”) whose shares were exchanged for or who had the right to receive in exchange $57.00 per share in cash on February 15, 2022.

Notice of Settlement: Please also be advised that (i) Plaintiff Lawrence Bass (“Plaintiff”), individually and on behalf of the Class (defined in Paragraph 18 below); (ii) Geneve Holdings, Inc. (“Geneve”), Steven B. Lapin (“Lapin”), Roy T.K. Thung (“Thung”), and Teresa Herbert (“Herbert”) (collectively, “Defendants”); and (iii) Independence Holding Company (“IHC”) (and together with Plaintiff and Defendants, the “Settling Parties,” and each a “Settling Party”) have reached a proposed settlement for $11,000,000.00 in cash (the “Settlement”).  The proposed Settlement, if approved, will resolve all claims in the Action against Defendants, and the Action will be dismissed with prejudice.

If you are a member of the Class, you are subject to the Settlement. The Class preliminarily certified by the Court consists of:

All record holders and beneficial owners of shares of IHC common stock whose shares were exchanged for or who had the right to receive in exchange $57.00 per share in cash at the Closing of the Transaction, including each such Class Member’s heirs, successors in interest, successors, transferees, and assigns.

Excluded from the Class are: (i) each Defendant, (ii) any person who was a Geneve officer or director at Closing, (iii) members of the Immediate Family of any of the foregoing, and (iv) any entity in which any of the Defendants has a controlling interest (each of (i)-(iv), an “Excluded Person”).

The Settling Parties estimate that the Class consists of approximately 4.9 million shares.

Please Note: The Class is a non-“opt-out” class pursuant to Delaware Court of Chancery Rules 23(a), 23(b)(1), and 23(b)(2).  Accordingly, Class Members do not have the right to exclude themselves from the Class.

PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY. This Notice explains how members of the Class will be affected by the Settlement. 

If you have questions, you may call the IHC Stockholder Litigation Help Line at 1-877-354-3840 or email info@IHCStockholderLitigation.com

CLASS MEMBERS’ LEGAL RIGHTS IN THE SETTLEMENT
Description Due Date

RECEIVE A PAYMENT FROM THE SETTLEMENT. CLASS MEMBERS DO NOT NEED TO SUBMIT A CLAIM FORM.

If you are a member of the Class (defined in paragraph 18 of the Notice), you may be eligible to receive a pro rata distribution from the Net Settlement Fund. Eligible Class Members (defined in paragraph 29 of the Notice) do not need to submit a claim form in order to receive a distribution from the Net Settlement Fund, if the Settlement is approved by the Court. Your distribution from the Net Settlement Fund will be paid to you directly.  See paragraphs 29-32 in the Notice for further discussion.

OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN FEBRUARY 27, 2025.

If you are a member of the Class and would like to object to the proposed Settlement, the proposed Plan of Allocation, or Plaintiff’s Counsel’s request for an award of attorneys’ fees and expenses, you may write to the Court and explain the reasons for your objection.

ATTEND A HEARING ON MARCH 14, 2025, AT 11:00 A.M., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN FEBRUARY 27, 2025.

Filing a written objection and notice of intention to appear that is received by February 27, 2025, allows you to speak in Court, at the discretion of the Court, about your objection.  In the Court’s discretion, the March 14, 2025, hearing may be conducted by telephone or video conference (see paragraphs 38-39 in the Notice). If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection.