SCHWARTZ V. LATCH, INC. ET AL.

SCHWARTZ V. LATCH, INC. ET AL.
CIVIL ACTION NO. 1:23-CV-00027-WCB
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE


All persons and entities who or which were stockholders of pre-merger Latch, Inc. (“Legacy Latch”) and purchased or otherwise acquired Latch, Inc. (“Latch” or the “Company”) common stock pursuant to the registration statement filed in connection with Latch’s June 4, 2021 merger with TS Innovation Acquisitions, Inc. (“TSIA”) and were allegedly damaged thereby (the “Settlement Class”).

IF YOU ARE A MEMBER OF THE SETTLEMENT CLASS, YOUR RIGHTS WILL BE AFFECTED BY THE PROPOSED SETTLEMENT AND YOU MAY BE ENTITLED TO A MONETARY PAYMENT.

Pursuant to Federal Rule of Civil Procedure 23 and an Order of the United States District Court for the District of Delaware, that the Court-appointed Lead Plaintiff, Scott Schwartz, on behalf of himself and all members of the Settlement Class, and Latch, Luke Schoenfelder, Robert J. Speyer, Paul A. Galiano, Jenny Wong, Joshua Kazam, Jennifer Rubio, Ned Segal, Michaelangelo Volpi, Peter Campbell, Tricia Han, Raju Rishi, J. Allen Smith, and Andrew Sugrue (“Individual Defendants” and, together with Latch, “Defendants” and, together with Lead Plaintiff, the “Parties”), have reached a proposed settlement of the claims in the above-captioned class action (the “Action”) in the amount of $1,950,000 (the “Settlement”).

A hearing will be held before the Honorable William C. Bryson on December 9, 2025 at 10:00 a.m., via Zoom, where the Court will consider whether: (i) the Settlement is fair, reasonable, and adequate, and should be finally approved; (ii) the Plan of Allocation is fair and reasonable, and should be approved; and (iii) Lead Counsel’s application for attorneys’ fees and expenses and Lead Plaintiff’s service awards are reasonable and should be approved. The Court may change the date of the Settlement Hearing, or hold it telephonically or via videoconference, without providing another notice. You do NOT need to attend the Settlement Hearing to receive a distribution from the Net Settlement Fund.

If you are a Settlement Class Member, to be eligible to share in the distribution of the Net Settlement Fund, you must submit a Claim Form postmarked or submitted online no later than November 10, 2025. If you are a Settlement Class Member and do not timely submit a valid Claim Form, you will not be eligible to share in the distribution of the Net Settlement Fund, but you will nevertheless be bound by all judgments or orders entered by the Court in the Action.

If you are a Settlement Class Member and wish to exclude yourself from the Settlement Class, you must submit a written request for exclusion in accordance with the instructions set forth in the Notice such that it is received no later than November 9, 2025. If you validly exclude yourself from the Settlement Class, you will not be bound by any judgments or orders entered by the Court in the Action, whether favorable or unfavorable, and you will not be eligible to share in the distribution of the Net Settlement Fund.

Any objections to the proposed Settlement, Lead Counsel’s application for attorneys’ fees and expenses, and/or the proposed Plan of Allocation must be filed with the Court, either by mail or in person, and be mailed to counsel for the Parties in accordance with the instructions in the Notice, such that they are received no later than November 18, 2025.