Kuhne v. Gossamer Bio, Inc. et al.

NOTICE OF (I) PENDENCY OF CLASS ACTION AND PROPOSED SETTLEMENT; (II) MOTION FOR AN AWARD OF ATTORNEYS' FEES AND REIMBURSEMENT OF LITIGATION EXPENSES; AND (III) SETTLEMENT HEARING

A Federal Court has authorized the Notice. This is not a solicitation from a lawyer.

Please read the Notice carefully. A $2.375 million settlement has been reached for investors in Gossamer Bio, Inc. stock between February 8, 2019, and December 13, 2019, inclusive (the "Class Period"), and/or who acquired Gossamer shares pursuant or traceable to Gossamer's Registration Statement and Prospectus in connection with the IPO (the "Class").

If you are a member of the Class, your legal rights will be affected whether you act or not.

Notice of Pendency of Class Action: Please be advised that your rights may be affected by the above-captioned securities class action (the "Action") pending in the United States District Court for the Southern District of California (the "Court"), if, during the period between February 8, 2019 and December 13, 2019, inclusive (the "Class Period"), you purchased or otherwise acquired Gossamer Bio, Inc. ("Gossamer" or the "Company") common stock, and/or acquired Gossamer shares pursuant or traceable to Gossamer's Registration Statement and Prospectus in connection with the IPO.¹

Notice of Amendment to Stipulation: Please also be advised that the Settling Parties filed an Amendment to Stipulation and Agreement of Class Action Settlement (the “Amendment”). The Amendment addresses an error in the Stipulation of Settlement and Exhibits previously filed in this Action. The Stipulation and its exhibits mistakenly referred to a Class Period that ran through December 13, 2020, rather than December 13, 2019, due to a typo in the original complaint filed in this Action. The Amendment addresses this typo and makes clear that the parties intended to settle claims only through December 13, 2019.

Notice of Settlement: Please also be advised that the Court-appointed Lead Plaintiff, on behalf of himself and the Class (as defined below), has reached a proposed settlement of this Action for $2,375,000 in cash that, if approved, would resolve all claims in the Action (the "Settlement").

Please read the Notice carefully. It explains important rights you may have, including the possible receipt of cash from the Settlement. If you are a member of the Class, your rights are affected whether or not you act.

If you have any questions about the Notice, the proposed Settlement, or your eligibility to participate in the Settlement, please do not contact Gossamer, any other Defendants in the Action, or their counsel. Questions should be directed to Class Counsel or the Claims Administrator.

This Notice relates to a proposed Settlement of claims in a pending Action brought by investors alleging, among other things, that Defendants violated the federal securities laws by making materially false and misleading statements in materials accompanying Gossamer's IPO and failed to disclose material adverse facts about the Company's business, operations, and compliance policies. The Defendants deny each and every claim and contention alleged in the Action and deny any misconduct or wrongdoing whatsoever. The proposed Settlement, if approved by the Court, will settle all claims of the Class, as defined above. See also FAQ #2 for more information.

Subject to Court approval, Lead Plaintiff, on behalf of himself and the Class, has agreed to settle the Action in exchange for a settlement payment of $2,375,000 in cash (the "Settlement Amount") to be deposited into an escrow account. The Net Settlement Fund (i.e., the Settlement Amount plus any and all interest earned thereon (the "Settlement Fund") less (i) the amount of the Fee and Expense Award and any award to Lead Plaintiff as allowed under the PSLRA, if and to the extent allowed by the Court; (ii) Notice and Administration Expenses; (iii) Taxes and Tax Expenses; and (iv) any other fees or expenses approved by the Court. The Net Settlement Fund will be distributed in accordance with a plan of allocation that is approved by the Court, which will determine how the Net Settlement Fund shall be allocated among members of the Class. See Page 8 of the Notice to read the proposed plan of allocation in more detail. The proposed Plan of Allocation can also be viewed here.

Based on Lead Plaintiff's damages expert's estimates of the number of shares of Gossamer common stock purchased during the Class Period that may have been affected by the matters at issue in the Action, and assuming that all Class Members elect to participate in the Settlement, the estimated average recovery (before the deduction of any Court-approved fees, expenses and costs as described herein) per eligible security is approximately 6 cents per share. Class Members should note, however, that the foregoing average recovery per share is only an estimate. Some Class Members may recover more or less than this estimated amount depending on, among other factors, when and at what prices they purchased/acquired or sold their Gossamer common stock and the total number of valid Claim Forms submitted. Distributions to Class Members will be made based on the Plan of Allocation set forth on Page 8 of the Notice or such other plan of allocation as may be ordered by the Court. The proposed Plan of Allocation can also be viewed here.

The Parties do not agree on the average amount of damages per share that would be recoverable if Lead Plaintiff was to prevail in the Action. Among other things, Defendants do not agree with the assertion that they violated the federal securities laws or that any damages were suffered by any members of the Class as a result of their conduct.

Lead Counsel, who have been prosecuting the Action on a wholly contingent basis since its inception in 2020, have not received any payment of attorneys' fees for their representation of the Class and have advanced the funds to pay expenses necessarily incurred to prosecute this Action. Court appointed Lead Counsel, Block & Leviton LLP, will apply to the Court for an award of attorneys' fees in an amount not to exceed 30% of the Settlement Fund. In addition, Lead Counsel will apply for reimbursement of Litigation Expenses paid or incurred in connection with the institution, prosecution, and resolution of the claims against the Defendants, in an amount not to exceed $60,000, which may include an application for reimbursement of the reasonable costs and expenses incurred by Lead Plaintiff directly related to his representation of the Class. Any fees and expenses awarded by the Court, or any Lead Plaintiff Award, shall be paid solely from the Settlement Fund and shall be paid to Lead Counsel, or with respect to a Lead Plaintiff Award, paid to Lead Plaintiff, within five days following an award ordered by the Court, provided that there has been final approval of the Stipulation of Settlement by the Court. If there is any appeal of an award of attorneys' fees and expenses, or of a Lead Plaintiff Award, Lead Counsel shall repay to the Settlement Fund any amount of attorneys' fees or expenses reversed on appeal. Class Members are not personally liable for any such fees or expenses. Estimates of the average cost per affected share of Gossamer common stock, if the Court approves Lead Counsel's fee and expense application, is 2 cents per eligible share.

Lead Plaintiff and the Class are represented by Block & Leviton LLP, 260 Franklin Street, Suite 1860, Boston, MA 02110. You may contact attorney Jacob A. Walker at jake@blockleviton.com, or at (617) 398-5600.

Lead Plaintiff's principal reason for entering into the Settlement is the substantial immediate cash benefit for the Class without the risk or the delays inherent in further litigation. Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after motions for class certification, summary judgment, a trial of the Action, and the likely appeals that would follow a trial. This process could be expected to last several years. Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation.

Your Legal Rights and Options in the Settlement
Submit a claim. Submit a Claim Form postmarked no later than July 7, 2022.	This is the only way to be eligible to receive a payment from the Settlement Fund. If you are a Class Member and you remain in the Class, you will be bound by the Settlement as approved by the Court and you will give up any Released Claims (as defined on pages 5-6 of the Notice) that you have against Defendants and the other Released Defendant Parties (as defined on pages 5-6 of the Notice), so it is in your interest to submit a Claim Form.
Exclude yourself. Exclude yourself from the Class by submitting a written exclusion so that it is received by no later than June 3, 2022.	If you exclude yourself from the Class, you will not be eligible to receive any payment from the Settlement Fund. This is the only option that allows you ever to be part of any other lawsuit against any of the Defendants or the other Released Defendant Parties concerning the Released Claims.
Object. Object to the Settlement by submitting a written objection so that it is received no later than June 3, 2022.	If you do not like the proposed Settlement, the proposed Plan of Allocation, or the request for attorneys' fees and reimbursement of Litigation Expenses, you may write to the Court and explain why you do not like them. You cannot object to the Settlement, the Plan of Allocation or the fee and expense request unless you are a Class Member and do not exclude yourself from the Class.
Appear at a hearing. Attend a hearing on June 24, 2022 and file a Notice of Intention to Appear so that it is received no later than June 3, 2022.	Filing a written objection and notice of intention to appear by June 3, 2022, allows you to speak in Court, at the discretion of the Court, about the fairness of the proposed Settlement, the Plan of Allocation, and/or the request for attorneys' fees and reimbursement of Litigation Expenses. 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.
Do nothing.	If you are a member of the Class and you do not submit a valid Claim Form, you will not be eligible to receive any payment from the Settlement Fund. You will, however, remain a member of the Class, which means that you give up your right to sue about the claims that are resolved by the Settlement, and you will be bound by any judgments or orders entered by the Court in the Action.

Gossamer Securities Litigation Settlement
c/o Claims Administrator
1650 Arch Street, Suite 2210
Philadelphia, PA 19103
1-833-554-0994
www.GossamerSecuritiesLitigation.com
info@GossamerSecuritiesLitigation.com

Block & Leviton LLP
Attn: Jacob A. Walker
260 Franklin Street, Suite 1860
Boston, MA 02110
Telephone: (617) 398-5600
Email: jake@blockleviton.com