Grant & Eisenhofer P.A. Announce a Notice of Pendency and Proposed Class Action For All Record and Beneficial Holders of GORES Holdings IV, Inc., Class A Common Stock, Who Purchased, Acquired, Or Held Such Securities at any Time During The Period From September 22, 2020 Through January 21, 2021

WILMINGTON, Del., May 19, 2025 /PRNewswire/ -- 

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

SUMMARY NOTICE OF PENDENCY AND PROPOSED

SETTLEMENT OF STOCKHOLDER CLASS ACTION,

SETTLEMENT HEARING, AND RIGHT TO APPEAR

THIS NOTICE WAS AUTHORIZED BY THE COURT. IT IS NOT A LAWYER SOLICITATION. PLEASE READ THIS SUMMARY NOTICE CAREFULLY. YOUR RIGHTS WILL BE AFFECTED BY A CLASS ACTION LAWSUIT PENDING IN THIS COURT.

YOU ARE HEREBY NOTIFIED, pursuant to an Order of the Court of Chancery of the State of Delaware (the "Court") and Delaware Court of Chancery Rule 23 that:  (i) the above-captioned action (the "Action") is pending in the Court and has been preliminarily certified as a class action; and (ii) Plaintiffs, Defendants, and non-party UWM Holdings Corp. (f/k/a Gores Holdings IV, Inc.) (the "Company") have reached a proposed settlement for $17,500,000.00 in cash (the "Settlement Amount") as set forth in the Stipulation (the "Settlement"), a copy of which is available at www.GoresIVStockholderSettlement.com. The Settlement, if approved by the Court, will resolve all claims in the Action.

A hearing (the "Settlement Hearing") will be held on July 15, 2025, at 1:30 p.m., before The Honorable Lori W. Will, Vice Chancellor, either in person at the Court of Chancery of the State of Delaware, Leonard L. Williams Justice Center, 500 North King Street, Wilmington, Delaware 19801, or remotely by telephone or videoconference (in the discretion of the Court), to, among other things:  (i) determine whether to finally certify the Class for settlement purposes only, pursuant to Court of Chancery Rules 23(a), 23(b)(1), and 23(b)(2); (ii) determine whether Plaintiffs and Plaintiffs' Counsel have adequately represented the Class, and whether Plaintiffs should be finally appointed as Class representatives for the Class and Plaintiffs' Counsel should be finally appointed as counsel for the Class; (iii) determine whether the proposed Settlement should be approved as fair, reasonable, and adequate to the Class and in the best interests of the Class; (iv) determine whether the Action should be dismissed with prejudice and the Releases provided under the Stipulation should be granted; (v) determine whether the Order and Final Judgment approving the Settlement should be entered; (vi) determine whether the proposed Plan of Allocation of the Net Settlement Fund is fair and reasonable, and should therefore be approved; (vii) determine whether and in what amount any Fee and Expense Award should be paid to Plaintiffs' Counsel out of the Settlement Fund and whether and in what amount any service award to each named Plaintiff should be paid out of the Fee and Expense Award; (viii) hear and rule on any objections to the Settlement, the proposed Plan of Allocation, and/or Plaintiffs' Counsel's application for any Fee and Expense Award; and (ix) consider any other matters that may properly be brought before the Court in connection with the Settlement. Any updates regarding the Settlement Hearing, including any changes to the date or time of the hearing or updates regarding in-person or remote appearances at the hearing, will be posted to the Settlement website, www.GoresIVStockholderSettlement.com.

If you are a member of the Class, your rights will be affected by the pending Action and the Settlement, and you may be entitled to share in the Net Settlement Fund. If you have not yet received the Notice, you may obtain a copy of the Notice by contacting the Settlement Administrator at Gores IV Stockholder Litigation, c/o A.B. Data, Ltd., P.O. Box 170500, Milwaukee, WI 53217. A copy of the Notice can also be downloaded from the Settlement website, www.GoresIVStockholderSettlement.com.

If the Settlement is approved by the Court and the Effective Date occurs, the Net Settlement Fund will be distributed on a pro rata basis to Eligible Class Members in accordance with the terms of the proposed Plan of Allocation stated in the Notice or such other plan of allocation as is approved by the Court. 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 will be bound by any judgment entered in the Action pursuant to the terms and conditions of the Stipulation.

Any objections to the Settlement, the proposed Plan of Allocation, or Plaintiffs' Counsel's application for the Fee and Expense Award must be filed with the Register in Chancery in the Court of Chancery of the State of Delaware and delivered to Plaintiffs' Counsel, Defendants' Counsel, and counsel for the Company such that they are received no later than June 23, 2025, in accordance with the instructions set forth in the Notice.

Please do not contact the Court or the Office of the Register in Chancery regarding this Summary Notice. All questions about this Summary Notice, the Settlement, or your eligibility to participate in the Settlement should be directed to the Settlement Administrator or Plaintiffs' Counsel.

Requests for the Notice should be made to the Settlement Administrator:

Gores IV Stockholder Litigation

c/o A.B. Data, Ltd.

P.O. Box 170500

Milwaukee, WI  53217

1-877-495-0904

Website: www.GoresIVStockholderSettlement.com

Inquiries, other than requests for the Notice, should be made to Plaintiffs' Counsel:

Kelly L. Tucker

Grant & Eisenhofer P.A.

123 Justison Street

Wilmington, DE 19801

Telephone: (302) 622-7000

Email: ktucker@gelaw.com

BY ORDER OF THE COURT OF

CHANCERY OF THE STATE OF

DELAWARE:

Dated: May 15, 2025

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SOURCE Grant & Eisenhofer P.A.