TuSimple Securities Settlement

WELCOME TO THE TUSIMPLE SECURITIES SETTLEMENT WEBSITE

The information contained on this website is only a summary of the information presented in more detail in the Notice of Pendency and Proposed Settlement of Class Action (“Notice”). Because this website is just a summary, you should review the Notice for additional details.

Summary of the Action and Settlement

This website relates to a proposed settlement of a class action lawsuit (“Litigation”) brought by Indiana Public Retirement System, Robert Miller, and Michelle Poirier (collectively, “Plaintiffs”) against TuSimple Holdings, Inc. (“TuSimple” or the “Company”), Guowei “Charles” Chao, Xiaodi Hou, Mo Chen, Bonnie Yi Zhang, Cheng Lu, Patrick Dillon, Brad Buss, Karen C. Francis, Morgan Stanley & Co. LLC, Citigroup Global Markets, Inc., J.P. Morgan Securities LLC, BofA Securities, Inc., Cowen and Company, LLC, Credit Suisse Securities (USA) LLC, Nomura Securities International, Inc., RBC Capital Markets, LLC, Needham & Company, LLC, Oppenheimer & Co., Inc., Piper Sandler & Co., Robert W. Baird & Co., and Valuable Capital Limited (collectively, “Defendants”), alleging that Defendants violated the federal securities laws by making false statements and omissions of material facts during the Class Period (i.e., the period between April 15, 2021 and December 20, 2022, inclusive) which had the effect of artificially inflating the trading prices of TuSimple common stock and call options and artificially deflating the trading price of TuSimple put options. Defendants deny the allegations and any liability or wrongdoing of any kind.

The Court has not decided in favor of Defendants or Plaintiffs. Instead, both sides have agreed to a settlement of the Litigation for $189 million in cash (“Settlement”) for the benefit of the Settlement Class. On December 2, 2024, the Court will hold a Settlement Hearing to consider final approval of the Settlement and related matters.

If you are a member of the Settlement Class, you are subject to the Settlement. The Settlement Class consists of:

All Persons who purchased and/or otherwise acquired TuSimple securities between April 15, 2021 and December 20, 2022, inclusive.

Excluded from the Settlement Class are: (i) Defendants and members of their immediate families; (ii) current and former officers and directors of TuSimple and members of their immediate families; (iii) any entity in which any Defendant has a controlling interest or which is related to or affiliated with any Defendant; (iv) TuSimple’s subsidiaries and affiliates or other entities owned or controlled by it; (v) the legal representatives, heirs, successors, or assigns of each Defendant; and (vi) any Persons who properly exclude themselves by submitting a valid and timely request for exclusion.

Please read the Notice to fully understand your rights and options. Copies of the Notice and Proof of Claim and Release can be found in the Case Documents and File Claim tabs at the top of this page.

Payments to eligible claimants will be made only if the Court approves the Settlement and Plan of Allocation, after any appeals are resolved, and after the completion of all claims processing. Please be patient, as this process will take some time to complete.

YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT

SUBMIT A CLAIM FORM	The only way to be eligible to receive a payment from the Settlement. Proofs of Claim must be postmarked or submitted online on or before January 31, 2025. The Proof of Claim is available on this website on the page titled "File Claim."
EXCLUDE YOURSELF FROM THE SETTLEMENT CLASS	Get no payment. This is the only option that potentially allows you to ever be part of any other lawsuit against the Defendants or any other Defendants’ Released Persons about the legal claims being resolved by this Settlement. Should you elect to exclude yourself from the Settlement Class, you should understand that Defendants and the other Released Defendant Parties will have the right to assert any and all defenses they may have to any claims that you may seek to assert, including, without limitation, the defense that any such claims are untimely under applicable statutes of limitations and statutes of repose. Requests for exclusion must be postmarked or received on or before November 12, 2024.
OBJECT	Write to the Court about why you do not like the Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and expenses. You will still be a Member of the Settlement Class. Objections must be postmarked or received by the Court and counsel on or before November 12, 2024. If you submit a written objection, you may (but do not have to) attend the Settlement Hearing.
GO TO THE SETTLEMENT HEARING ON DECEMBER 2, 2024, AT 10:30 A.M.	Ask to speak in Court about the fairness of the Settlement. Requests to speak at the Settlement Hearing must be postmarked or received by the Court and counsel on or before November 12, 2024.
DO NOTHING	Receive no payment. You will, however, still be a Member of the Settlement Class, which means that you give up your right to ever be part of any other lawsuit against the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement and you will be bound by any judgments or orders entered by the Court in the Litigation.

IMPORTANT DATES AND DEADLINES

Submit Proof of Claim:	January 31, 2025
Exclude yourself from the Settlement Class	November 12, 2024
Object	November 12, 2024
Final Hearing	December 2, 2024, at 10:30 a.m.