Opendoor Technologies Loss Submission Form

Company: Opendoor Technologies Incorporated

Ticker: (NASDAQ) OPEN

Deadline

Passed

Lead Plaintiff Deadline: December 06, 2022

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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 Opendoor Technologies Incorporated 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,



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.

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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 Opendoor Technologies Incorporated. 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.

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Class Definition

(a) securities between December 21, 2020 and September 16, 2022; (b) common stock pursuant and/or traceable to documents issued in connection with the business combination between the Company and Opendoor Labs Inc. completed on or about December 18, 2020; (c) Opendoor common stock pursuant and/or traceable to the documents issued in connection with the Company’s secondary public offering that was completed on or about February 9, 2021; and/or (d) Opendoor common stock pursuant and/or traceable to the documents issued in connection with the Company’s secondary public offering that was completed on or about September 17, 2021

Allegations

(i) the algorithm used by the Company to make offers for homes could not accurately adjust to changing house prices across different market conditions and economic cycles; (ii) as a result, the Company was at an increased risk of sustaining significant and repeated losses due to residential real estate pricing fluctuations; (iii) accordingly, defendants overstated the purported benefits and competitive advantages of the algorithm; (iv) as a result, documents issued in connection with the merger between the Company and Opendoor Labs Inc. and defendants’ public statements throughout the class period were materially false and/or misleading and failed to state information required to be stated therein.

Eligibility

In order to be included in the lawsuit, you must have incurred a loss on shares of Opendoor purchased or acquired during the class period listed above and/or pursuant to the stock offering(s) referenced above.

Lead Plaintiff Deadline

If you suffered a loss in Opendoor during the relevant time frame or pursuant to the relevant offering(s), you have until December 06, 2022 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.