MEMORANDUM -...

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2 8 NOV . 2016 NOTICE OF CLASS ACTION MEMORANDUM DATE: NOVEMBER 18, 2016 SECURITY DESCRIPTION: AlO NETWORKS INC. ISIN: US0021211018 HEARING DATE: JANUARY 13, 2017 EXCLUSION DATE: DECEMBER 14, 2016 PROOF OF CLAIM DEADLINE: FEBRUARY 10, 2017 Enclosed for your consideration is a Notice of Pendency of Class Action, Proposed Settlement of Class Action, and Proof of Claim involving the above-mentioned security. Kindly note that if you wish to participa te in the settlement please complete the enclosed Proof of Claim and forn,ard it together with any Supporting documentation if required , postmarked no la ter than FEBRUARY 10, 2017, to one of the following address: CLAIMS ADMINISTRATOR: AlO Securities Litigation Claims Administrator CIO A.B. Data Ltd Post Office Box 173012 Milwaukee, WI 53217 Website: www.Al0Securitiessettlement.com Telephone: 877-241-7503 Email: [email protected] Contact your account representative if you require additional information relating to activity within your account during the class action period. Kind Regards, Corporate Actions/Reorganization Department

Transcript of MEMORANDUM -...

Page 1: MEMORANDUM - liquidator-bpes.chliquidator-bpes.ch/files/Notice-of-class-action-A10-Netwroks-inc..pdf · 2 8 NOV. 2016 NOTICE OF CLASS ACTION MEMORANDUM DATE: NOVEMBER 18, 2016 SECURITY

2 8 NOV. 2016

NOTICE OF CLASS ACTION MEMORANDUM

DATE: NOVEMBER 18, 2016

SECURITY DESCRIPTION: AlO NETWORKS INC.

ISIN: US0021211018

HEARING DATE: JANUARY 13, 2017

EXCLUSION DATE: DECEMBER 14, 2016

PROOF OF CLAIM DEADLINE: FEBRUARY 10, 2017

Enclosed for your consideration is a Notice of Pendency of Class Action, Proposed Settlement of Class Action, and Proof of Claim involving the above-mentioned security. Kindly note that if you wish to participa te in the settlement please complete the enclosed Proof of Claim and forn,ard it together with any Supporting documentation if required, postmarked no la ter than FEBRUARY 10, 2017, to one of the following address:

CLAIMS ADMINISTRATOR: AlO Securities Litigation Claims Administrator CIO A.B. Data Ltd Post Office Box 173012 Milwaukee, WI 53217 Website: www.Al0Securitiessettlement.com Telephone: 877-241-7503 Email: [email protected]

Contact your account representative if you require additional information relating to activity within your account during the class action period.

Kind Regards, Corporate Actions/Reorganization Department

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Page 3: MEMORANDUM - liquidator-bpes.chliquidator-bpes.ch/files/Notice-of-class-action-A10-Netwroks-inc..pdf · 2 8 NOV. 2016 NOTICE OF CLASS ACTION MEMORANDUM DATE: NOVEMBER 18, 2016 SECURITY

, SUPERIOR COURT OF THE STATE OF CALIFORNTA

COUNTY OF SANTA CLARA

ln re A 10 NETWORKS, INC. SHAREHOLDER LITIGATION

Lead Case No. l-15-CV-276207 CLASS ACTION

This Document Relates To : ALL ACTIONS.

Assigned for Ali Purposes to the Honorable Peter H. Kirwan Dept. 1 Date Action Filed: 01 /29/15

NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION

TO: ALL PERSONS OR ENTITIES ("PERSONS") THAT PURCHASED OR OTHERWISE ACQUIRED AIO NETWORKS, INC. ("AIO" OR THE "COMPANY") COMMON STOCK PURSUANT AND/OR TRACEABLE TO THE REGISTRATION STATEMENT AND PROSPECTUS FOR THE COMPANY'S MARCH 21, 2014 INITIAL PUBLIC OFFERING ("IPO")

THIS NOTICE W AS AUTHORIZED BY THE COURT. 1T IS NOT A LA WYER SOLICITATION. PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY.

WHY SHOULD I READ THIS NOTICE?

This Notice is given pursuant to an order issued by the Superior Court ofCalifornia, County of Santa Clara (the "Court"). This Notice serves to inforrn you of the proposed settlement of the above class action lawsuit (the "Settlement") for $9,837,500 in cash and the hearing (the "Settlement Fairness Hearing") to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement, as set forth in the Stipulation ofSettlement dated June 30, 2016 (the "Stipulation"). 1 The Stipulation is by and between: (i) Plaintiffs City of Warren Police and Fire Retirement System, Arkansas Teacher Retirement System, and Michael Kaveney (on behalf of themselves and each of the Class Members), by and through their counsel of record; and (ii) Defendants A 10, Lee Chen, Greg Straughn, Robert Cochran, Peter Y. Chung, Alan S. Henricks, Phillip J. Salsbury (the "Jndividual Defendants"), Morgan Stanley & Co. LLC, Merrill Lynch, Pierce, Fenner & Smith lncorporated, J.P . Morgan Securities LLC, RBC Capital Markets LLC, Pacifie Crest Securities LLC, and Oppenheimer & Co. Inc. (the "Underwriter Defendants" and collectively, the "Defendants"), by and through their respective counsel ofrecord in the above-captioned action (the "Litigation"). Upon and subject to the terms and conditions hereof, Plaintiffs, on behalfofthemselves and the Class, on the one hand, and each of the Defendants, on the other hand (collectively, "Settling Parties"), intend this Settlement to be a final and complete resolution of ail disputes between the Settling Parties with respect to the Litigation. This Notice is not an expression of any opinion by the Court as to the merits of the claims or defenses asserted in the lawsuit.

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YOUR LEGAL R1GHTS AND OPTIONS IN THIS SEITLEMENT: ,,,. ·,.

SUBMIT A CLAIM FORM POSTMARKED OR The only way to get a payment. RECEIVEDNO LATER THAN FEBRUARY 10,2017.

EXCLUDE YOURSELF FROM THE CLASS BY Get no payment. This is the only option that allows you to ever be SUBMITTING A WRITI'EN REQUEST FOR part of any other lawsuit against the Defendants and their Related EXCLUSION POSTMARKED NO LATER THAN Persons about the claims in this case. DECEMBER 14, 2016.

OBJECT TO THE SETTLEMENT BY SUBMITTING A Write to the Court about why you don't like the Settlement. WRITTEN OBJECTION POSTMARKED NO LATER THAN DECEMBER 14, 2016.

GO TO A HEARING ON JANUARY 13, 2017, AT Ask to speak in Court about the fairness of the Settlement. 9:00 A.M.

DO NOTHING. Get no payment. Give up rights .

• These rights and options - and the deadlines to exercise them - are explained in this Notice.

• The Court in charge of this case still has to decide whether to approve the Settlement. Payments will be made if the Court approves the Settlement and after appeals are resolved . Please be patient.

1The Stipulation and ail of its Exhibits can be viewed at www.AIOsecuritiessettlement.com. Ali capitalized terms used herein have the same meanings as the terms defined in the Stipulation .

QUESTIONS? CALL 877-241-7503 OR VISIT WWW.AIOSECURITIESSETTLEMENT.COM PAGE 1 OF7

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WHAT IS THIS LAWSUIT ABOUT?

The Allegations and Status of the Case

On January 29, 2015, City of Warren Police and Fire Retirement System filed a complaint for violations of federal securities laws against Defendants. Two related cases, making substantially similar allegations, were subsequently filed in this Court, captioned Arkansas Teacher Retirement System v. AJO Networks, Inc., et al., Case No. 1-l 5-cv-278575 and Kaveney v. A 10 Networks, !ne. , et al., Case No. l- l 5-cv-279006. On June 1, 2015, the Court entered an Order Relating and Consolidating Cases and Appointing Counsel to Lead Efforts and Coord inate Communications Between Plaintiffs and Defendants.

Plaintiffs, who purchased A 10 common stock issued in connection with A 1 O's IPO on or about March 21, 2014, alleged that Defendants issued a rnaterially false and misleading Registration Statement and Prospectus that misled investors regarding Al O's revenue growth and increased demand for its products. Defendants deny that the Registration Statement and Prospectus contained any untrue statement of a material factor ornitted to state a material fact required to be stated therein or necessary to make the statements therein not misleading. Plaintiffs' Consolidated Class Action Complaint for Violations of the Securities Act of 1933 (the "Complaint") was filed on June 30, 2015 .

On July 31, 2015, Defendants filed a joint demurrer to the Complaint arguing a failure to state facts sufficient to constitute a cause of action. ln addition, AI O and the Individual Defendants filed a motion to strike. Plaintiffs filed their oppositions to both motions on August 31 , 2015 . The Court heard argument on November 6,2015, and on November 12, 2015, the Court issued its Order Re: ( 1) Demurrer to the Complaint; (2) Motion to Strike Portions of the Complaint. The November 12, 2015, Orcier overruled the motion to strike in its entirety and overruled the demurrer except with regard to Plaintiffs' § l 2(a)(2) claim as asserted against A 10, finding that Plaintiffs had not sufficiently alleged that A 10 was a statutory "seller," and granted Plaintiffs leave to amend. On November 23, 2015, Plaintiffs filed their First Amended Consolidated Class Action Complaint for Violations of the Securities Act of 1933 (the "Amended Complaint").

On January 8, 2016, Defendants answered the Amended Complaint, generally denying the allegations and asserting various affirmative defenses.

The parties thereafter agreed to attend a mediation session conducted by a third-party neutral, the Hon. Layn R. Phillips (Ret.). Plaintiffs and Defendants submitted and exchanged mediation statements summarizing their respective positions. The mediation session was held on March 22, 2016. While the Settling Parties did not reach an agreement to settle the Litigation at the mediation, the Settling Parties continued their negotiations through Judge Phillips. These efforts culminated with the Settling Parties agreeing to settle the Litigation for $9,837,500 in cash .

THE COURT HAS NOT RU LED ASTO WH ETHER DEFENDANTS ARE LIABLE TO PLAINTIFFS ORTO THE CLASS. THIS NOTICE IS NOT INTENDED TO BE AN EXPRESSION OF ANY OPINION BY THE COURT WITH RESPECT TO THE TRUTH OF THE ALLEGATIONS IN THIS LA WSUIT OR THE MERITS OF THE CLAI MS OR DEFENSES ASSERTED. THIS NOTICE IS SOLELY TO ADVISE VOU OF THE PENDENCY OF THE LITIGA TION AND PROPOSED SETTLEMENT THEREOF AND YOUR RIGHTS IN CONNECTION WITH THAT SETTLEMENT.

HOW DO I KNOW IF I AM A CLASS MEMBER?

lfyou purchased or otherwise acquired the common stock of A 10 pursuant and/or traceable to the Registration Statement and Prospectus filed in connection with A 1 O's March 21, 2014 !PO, you are a Class Member. As set forth in the Stipulation, excluded from the Class are Defendants and their respective successors and assigns; past and current executive officers and directors of A 10 and the Underwriter Defendants; members of the immediate families of the lndividual Defendants; the legal representatives, heirs, successors or assigns of the lndividual Defendants; and any entity in which any of the above excluded persons have or had a majority interest . The foregoing exclusion shall not cover"lnvestment Vehicles," which for these purposes shall mean any investment company or pooled investment fund , including, but not limited to, mu tuai fund families, exchange-traded funds, fund of funds, private equity funds, real estate funds, and hedge funds , in which any Underwriter Defendant or any of its affiliates has or may have a direct or indirect interest or as to which any Underwriter Defendant or any of its affiliates may actas an investment advisor, general partner, managing member, or in other similar capacity, other than an investment vehicle ofwhich the Underwriter Defendant or any of its affiliates is a majority owner or ho Ids a majority beneficial interest and only to the extent ofsuch Underwriter Defendant's or affiliate's ownership or interest. Also excluded is any Person who validly requests exclusion from the Class.

Ifyou are not sure ifyou are a Class Member, you can ask for free help. You can contact the Claims Administrator at 1-877-241-7503 or Rick Nelson, a representative of Plaintiffs' Counsel at 1-800-449-4900. You can also fill out and return the ProofofClaim form enclosed with this Notice.

WHAT IS THE MONET ARY VALUE OF THE PROPOSED SETTLEMENT?

The Settlement, if approved, will result in the creation of a cash settlement fund of $9,837,500 (the "Settlement Amount"). The Settlement Amount, plus accrued interest (the "Settlement Fund") and minus the costs ofthis Notice and ail costs associated with the administration of the Settlement, as well as any attorneys' fees, ex penses, and payment to Plaintiffs for their time and expenses in representing the Class that may be approved by the Court (the "Net Settlement Fund"), will be distributed to Class Members pursuant to the Plan of Allocation that is described in the next section ofthis Notice .

Plaintiffs estimate that there are approximately 12,845,000 shares of A 10 common stock which may have been damaged during the period March 21, 2014 through January 29, 2015 (the "Class Period"). Plaintiffs estimate that the average recovery under the Settlement is roughly $0 .76 per damaged share before notice and administration costs and the attorneys' fee and expense award as we ll as payments to the Plaintiffs

QUESTIONS? CALL 877-241-7503 OR VlSlT WWW.AIOSECURITlESSETTLEMENT.COM PAGE 2 OF 7

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for their time and expenses in representing the Classas determined by the Court. Should the Court award the requested attorneys' fees of25% of the Settlement Fund (or $2,459,375), Plaintiffs' Counsel's expenses ofup to $175,000, awards of$2,500 to each Plaintifffor his or its representation of the Class and the maximum estimated cost of notice and administration of the Settlement of$375,000, the average per share recovery would be approximately $0.53. Using certain estimates of the number of claims that are going to be filed (30%) and the number of estimated claims that are going to be val id (70% of the 30%), it is estimated that approximately 2,700,000 shares will participate in the Settlement and the average recovery will be approximately $2.52 per share. Of course, these are just estimates; a Class Member's actual recovery will be a proportion of the Net Settlement Fund determined by that claimant's recognized claim as compared to the total recognized claims submitted. An individual Class Member may receive more or less than this average amount depending on the number of claims submitted, when during the Class Period a Class Member purchased or acquired A 10 common stock, the purchase or acquisition price paid, and whether those shares were held at the end of the Class Period or sold during the Class Period, and, if sold, when they were sold and the amount received . See the Plan of Allocation below for more information on your recognized claim.

WHAT IS THE PROPOSED PLAN OF ALLOCATION?

Your share of the Net Settlement Fund will depend on the number of val id Proofs ofClaim that Class Members send in and how many shares of A 10 common stock you purchased or acquired during the relevant period and when you bought and sold them .

For purposes of determining the amount an Authorized Claimant may recover under the Plan of Allocation, Lead Counsel conferred with their damages consultant and the Plan of Allocation reflects an assessment of damages that they believe cou Id have been recovered had Plaintiffs prevai led at trial.

ln the unlikely event there are sufficient funds in the Net Settlement Fund, each Authorized Claimant will receive an amount equal to the Authorized Claimant's claim, as defined below. If, however, the amount in the Net Settlement Fund is not sufficient to permit payment of the total claim of each Authorized Claimant, then each Authorized Claimant shall be paid the percentage of the Net Settlement Fund that each Authorized Claimant's claim bears to the total of the claims of ail Authorized Claimants. Payment in this manner shall be deemed conclusive against ail Authorized Claimants.

The calculation of claims below is not an estimate of the amount you will receive. lt is a fonnula for allocating the Net Settlement Fund among ail Authorized Claimants. A claim will be calculated as follows :

Claims for the March 21, 2014 Initial Public Offering

• Initial Public Offering Price: $15.00 per share • Closing price on the date the lawsuit was filed2

: $4.70 per share

For shares of Al O corn mon stock purchased or otherwise acquired pursuant to and/or traceable to the Company's March 21, 2014 registration statement, on March 21, 2014 through July 30, 2014, and

1) sold prior to July 31, 2014, the claim per share is $0.

2) sold on or between July 31, 2014, through October 7, 2014, the claim per share is the least of (i) the Purchase Price per share less the Sales Price per share, or (ii) $15 .00 Jess the Sales Price per share, or (iii) $2.13 (7/31/14 Price Decline).

3) sold on or between October 8, 2014, through January 28, 2015, the claim per share is the least of (i) the Purchase Price per share less the Sales Price per share, or (ii) $15 .00 Jess the Sales Price per share, or (iii) $5.48 (7/31/14 and 10/8/14 Price Declines).

4) retained at the close of trading on January 28, 2015, or sold on or after January 29, 2015, the claim per share is the least of(i) the Purchase Price per share Jess $4.70, (ii) the Purchase Price per share Jess the Sales Price per Share, or (iii) $5.48 (7/3 J/14 and 10/8/ 14 Price Declines).

For shares of A 10 common stock purchased or otherwise acquired pursuant to and/or traceable to the Company's March 21, 2014 registration statement, on July 31, 2014 through September 17,2014 (Date prior to Lock-up Expiration), and

1) sold prior to October 8, 2014, the claim per share is $0 .

2) sold on or between October 8, 2014, through January 28, 2015, the claim per share is the least of (i) the Purchase Price per share Jess the Sales Price per share, or (ii) $15 .00 Jess the Sales Price per share, or (iii) $3 .35 (10/8/14 Price Decline).

3) retained at the close of trading on January 28, 2015, or, sold on or after January 29, 2015, the claim per share is the least of (i) the Purchase Price per share Jess $4.70, (ii) the Purchase Price per share Jess the Sales Price per Share, or (iii) $3.35 (10/8/14 Price Decline).

ln the event a Class Member has more than one purchase, acquisition, or sale of A 10 common stock during the Class Period, ail purchases, acquisitions, and sales within the Class Period shall be matched on a First-In, First-Out ("FIFO") basis for purposes of calculating a claim. Un der the FI FO method, Class Period sales will be matched in chronological order against A 10 common stock purchased or acquired du ring the Class Period .

2The first complaint was filed on January 29, 2015 .

QUESTIONS? CALL 877-241-7 503 OR VISIT WWW .AI OSECURITIESSETTLEMENT.COM PAGE 3 OF 7

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A purchase, acquisition, or sale of A 10 common stock shall be deemed to have occurred on the "con tract" or "trade" date as opposed to the "settlement" or "payment" date. Ali purchase, acquisition, and sale prices shall exclude any fees and commissions. The receipt or grant by gift, devise or operation of law of A 10 common stock during the Class Period shall not be deemed a purchase, acquisition, or sale of A 10 common stock for the calculation of a claimant's recognized daim nor shall it be deemed an assignment of any daim relating to the purchase or acqu isition of such shares unless specifically provided in the instrument of gift or assignment. The receipt of A 10 common stock during the Class Period in exchange for securities of any other corporation or entity shall not be deemed a purchase, acquisition, or sale of A 10 common stock.

Payment according to the Plan of Allocation will be deemed conclusive against ail Authorized Claimants . No Person shall have any d aim against Plaintiffs, Plaintiffs ' Counsel , any claims administrator, any other Person designated by Plaintiffs' Counsel , Defendants, Defendants' Related Persons, or counsel to Defendants or their Related Persons based on distributions made substantially in accordance with the Stipulation, the Plan of Allocation, or further orders of the Court.

Covering purchases during the Class Period for shares originally sold short will be excluded from the calculation of an Authorized Claimant 's recognized claim. In the event that there is a short position in A 10 common stock, the date of covering a "short sale" is deemed to be the date ofpurchase of the stock. The date ofa "short sale" is deemed to be the date of sale of the stock. The earliest Class Period purchases shall be matched against such short position, and not be entitled to a recovery, until that sho11 position is fully covered.

With respect to A JO common stock purchased or sold through the exercise of an option, the purchase/sale date of the common stock is the exercise date of the option and the purchase/sale price of the stock is the exercise price of the option. Any recognized claim arising from purchases of A 10 common stock acquired during the Class Period through the exercise of an option on Al O common stock shall be computed as provided for other purchases of Al O common stock in the Plan of Allocation .

The total of ail profits shall be subtracted from the total of all losses from transactions du ring the Class Period to determine if a Cl ass Member has a recognized claim. Only if a Class Member had a net market Joss, after ail profits from transactions in Al O common stock during the Class Period are subtracted from ail losses , will such Class Member be eligible to receive a distribution from the Net Settlement Fund.

If an Authorized Claimant has an overall market gain, the recognized claim for that Authorized Claimant will be zero. If an Authorized Claimant has an overall market loss , that Authorized Claimant 's recognized claim will be limited to the amount of total market loss. The Cla ims Administrator shall allocate to each Authorized Claimant a pro rata share of the Net Settlement Fund based 011 his, her, or its recognized claim as compared to the total recognized claims of ail Authorized Claimants. No di stribution shall be made to Authorized Claimants who would otherwise receive a distribution of less than $10.00.

Class Members who do not submit acceptable Proofs of Claim will not share in the Settlement proceeds. The Settlement and the Final Judgment dismissing this Litigation will nevertheless bi11d Class Members who do not submit a request for exclusion and/or su bmit an acceptable Proof of Claim.

Please contact the Claims Administrator or Lead Counsel ifyou disagree with any determinations made by the Claims Administrator regarding your ProofofClaim. Jfyou are unsatisfied with the determinations, you may ask the Court, which retainsjurisdiction over ail Class Members and the claims administration process, to decide the issue by submitting a written request.

Defendants, their respective counsel, and ail other Related Persons will have 110 respo11sibility or liability whatsoever for the investment of the Settleme11t Fund, the distribution of the Net Settlement Fund, the Plan of Allocation , or the payment of any claim. Plaintiffs and Plainti ffs ' Counsel, likewise, will have no liability for their reasonable efforts to execute, administer, and distribute the Settlement.

Distributions will be made to Authorized Claimants after ail claims have been processed and after the Court has finally approved the Settlement. If any funds remain in the Net Settlement Fund by reason of un-cashed distribution checks or otherwise, then , after the Cla ims Admin istrator has made reasonable and diligent efforts to have Class Members who are entitled to participate in the distribut ion of the Net Settlement Fund cash their distributions, any balance remaining in the Net Settlement Fund after at least six (6) months after the initia l distribution ofsuch funds shall be used : (a) first , to pay any amounts mistakenly omitted from the initial disbu rsement; (b) second , additiona l settlement administration fees , costs, and ex penses, i11cluding th ose of Plaintiffs ' Co un sel as may be approved by the Court; and ( c) to make a second distribution to claimants who cashed their checks from the initial distribution and who would receive at least $10 .00, after payme nt of the estimated costs, expenses, or fees to be incurred in administering the Net Settlement Fund and in making this second distri bution , ifsuch second distribution is economically feasible. These redistributions shall be repeated, ifeconomically feasible , until the balance remain ing in the Net Settlement Fund is de minimis and such remaining balance shall then be distributed to Bay Area Legal Aid .

MUST I CONTACT PLAINTIFFS' COUNSEL IN OROER TO PARTICIPATE IN DISTRIBUTION OF THE SETTLEMENT FUND?

No. If you have received this Notice and timely submit your Proof of Clàim to the address designated on the Proof of Claim form accompanying this Notice, you need not contact Plaintiffs' Counsel. I fyou did not receive this Notice but believe you should have, or if yo ur address changes, please contact the Claims Administrator at:

QUESTIONS? CALL 877-241-7503 OR VISIT WWW.AIOSECURITIESSETTLEMENT.COM PAGE 4 OF 7

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AI O Securities litigation Claims Administrator

c/o A.B. Data, Ltd . P.O. Box 173012

Milwaukee, WI 53217 Phone: l-877-241-7503

www.AlOsecuritiessettlement.com info@A I Osecuritiessettlement.com

THERE WILL BE NO PAYMENTS IF THE STIPULATION IS TERMINATED

The Stipulation may be terminated under several circumstances outlined in it. If the Stipulation is terminated, the Litigation will proceed as if the Stipulation had not been entered into.

WHAT ARE THE REASONS FOR SETTLEMENT?

The Coui1 has not reached any final decisions in connection with Plaintiffs' claims against Defendants. lnstead, Plaintiffs and Defendants have agreed to this Settlement, which was reached with the substantial assistance of the Hon. Layn R. Phillips (Ret.), a highly experienced mediator of complex class actions. In reaching the Settlement, the Settling Parties have avoided the cost, delay, and uncertainty of further litigation.

As in any litigation, Plaintiffs and the Class would face an uncertain outcome ifthey did not agree to the Settlement. The Settling Parties expected that the case cou Id continue for a lengthy period of time and that if Plaintiffs succeeded, Defendants would file appeals that would postpone final resolution of the case. Continuation of the case against De fendants could result in a judgment greater than this Settlement. Conversely, continuing the case could result in no recovery at ail or a recovery that is less than the amount of the Settlement.

Pla inti ffs and Plaintiffs' Counsel believe that this Settlement is fair and reasonable to the Members of the Class. They have reached this conclusion for several reasons. Specifically, if the Settlement is approved, the Class will receive a significant monetary recovery. Additionally, Plaintiffs' Counsel believe that the significant and immediate benefits of the Settlement, when weighed against the significant risk , delay and unce11ainty of continued litigation, are an excellent result for the Class.

WHO REPRESENTS THE CLASS?

The law finns ofRobbins Geller Rudman & Dowd LLP, Labaton Sucharow LLP, and Scott+ Scott, Attorneys at Law, LLP representyou and other Class Members. These lawyers are called Plaintiffs' Counsel. These lawyers will apply to the Court for payment of attorneys' fees and expenses from the Settlement Fund; you will not be otherwise charged for their work. Ifyou want to be represented by your own lawyer, you may h ire one at your own ex pense.

HOW WILL THE PLAINTIFFS' LAWYERS BE PAID?

Plainti ffs' Counsel will file a motion for an award of attorneys ' fees and expenses that will be considered at the Settlement Fairness Hearing. Plaintiffs' Counsel will apply for an award of25% of the Settlement Fund, plus payment ofexpenses incurred in connection with the Litigation in an amount not to exceed $175,000 . ln addition, each of the Plaintiffs may seek payment ofup to $2,500 for their time and expenses incurred in representing the Class. Such sums as may be approved by the Court will be paid from the Settlement Fund . Class Members are not personally liable for any such fees or expenses.

The attorneys' fees and expenses requested will be the only payment to Plaintiffs' Counsel for their effo11s in achieving this Settlement and for their risk in undertaking this representation on a wholly contingent basis. Plaintiffs' Counsel have committed significant time and expenses in litigating this case for the bene fit of the Class. To date, Plaintiffs' Counsel have not been paid for their services in conducting this Litigation on behalf of the Plaintiffs and the Class, or for their ex penses. The fees requested will compensate Plaintiffs' Counsel for their work in achieving the Settlement. The Court will decide what constitutes a reasonable fee award and may award less than the amount requested by Plaintiffs' Counsel.

CAN I EXCLUDE MYSELF FROM THE SETTLEMENT?

If you want to keep the right to sue or continue to sue De fendants on your own abou t the legal issues in this case, then you must take steps to get out of the Class. This is called excluding yourself from, or "opting out" of, the Class .

To exc lude yourself from the Class, you must send a letter by mail saying that you want to be excluded from the Class in the following action : ln re A / 0 Ne tworks, Inc. Shareho/der litigation, Lead Case No. l- l 5-CY-276207. Be sure to include your name, address, telephone number, and sign the letter. You should also include the number of shares of A 10 common stock you purchased or acquired that are subject to the Litigation . Your exclusion request must be postmarked no later than December 14, 2016 and sent to the Claims Administrator at:

A I O Securities litigation EXCLUSIONS

Claims Administrator c/o A.B. Data, Ltd . P.O. Box 173012

Milwaukee, WJ 53217

QUESTIONS? CALL 877-241-7503 OR VISIT WWW .AI OSECURITIESSETTLEMENT.COM PAGE 5 OF 7

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You cannot exclude yourselfby phone or by email. If you make a proper request for exclusion, you will not receive a Settlement payment, and you cannot object to the Settlement. If you make a proper request for exclusion, you will not be legally bound by anything that happens in this lawsuit.

CAN I OBJECT TO THE SETTLEMENT, THE REQUESTED ATTORNEYS' FEES AND EXPENSES, THE REQUESTEO PA YMENT OF COSTS AND EXPENSES TO PLAINTIFFS AND/OR THE PLAN OF ALLOCATION?

Yes. lfyou are a Class Member, you may object to the terms of the Settlement. Whether or not you object to the terms of the Sett lement, you may also abject to the requested attorneys ' fees , costs and expenses, the payment to Plaintiffs for their time and expenses, and/or the Plan of Allocation . In order for any objection to be considered, you must file a written statement, accompanied by proof ofClass membership, with the Court, and send to Lead Counsel postmarked by December 14, 2016. The Court ' s address is : Superior Court of California, County of Santa Clara, 191 North First Street, San Jose, CA 95113 , and Lead Counsel's addresses are: Robbins Geller Rudman & Dowd LLP, 65 5 West Broadway, Suite 1900, San Diego, CA 92101 , c/o Ellen GusikoffStewart; and Labaton Sucharow LLP, 140 Broadway, New York, NY 10005, c/o David J. Goldsmith. Attendance at the Settlement Fairness Hearing is not necessary ; however, persons wishing to be heard oral ly at the Settlement Fairness Hearing are required to indicate in their written objection their intention to appear at the hearing and identify any witnesses they may cal! to testify and exhibits, if any, they intend to introduce into evidence. A Class Member who does not file a written objection may appear and object at the Settlement Fairness Hearing.

WHAT IS THE DIFFERENCE BETWEEN OBJECTING AND EXCLUDING MYSELF FROM THE SETTLEMENT?

Objecting is telling the Court that you do not like something about the proposed Settlement, the Plan of Allocation, Plainti ffs' Counsel 's request for an award of attorneys ' fees and expenses, or payment to Plaintiffs for their time and expenses in representing the Class. You can object on/y if you stay in the Class. Excluding yourself is telling the Court that you do not want to be part of the Class. If you exclude yourself, you have no basis to object because the case no longer applies to you .

HOW CAN l GETA PA YMENT?

ln order to qualify for a payment, you must timely submit a Proof of Claim. A Proof of Claim is enclosed with this Notice or it may be downloaded atwww.AIOsecuritiessettlement.com. Read the instructions carefully, fil! out the Proofof Claim, include ail the documents the form asks for, sign it, and mail or submit it online so that it is postmarked (if mailed) or received (if filed electronically) no la ter than February 10, 2017 . The ProofofClaim form may be submitted online at www.AlOsecuritiessettlement.com. lf you do not submi t a valid ProofofClaim form, you will not receive a payment from the Net Settlement Fund; however, unless you expressly exclude yourselffrom the Classas described above, you will still be bound in ail other respects by the Settlement, the Judgment, and the releases contai ned in them .

WHAT CLAIMS WILL BE RELEASEO BY THE SETTLEMENT?

Unless you exclude yourself, you are staying in the Class, and that means that you cannot sue, continue to sue, or be part of any other lawsuit against the Defendants about the same issues in this case or about issues that cou Id have been asserted in this case . lt also means that ail of the Court's orders will apply to you and legally bind you and you will release your Released Claims in this case aga inst Defendants and their Related Persons. "Released Claims" shall collectively mean any and ail claims (state or federal, including, but not limited to, claims ari sing under the federal securities laws, any rules or regulations promulgated thereunder, or otherwise, as well as Unknown Clai ms) against Defendants and their Related Persons, arising out of, relating to, or in connection with both (i) the facts, events, transactions, acts, occurrences, statements, representations, misrepresentations or omissions which were or cou Id have been alleged in the Litigation or any fo ru m by any of the Plaintiffs or any other Class Members, and (ii) the purchase or acquisition of A 10 corn mon stock pursuant and/or traceab le to the Registration Statement and Prospectus issued in connection with AI O's March 21 , 2014 !PO. "Released Claims" further includes any and ail claims arising out of, based upon or related to the Settlement or resolution of the Litigation, except for any alleged breaches of the Stipulation . Released Claims also excludes any of the claims asserted in Hornung v. A 10 Networks, Inc., et al. , Case No. 15-cv-282286 (Santa Clara County Superior Court of California).

"Related Persons" means each ofa Defendant 's past, present or future parents, subsidiaries, affiliates , divisions and joint ventures, and the ir respective directors, officers, employees, partners, members, principals, agents, underwriters, insurers, co-insurers, reinsurers, contro ll ing shareholders, attorneys, accountants or auditors, financial or investment advisors or consultants, banks or investment bankers, persona! or legal representatives, predecessors, successors, assigns, spouses, heirs, related or affiliated entities, any entity in which a Defendant has a control ling interest, any member ofan lndividual Defendant' s immediate family , or any trust ofwhich any lndividual Defendant is the settlor or which is for the benefit of any De fendant and/or member(s) of his family .

THE SETTLEMENT FAIRNESS HEARING

The Court will hold a Settlement Fairness Hearing on January 13 , 2017, at 9:00 a.m., before the Honorable Peter H. Kirwan at the Superior Court of California, County of Santa Clara, 191 North First Street, San Jose, CA 95113 , for the purpose of determining whethe r: ( 1) the Settlement of the Litigation for $9,837,500 in cash should be approved by the Court as fair, reasonable, and adequate; (2) to award Plaintiffs ' Counsel attorneys' fees and expenses out of the Settlement Fund; (3) to pay Plaintiffs for their time and expenses they incurred in rep resenti ng the Class out of the Settlement Fund; and (4) the Plan of Allocation should be approved by the Court . The Court may adjou rn or continue the Settlement Fairness Hearing without further notice to Members of the Class.

HOW 00 I OBTAIN AOOITIONAL INFORMATION?

Th is Notice contains only a summary of the terms of the proposed Settlement. The records in this Litigation may be examined and copied at any time during regular office heurs, and subject to customary copying fees , at the office of the Clerk of the Superior Court of Californi a,

QUESTIONS? CALL 877-241-7503 OR YISIT WWW.A IOSECURITIESSETTLEMENT.COM PAGE 6 OF 7

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County of Santa Clara. In addition, ail of the Settlement documents, including the Stipulation, this Notice, the Proof of Claim fonn, and proposed Judgment may be obtained by contacting the Claims Administrator at:

AI O Securities Litigation Claims Administrator

c/o A.B. Data, Ltd. P.O. Box 173012

Milwaukee, WI 53217 Phone: 1-877-241-7503

www.AIOsecuritiessettlement.com info@A I Osecuritiessettlement.com

In addition, you may contact Rick Nelson, Shareholder Relations, Robbins Geller Rudman & Dowd LLP, 655 West Broadway, Suite 1900, San Diego, CA 92101, 1-800-449-4900, or Nicole M. Zeiss, Settlement Counsel, Labaton Sucharow LLP, 140 Broadway, New York, NY 10005, settlementquestions@labaton .com, 1-888-219-6877 if you have any questions about the Litigation or the Settlement or want to obtain Settlement documents .

DO NOT WRITE TO OR TELEPHONE THE COURT FOR INFORMATION

SPECIAL NOTICE TO BANKS, BROKERS, AND OTHER NOMINEES

I fyou hold any A 10 common stock purchased or acquired between March 21, 20 I 4 and January 29, 2015, as a nominee for a beneficial owner, then, within ten ( 10) days after you receive this Notice, you must either: ( 1) send a copy ofthis Notice by First-Class Mail to ail such Persons; or (2) provide a list of the names and addresses ofsuch Persons to the Claims Administrator:

AI O Securities litigation FULFILLMENT

Claims Administrator c/o A.B . Data, Ltd.

3410 West Hopkins Street P.O. Box !73012

Milwaukee, WI 53217 info@A l Osecuritiessettlement.com

lfyou choose to mail the Notice and ProofofClaim yourself, you may obtain from the Claims Administrator (without cost to you) as many additional copies of these documents as you will need to complete the mailing.

Regardless of whether you choose to complete the mailing yourself or elect to have the mailing performed for you, you may obtain reimbursement for or advancement of reasonable administrative costs actually incurred or expected to be incurred in connection with forwarding the Notice and which would not have been incurred but for the obligation to forward the Notice, upon submission ofappropriate documentation to the Claims Administrator.

DATED: OCTOBER 13, 2016 BY OROER OF THE SU PERI OR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA HONORABLE PETER H. KIRWAN

QUESTIONS? CALL 877-241-7503 OR YISIT WWW .A IOSECURITIESSETTLEMENT.COM PAGE70F7

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IN RE AlO NETWORKS, INC. SHAREHOLDER LITIGATION CLAIMS ADMINISTRA TOR c/o A.B. DATA, L TD. PO BOX 173012 MILWA UKEE, WI 53217

COURT-APPROVED NOTICE REGARDING

IN RE AlO NETWORKS, INC. SHAREHOLDER LITIGA TION

DATED MATERIAL-OPEN IMMEDIATELY A IO_BA_54 132N l2

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MUST BE POSTMARKED OR RECEIVED NO

LATER THAN F'EBRUARY 10, 2017

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANT A CLARA

ln re A 10 NETWORKS, INC. SHAREHOLDER LITIGATION

Lead Case No. l-15-CV-276207 CLASS ACTION

This Document Relates To: ALL ACTIONS.

1. GENERAL INSTRUCTIONS

Assigned for Ali Purposes to the Honorable Peter H. Kirwan Dept. 1 Date Action Filed: 01/29/15

PROOF OF CLAIM AND RELEASE

l lllllll lllll lllll lllll lllll llll lllll lllll 111111111111111111

FOR INTERNAL USE ONLY

1. To recover as a Member of the Class based on your claims in the action entitled ln re A 10 Networks, Inc. Shareho/der litigation, Lead Case No. 1: l 5-CV-276207 (the "Litigation"), you must complete and, on page 4 hereof, sign this Proof of Claim and Release ("Proof of Claim"). If you fail to file a properly addressed (as set forth in paragraph 3 below) Proof of Claim, your claim may be rejected and you may be precluded from any recovery from the Net Settlement Fund created in connection with the proposed Settlement of the Litigation.

2. Submission of this Proof of Claim, however, does not ensure that you will share in the proceeds of the Settlement of the Litigation.

3. VOU MUST MAIL OR SUBMIT ONLINE YOUR COMPLETED AND SIGNED PROOF OF CLAIM, ACCOMPANIED BY COPIES OF THE DOCUMENTS REQUESTED HEREIN, ON OR BEFORE FEBRUARY 10,2017, ADDRESSED AS FOLLOWS:

A 10 Securities litigation Claims Administrator

c/o A.B . Data, Ltd. P.O. Box 173012

Milwaukee, WI 53217 Online Submissions: www.A 1 Osecuritiessettlement.com

lfyou are NOT a Member of the Class, as defined in the Notice of Proposed Settlement ofClass Action (the "Notice"), DO NOT submit a Proof of Claim.

4. If you are a Member of the Class and you do not timely request exclusion in connection with the proposed Settlement, you will be bound by the terms of any judgment entered in the Litigation, including the releases provided therein, WHETHER OR NOT YOU SUBMIT A PROOF OF CLAIM.

li. CLAIMANT IDENTIFICATION

If you purchased or acquired the common stock of A 10 Networks, Inc. ("AI O" or the "Company") during the period from March 21, 2014, through and including January 29, 2015, use Part I of this fonn, entitled "Claimant Identification," to list the claimant name, mailing address, and account infonnation if relevant (such as for a claim submitted on behalf of an IRA, a trust, or an estate account). Please list the most current claimant or account name as you would like the infonnation to appear on the check, if eligible for payment. Please also provide a telephone number and/or email address, as the Claims Administrator may need to contact you with questions about the claim submitted. If your Claimant Identification information changes, please notify the Claims Administrator in writing at the address above.

1 f you are acting in a representative capacity on behalf of a Class Member (for example, as an executor, administrator, trustee, or other representative) , you must submit evidence of your current authority to act on behalf of that Class Member. Such evidence would include, for ex ample, letters testamentary, letters of administration, or a copy of the trust documents or other documents which provide you with the authority to submit the claim. Please also indicate your representative capacity under your signature on page 4 ofthis claim fonn.

NOTICE REGARDING ELECTRONIC FILES: Certain claimants with large numbers of transactions may request to, or may be requested to, submit information regarding their transactions in electronic files. If you have a large number of transactions and wish to file your claim electronically, you must contact the Claims Administrator at 1-877-241-7503 to obtain the required file layout.

III. CLAIM FORM Use Part II of this fonn, entitled "Schedule of Transactions in A 10 Common Stock" to supply ail required details ofyour transaction(s) in A 10 common stock. If you need more space or additional schedules, attach separate sheets giving ail of the required information in substantially the same fom1 . Sign and print or type your name on each additional sheet.

On the schedules, provide ail of the requested information with respect to ail of your purchases or acquisitions and ail of your sales of AIO common stock between March 21, 2014, and January 29, 2015, inclusive, which took place pursuant to and/or traceable to AIO's Initial Public Offering on or about March 21, 2014, whether such transactions resulted in a profit or a loss. You must also provide ail of the requested information with respect to ail of the shares of AIO common stock you held at the close of trading on January 29, 2015 . Failure to report ail such transactions may result in the rejection ofyour claim.

QUESTIONS? CALL 877-241-7503 OR VISIT WWW.AIOSECURITIESSETTLEMENT.COM PAGE I OF4

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List these transactions separately and in chronological order, by trade date, beginning with the earliest. You must accurately provide the

month, day, and year of each transaction you list.

The date of covering a "short sale" is deemed to be the date of purchase of Al O common stock. The date of a "short sale" is deemed to be

the date of sale of AIO common stock.

Copies of stockbroker confirmation slips, stockbroker statements, or other documents evidencing your transactions in A 10 common stock should be attached to your claim. If any such documents are not in your possession, please obtain a copy or equivalent documents fro m your broker because these documents are necessary to prove and process your claim. Failure to provide thi s documentation could de lay verification of your claim or result in rejection of your claim.

PART 1- CLAIMANT IDENTIFICATION - Complete either Section A or Band then proceed to Section C. Please type or print.

The Claims Administrator will use the information supplied below for ail communications regarding this Proof of Claim fonn . If thi s information changes, you MUST notify the Claims Administrator in writing at the address above.

A. Complete this Section ONLY if the Beneficial Owner is an individual, a joint account, or an IRA account. Otherwise, proceed to Section B.

Last Name (Beneficial Owner) First Name (Beneficial Owner)

I'-------------' Last Name Joint Beneficial Owner, if a licable First Name Joint Beneficial Owner, if a licable)

Name of Custodian, if applicable

If this account is an IRA, and if you would like any check that you MA Y be eligible to receive made payable to the IRA account,

please include " IRA" in the "Last Name" box above (e.g. , Jones IRA).

B. Complete this Section ONLY if the Beneficial Owner is an Entity, i.e., a corporation, trust, esta te, etc.

Entity Name Name of Representative, if applicable ( executor, administrator, trustee, etc .)

C. Mailing/Account Information:

Specify one of the follow ing:

0 Individual(s) 0Corporation D UGMA Custodian D IRA 0Partnership 0Estate 0Trust

0 Other:

Mailing Address - Line 1: Street Address/P.O. Box :

Mailin

City: State/Province:

D ZIP Code/Postal Code (ifoutside U.S.):

Country: Last 4 di its of Claimant Social Securit /Tax a er Identification Number: 1

Daytime Telephone Number: Evening Telephone Number:

J.___ __ ___,, !...____ __ ___, Email Address :2

1The last four digits of the taxpayer identification number ("TIN"), consisting of a valid Social Security Number (SSN) for individuals or Employer Identification Number ("EIN") for business entities, trusts, estates, etc ., and telephone number of the beneficial owner(s) may be used in verifying this claim. 2 An email address is not required, but if you provide it, you authorize the Clai111s Administrator to use it in providing you with information relevant to this claim.

QUESTIONS? CALL 877-241-7503 OR VISIT WWW.AIOSECURITIESSETTLEMENT.COM PAGE 20F4

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PART 11-SCHEDULE OF TRANSACTIONS IN AIO COMMON STOCK

Please be sure to include proper documentation with your Proof of Claim form. Do not include information regarding securities other than A 10 common stock.

A. PURCHASES OR ACQUISITIONS OF AIO COMMON STOCK BETWEEN MARCH 21, 2014, AND JANUARY 29, 2015, INCLUSIVE:

Date of Purchase/ Number of Purchase/ Acquisition Total Purchase/ Covered Shares Acquired Through Acquisition Shares Price per Share Acquisition Price Short Sale? Acquisition or Merger?

(List Purchased/ ( excluding taxes, (If so, identify the Chronologically) Acquired commissions, and fees) company acquired.)

(Month/Day/Y ear)

/ / $ $ ,'., Yes

/ / $ $ ,·, Yes

/ / $ $ "' Yes

/ / $ $ ,:, Yes

B. SALES OF AIO COMMON STOCK BETWEEN MARCH 21, 2014, AND JANUARY 29, 2015, INCLUSIVE:

Date of Sale Number of Sale Price per Share Total Sale Price (excluding taxes, commissions, and fees) (List Shares Sold

Chronologically) (Mon th/Day/Y ear)

/ / $ $

/ / $ $

/ / $ $

/ / $ $

C. ENDING HOLDINGS - NUMBER OF SHARES OF AIO COMMON STOCK HELD AT THE CLOSE OF TRADING ON JANUARY 29, 2015 (MUST BE DOCUMENTED). IF NONE, WRITE "ZERO" OR "O." [

1

IF YOU REQUIRE ADDITIONAL SPACE FOR THE SCHEDULE ABOYE, ATTACH EXTRA SCHEDULES IN THE SAME FORMAT. PRINT THE BENEFICIAL OWNER'S FULL NAME AND LAST FOUR DIGITS OF SOCIAL SECURITY/TAXPAYER IDENTIFICATION NUMBER ON EACH ADDITIONAL PAGE. IF YOU DO ATTACH EXTRA SCHEDULES, CHECK THIS BOX D YOUR SIGNATURE ON PAGE 4 WILL CONSTITUTE YOUR ACKNOWLEDGMENT OF THE RELEASE.

IV. SUBMISSION TO JURISDICTION OF COURT AND ACKNOWLEDGMENTS

I (We) submit this Proof of Claim under the terms of the Stipulation described in the Notice. I (We) also submit to the jurisdiction of the Superior Court of the State of Califomia, County of Santa Clara, with respect to my (our) claim as (a) Class Member(s) and for purposes of enforcing the release set forth herein. I (We) further acknowledge that I am (we are) bound by and subject to the terms ofany judgment that may be entered in the Litigation. I (We) agree to fumish additional infonnation to the Claims Administrator to support this claim ifrequested to do so. I (We) have not submitted any other claim in connection with the purchase, acquisition, or sale of AIO common stock and know of no other persan having done so on my (our) behalf.

V. RELEASE 1. I (We) hereby acknowledge full and complete satisfaction of, and do hereby fully, finally, and forever settle, release, and discharge from the Released Claims each and ail of the Released Parties as provided in the Stipulation.

QUESTIONS? CALL 877-241-7503 OR VTSIT WWW.AIOSECURITIESSETTLEMENT.COM PAGE30F4

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2. "Related Persons" means each of a Defendant's past, present, or future parents, subsidiaries, affiliates, divisions and joint ventures, and their respective directors, officers, employees, partners, members, principals, agents, underwriters, insurers, co-insurers, reinsurers , controlling shareholders, attorneys, accountants or auditors, financial or investment advisors or consultants, banks or investment bankers, persona! or legal representatives, predecessors, successors, assigns, spouses, heirs, related or affiliated entities, any entity in which a Defendant has a controlling interest, any member of an Individual Defendant's immediate family , or any trust of which any lndividual Defendant is the settlor or which is for the benefit of any Defendant and/or member(s) of his family .

3. "Released Clairns" shall collectively mean any and ail clairns (state or federal, including, but not limited to, claims arising under the federal securities laws, any rules or regulations promulgated thereunder, or otherwise, as well as Unknown Claims) against Defendants and their Related Persons, arising out of, relating to, or in connection with bath (i) the facts, events, transactions, acts, occurrences, statements, representations, misrepresentations or omissions which were or could have been alleged in the Litigation or any fonun by any of the Plaintiffs or any other Class Members, and (i i) the purchase or acquisition of A 10 common stock pursuant and/or traceable to the Registration Statement and Prospectus issued in connection with AIO 's March 21, 2014 IPO. "Released Claims" further includes any and ail claims arising out of, based upon, or related to the Settlement or resolution of the Litigation, except for any alleged breaches of the Stipulation. "Released Claims" also excludes any of the claims asserted in Hornung v. A 10 Networks, Inc., et al. , Case No. 15-cv-282286 (Santa Clara County Superior Court of Cali fomia).

4. "Released Parties" means each and ail of the Defendants and their Related Persons.

5. This release shall be of no force or effect unless and until the Court approves the Stipulation and the Settlement becomes effective on the Effective Date.

6. I (We) hereby warrant and represent that I (we) have not assigned or transferred or purported to ass ign or transfer , voluntarily or involuntarily, any malter released pursuant to this release or any other part or portion thereof.

7. I (We) hereby warrant and represent that I (we) have included infom1ation about ail of my (our) purchases, acquisitions, and sa les of A 10 common stock between March 21 , 2014 and January 29, 2015, inclusive, and the number of shares of A 10 common stock held by me (us) at the close of trading on January 29, 2015 .

8. I (We) certify that I am (we are) not subject to backup withholding under the provisions of Section 3406(a)( 1 )(C) of the Internai Revenue Code.

Note: If you have been notified by the Interna! Revenue Service that you are subject to backup withholding, please strike out the language that you are not subject to backup withholding in the certification above.

I (We) declare under penalty of perjury under the laws of the United States of America that the foregoing information supplied by the undersigned is true and correct.

Executed this _______ day of ________ in __________ _ (MonthN ear) (City/State/Country)

Signature of claimant Print your name here Date

Signature of joint claimant, if any Print your name h~re Date

Signature of person signing on behalf of claimant Print your name here Date

Capacity of persan signing on behalf of claimant, if other than an individual , e.g., executor, president, trustee, custodian, etc.

ACCURATE CLAIMS PROCESSING TAKES A SIGNIFICANT AMOUNT OF TIME. THANK YOU FOR YOUR PATIENCE.

REMINDER CHECKLIST

1. Please sign the above release and declaration. 2. Remember to attach supporting documentation, if available. 3. Do not send original stock certificates. 4. Keep a copy of your claim form for your records . 5. Ifyou desire an acknowledgment ofreceipt ofyour claim form, please send it Certified Mail , Retum Receipt Requested. 6. Ifyou move, please send your new address to the address below.

THIS PROOF OF CLAIM FORM MUST BE SUBMITTED ONLINE BY OR, IF MAILED, POSTMARKED NO LATER THAN FEBRUARY 10, 2017, ADDRESSED AS FOLLOWS:

A 10 Securities litigation Claims Administrator

c/o A.B. Data, Ltd. P.O. Box 173012

Milwaukee, WI 53217 www.A 1 Osecuritiessettlement.com

QUESTIONS? CALL 877-241-7503 OR VISIT WWW.AIOSECURITIESSETTLEMENT.COM PAGE4 0F4