GDS Holdings Lawsuit Submission Form

Company: GDS Holdings Limited

Ticker: (NASDAQ) GDS

Deadline

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Lead Plaintiff Deadline: August 21, 2023

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Certification of Plaintiff Pursuant to Federal Securities Laws

I, duly certify and say, as to the claims asserted under the federal securities laws, that:

1. I have reviewed a complaint filed in the action.

2. I did not purchase the security that is the subject of this action at the direction of plaintiff's counsel or in order to participate in this action.

3. I am willing to serve as a representative party on behalf of the class, including providing testimony at deposition and trial, if necessary.

4. My transaction(s) in GDS Holdings Limited which are the subject of this litigation during the class period set forth in the complaint are set forth in the chart attached hereto.

5. Within the last 3 years,

I have not sought to serve nor have I served as a class representative in any federal securities fraud case.
I have sought to serve as a class representative in

6. I will not accept any payment for serving as a representative party on behalf of the class beyond the Plaintiff's pro rata share of any recovery, except as ordered or approved by the court, including any award for reasonable costs and expenses (including lost wages) directly relating to the representation of the class.

Are you US Citizen?

Yes. I certify under penalty of perjury that the foregoing is true and correct. Executed this
No. I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this

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Signed pursuant to California Civil Code Section 1633.1, et seq. - and the Uniform Electronic Transactions Act as adopted by the various states and territories of the United States.

By your signature above, you confirm that have retained Levi & Korsinsky, LLP to represent you and the shareholder class as a lead plaintiff in the pending class action against GDS Holdings Limited. This representation will be on a contingency basis, meaning that Levi & Korsinsky will advance all expenses in the litigation and will only seek compensation and/or reimbursement of expenses if the firm obtains a recovery. Regardless of the result, we will never ask you to directly pay for any attorneys’ fees, expenses, or costs. Should we obtain a favorable result, we may ask the court to award us compensation and reimbursement of expenses to be paid by the defendants or as a portion of any class recovery. In exchange for our representation, you agree to cooperate as our client by providing, for example, relevant documents and deposition testimony, if necessary. During the course of this litigation, we may employ and/or work with other law firms, experts, and third-parties to successfully prosecute this action. If you are not appointed as the lead plaintiff or Levi & Korsinsky is not appointed as lead counsel, we will notify you of such decision at which time this representation will end unless otherwise extended by you and the firm. We look forward to working with you towards a successful resolution of this action.

I have reviewed the complaint linked in paragraph 1

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Thank you for completing your submission. If our attorneys find you are a viable candidate for lead plaintiff they will reach out regarding the next steps.

All shareholders who submit will receive updates regarding the case.

Class Period

Begins

Apr 2021

Ends

Apr 2023

April 12, 2021 - April 03, 2023

Allegations

The filed complaint alleges that GDS Holdings Limited made materially false and/or misleading statements and/or failed to disclose that: (1) Defendant and GDS CEO William Wei had engaged in undisclosed pre-paid forward sale contract transactions as early as May 2020; (2) this presented a risk of Defendant Huang’s ownership going below 5% of the Company’s outstanding shares; (3) if Huang’s ownership dipped below 5%, it would result in a change of control of the Company which, as the Company admitted, could result in disastrous consequences; and (4) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.

Eligibility

In order to be included in the lawsuit, you must have incurred a loss on shares of GDS Holdings, either: A) purchased or acquired during the class period listed above, if applicable; or B) pursuant to the Initial Public Offering (IPO) of GDS Holdings, if applicable.

Lead Plaintiff Deadline

If you suffered a loss in GDS Holdings during the relevant time frame, or pursuant to GDS Holdings’s IPO if listed above, you have until August 21, 2023 to request that the Court appoint you as lead plaintiff. Your ability to share in any recovery doesn't require that you serve as a lead plaintiff.