PayPal Lawsuit Loss Submission Form

(1) defendants had inflated the Company’s vitally important Net New Active Accounts metric guidance through an usually large use of marketing campaigns that were easily susceptible to fraud; i.e. the creation of millions of illegitimate accounts which were created for the sole purpose of taking advantage of cash incentives for account creation; (2) defendants used these marketing campaigns and other incentives to hide the Company’s true churn rate and declining levels of engagement with the platform; and (3) as a result, defendants’ positive statements about the Company’s business, operations, and prospects were materially false and misleading and /or lacked a reasonable basis at all relevant times.