IN RE ZYGNA INC. SECURITIES LITIGATION

STIPULATION AND [PROPOSED] ORDER MODIFYING THE SCHEDULE CONCERNING SETTLEMENT

JACQUELINE SCOTT CORLEY, Magistrate Judge.

Lead Plaintiff David Fee ("Lead Plaintiff") and Defendants Zynga Inc. ("Zynga" or the "Company"), Mark Pincus, David M. Wehner and John Schappert (collectively "Defendants"), by and through their undersigned attorneys, submit this Stipulation seeking modification of the schedule for Settlement Class Members to submit claim forms, request exclusion from the Settlement, or object to the Settlement, Plan of Allocation, or request for attorneys' fees and reimbursement of litigation expenses and rescheduling the Final Approval Hearing.

Lead Plaintiff states the following:

On October 27, 2015, this Court granted preliminary approval of the $23 million Settlement and approved the form, content and method of notice to the class ("Preliminary Approval Order"). Pursuant to the Preliminary Approval Order, the deadline for Settlement Class Members to submit claim forms, request exclusion from the Settlement, or object to the Settlement, Plan of Allocation, or request for attorneys' fees and reimbursement of litigation expenses was January 12, 2016. The Court also set a final approval hearing for January 28, 2016 at 9:00 a. m.

The Court-appointed claims administrator, Epiq Systems, Inc. ("Epiq"), fully complied with the Court-approved notice plan. This included that on November 3, 2015, Epiq caused the Summary Notice to be published in Investor's Business Daily. Also on November 3, 2015 Epiq mailed the Notice of Pendency of Class Action and Proposed Settlement, Final Approval Hearing, and Motion for Attorneys' Fees and Reimbursement of Litigation Expenses (the "Notice") and the Proof of Claim and Release ("Proof of Claim") (together, the Notice and Proof of Claim are referred to herein as the "Notice Packet") to known holders of Zynga common stock during the Settlement Class Period as well as to 1,625 common banks, brokers and other nominees (collectively "brokers"). The Notice directed such brokers who purchased or otherwise acquired Zynga common stock for the beneficial interest of a person or organization other than themselves to either (i) send a copy of the Notice Packet to the beneficial owner of such common stock, postmarked no later than 10 days after such nominees' receipt of the Notice Packet, or (ii) provide to Epiq the names and addresses of such persons no later than 10 days after such nominees' receipt of the Notice Packet.

Most of these brokers complied with the request within or close to the deadline specified. However, despite continuous efforts by Epiq to ensure timely broker-compliance, including follow-up with brokers, certain brokers did not comply until within one month of or closer to the January 12, 2016 deadline. Epiq thereafter mailed Notice Packets to these names and addresses soon after they were received. Lead Counsel have generally observed an increase in such instances of brokers' failure to comply in a timely manner in securities class action settlements.

Specifically, here, Barclays Capital did not provide Epiq with its list of 1,200 names and addresses until December 17, 2015. Thereafter, on December 23, 2015, Epiq mailed Notice Packets to these names and addresses. Further, Wells Fargo Securities did not provide Epiq with its list of 96 names and addresses until December 18, 2015. Thereafter, on December 24, 2015, Epiq mailed Notice Packets to these names and addresses. Additionally, Scottrade did not provide Epiq with its list of 32,732 names and addresses until December 28, 2015. Thereafter, on December 31, 2015, Epiq mailed Notice Packets to these names and addresses. Further, Charles Schwab did not provide Epiq with its list of 24,009 names and addresses until December 28, 2015. Thereafter, on January 5, 2016, Epiq mailed Notice Packets to these names and addresses.

Lead Counsel was alerted by Epiq to these broker delays early in January and Lead Counsel discussed this with Epiq and received confirmation from Epiq that it did not anticipate receiving any additional large lists from brokers and that it had received names and addresses from the largest and most common brokers.

Thereafter, however, Epiq received a list of 4 names and addresses from National Financial on January 6, 2016. On January 11, 2016, Epiq mailed Notice Packets to these names and addresses. Further, although Fidelity sent Epiq a list of 31,875 names and addresses on November 30, 2015 (and Epiq mailed Notice Packets to these names and addresses on December 4, 2015), Fidelity sent a supplement list of 3,701 names and addresses, received by Epiq on January 8, 2016. Thereafter, on January 12, 2016, Epiq mailed Notice Packets to these names and addresses.

Thus, as a result of these events, certain Settlement Class Members may not have received their Notice Packets with sufficient time to respond.

Lead Plaintiff's and Defendants' Stipulation:

Lead Counsel and Defendants have met and conferred regarding the above delay. As such, Lead Plaintiff and Defendants request (1) an extension of the deadline for Settlement Class Members who were impacted by this delay to submit a claim, request exclusion or object; (2) an extension of the deadline for Lead Plaintiff's reply brief and response to objections and proof of notice compliance; and (3) that the Final Approval Hearing be rescheduled. Additionally, Lead Counsel would have the settlement website home page updated to prominently inform all visitors of the new date for the Final Approval Hearing and that, as to Settlement Class Members affected by the delay, the claim submission, request for exclusion and objection deadlines have been extended. Lead Plaintiff and Defendants propose the following deadlines:

[PROPOSED] ORDER

Pursuant to the stipulation of the parties and good cause having been shown, IT IS HEREBY ORDERED that the following deadlines are hereby GRANTED:

PURSUANT TO STIPULATION, IT IS SO ORDERED.