Proof of Publication

Case 20-33332-KLP Doc 911 Filed 02/11/21 Entered 02/11/21 10:37:51 Desc Main Document Page 1 of 2

PROOF OF PUBLICATION

21 ______Feb-10, 20___

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Feb 10, 2021, NYT & Natl, pg B3

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ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ EŽƚĂƌǇWƵďůŝĐ Case 20-33332-KLP Doc 911 Filed 02/11/21 Entered 02/11/21 10:37:51 Desc Main C M Y K Nxxx,2021-02-10,B,003,Bs-BW,E1Document Page 2 of 2

THE NEW YORK TIMES BUSINESS WEDNESDAY, FEBRUARY 10, 2021 N B3

MEDIA

Reddit Raises Fox Seeks to Dismiss Election Lawsuit Times Places $250 Million, By MICHAEL M. GRYNBAUM A Top Editor and JONAH E. BROMWICH Pushing Value Rupert Murdoch’s Fox Corpora- In the Office tion filed a motion on Monday to To $6 Billion dismiss the $2.7 billion defamation Of Its Publisher lawsuit brought against it last By MIKE ISAAC week by the election technology By MARC TRACY company Smartmatic, which has SAN FRANCISCO — Fresh off a win- The New York Times announced accused Mr. Murdoch’s cable net- ning Super Bowl ad and a role at on Tuesday that one of its highest- works and three Fox anchors of the center of a recent stock mar- ranking editors, Rebecca Blumen- spreading falsehoods that the stein, will take on a newly created ket frenzy, Reddit announced on company tried to rig the presiden- role, reporting directly to the pub- Monday that it had raised $250 tial race against Donald J. Trump. lisher, A. G. Sulzberger, and help- million in new funding, valuing The lawsuit has roiled right- ing him run newsroom operations the social news start-up at $6 bil- wing news media outlets whose as the newspaper’s business ex- lion as it aims to turbocharge user star personalities repeatedly cast pands. growth and double its work force. doubt on President Biden Jr.’s vic- Ms. Blumenstein, 54, a deputy The investment is a shot in the tory and raised the specter of a managing editor, has overseen arm for Reddit, which since 2005 significant financial penalty for The Times’s website, including has focused on building digital Fox. On Friday, the day after the the live briefings that became cen- communities around topic-based lawsuit was filed, Fox canceled tral to coverage of breaking news message boards. The latest fund- the nightly Fox Business program in the last year. She will remain on ing, led by Vy Capital with partici- hosted by Lou Dobbs, who is The Times’s masthead with a new pation from previous investors named in the suit with the Fox an- title: deputy editor, publisher’s of- like Andreessen Horowitz, Se- chors Maria Bartiromo and Jean- fice. quoia Capital and Tencent Hold- ine Pirro. “Rebecca will step away from ings, doubles Reddit’s valuation In its 44-page response filed in the news cycle to become my day- from its last financing in 2019. New York State Supreme Court, to-day partner in supporting our Reddit, which is based in San Fox argues that the claims of elec- DREW ANGERER/GETTY IMAGES journalism operations at a time Francisco, said the funding built toral fraud made on its channels Fox Corporation filed a motion in the $2.7 billion lawsuit brought by the election technology company Smartmatic. when they are growing rapidly in on the success of its burgeoning by Mr. Trump’s lawyers — includ- size and ambition,” Mr. Sulzberger advertising business, as brands ing Rudolph W. Giuliani and Sid- wrote in a memo to staff on Tues- and marketers are attracted to the ney Powell, who are also named in ering the news. “They’re arguing alleges that Mr. Trump’s lawyers dent of Venezuela, Hugo Chávez, day. site’s powerful and active commu- the defamation suit — were mat- that shields Fox News as an orga- used Fox’s platform, and its sym- assisted the company in creating Before joining The Times four nity members. ters of significant interest to view- nization for simply reporting on pathetic anchors, to spin conspira- software that could covertly alter years ago, Ms. Blumenstein was “We have come a long way in re- ers and handled fairly. the controversy, which is a matter cies about the company that dam- votes. (Mr. Chávez died in 2013 the deputy editor in chief of The cent years to focus more on the “This lawsuit strikes at the of public interest,” he said. aged its reputation and commer- and had nothing to do with Smart- Wall Street Journal, where she needs of the hundreds of thou- heart of the news media’s First A key to Fox’s defense is the ar- cial prospects. The suit has been matic.) had been the China bureau chief, Amendment mission to inform on gument that it cannot be held re- applauded by those seeking to In other exchanges cited by international editor, Page One edi- matters of public concern,” Fox sponsible for statements made on curb the flow of disinformation Smartmatic, Fox anchors alter- tor and managing editor of its says in the motion. “An attempt by its programs by Mr. Giuliani and from right-wing news outlets, but nately expressed support and as- website. a sitting president to challenge the Ms. Powell, given their roles as it has also raised questions about tonishment as Mr. Giuliani and In the new role, Ms. Blumen- result of an election is objectively Mr. Trump’s legal representa- the limits of speech in a changing Ms. Powell spun out their claims. stein will focus on diversity in the newsworthy.” tives. media landscape. In one case, a phrase used by Ms. newsroom, the plans for a post- Paul D. Clement, a partner in “The public had a right to know, Fox’s argument in its motion — Powell — “cyber Pearl Harbor” — pandemic return to the office and the Washington office of the law and Fox had a right to cover, that that it provided a forum for news- was later invoked by Mr. Dobbs on the challenge of remaining an in- firm Kirkland & Ellis who served the president and his allies were worthy interviews — may cut into his show and on social media. dependent voice in a hyperparti- as solicitor general under Presi- accusing Smartmatic (and oth- the conceptual heart of Smartmat- Fox’s response on Monday in- san landscape, Mr. Sulzberger dent George W. Bush, is leading ers) of manipulating the election ic’s case, which groups Fox, its cluded a 14-page appendix under said in the Fox’s defense. “Smartmatic’s the- results, regardless of the ultimate hosts and their guests as defend- the title “Fox’s Evenhanded Cov- memo. ory is fundamentally incompati- truth or accuracy of those allega- ants who collaborated to spread erage of Smartmatic,” document- Ms. Blumen- ble with the reality of the modern tions,” the motion reads. It also as- falsehoods. ing instances from Fox News and stein said in an news network and deeply rooted serts that Smartmatic’s suit does The defamation lawsuit cites Fox Business that the company interview that principles of free speech law,” Mr. not identify defamatory state- exchanges on Fox programs that, believes showed skepticism to- Mr. Sulzberger Clement said in a statement. ments by television hosts em- Smartmatic said, helped spread ward the Trump team’s claims. approached her A spokesman for Smartmatic ployed by Mr. Murdoch’s com- the false claim that it was the Among the examples are three a few weeks did not reply to a request for company. owner of a rival election tech com- identical, pretaped fact-checking ago. “I will re- ment. Fox also argues that Smart- pany, Dominion Voting System, segments that ran in mid-Decem- ally miss the HORACIO VILLALOBOS/GETTY IMAGES “It’s a strong move on their part matic should be considered a pub- and that it provided its services to ber on programs hosted by Ms. Rebecca newsroom,” she Steve Huffman, the head of Reddit, to try to come out and dismiss the lic figure. That argument, which is districts in multiple contested Bartiromo, Mr. Dobbs and Ms. Blumenstein said, “but I can which was part of a market frenzy. claim,” said Timothy Zick, a pro- likely to be contested by the tech states. In fact, Smartmatic was Pirro and that featured Eddie Pe- see areas where I could help The fessor at William & Mary Law company, means that Smartmatic used in the 2020 election only by rez, an election expert who de- Times at this important moment.” School who specializes in First must meet a high bar to prove that Los Angeles County. bunked a number of false claims sands of communities that make “The news business is facing so Amendment law. it was defamed: demonstrating And Smartmatic offers vivid ex- about Smartmatic. many challenges,” she added. “We up Reddit,” the company said in a Mr. Zick said Fox was making that the defendants knew their amples of Fox programming that The segments were broadcast have to do whatever we can to see blog post. “We have dedicated use of the concept of “neutral re- statements were false, or at least spread bizarre falsehoods, like a after Smartmatic sent a letter to around the corner of what’s com- ourselves to Reddit because we portage,” arguing that it could not had serious doubts about them. claim by Ms. Powell made on Mr. Fox demanding retractions and ing and make sure The Times is believe in the power of communi- be sued for defamation while cov- Smartmatic’s 276-page lawsuit Dobbs’s show that a former presi- threatening legal action. ties that provide a sense of belong- the best place for our people and ing and connection as real as the our journalists.” ones we make offline.” Ms. Blumenstein will become a Reddit has been highly visible more frequent public representa- in recent days. Last month, shares tive of The Times, “regularly en- of the video-game retailer gaging outside our walls to make Fox News Reports the case for our model of inde- GameStop soared as users of Red- pendent journalism,” Mr. Sulz- dit’s WallStreetBets forum, which berger wrote in his memo. is known as a “subreddit,” egged Big Growth in Profit The announcement of Ms. Blu- one another on to buy the stock, menstein’s new role came amid a partly to entrap hedge funds that By EDMUND LEE whose system was used in the flurry of senior-level moves at The had bet the stock would fall. presidential election in Los Ange- Times as it prepares for a leader- That sent GameStop’s stock on If Rupert Murdoch’s Fox News is at all worried about recent ratings les County, is seeking at least $2.7 ship change. The executive editor, an extraordinary and volatile ride. declines, the company hid its con- billion in damages against Fox Dean Baquet, will reach the pa- After a flurry of media attention, cern well. Mr. Murdoch’s power- Corporation, Fox News and sev- per’s usual retirement age for the WallStreetBets forum bal- house television business contin- eral of its prime-time stars for par- newsroom leaders and top execu- looned to more than seven million ues to have growth in revenue and ticipating in “the conspiracy to de- tives of 66 in September 2022. members. Multiple book and film profit, reporting gains on both ar- fame and disparage Smartmatic “Dean and I fully understand option rights have been shopped eas in its quarterly earnings re- and its election technology and the importance of having a robust over the saga, with the prospect of port announced on Tuesday. software,” according to the suit. plan to ensure that the newsroom fame and money embroiling the Fox Corporation, led by Mr. Mr. Trump and his supporters will be well led far into the future,” forum’s moderators in bitter dis- repeatedly described the election Mr. Sulzberger said in a statement Murdoch’s son Lachlan Murdoch, MIKE COHEN FOR THE NEW YORK TIMES putes. as “rigged,” and Fox News and its last month. “With a deep bench of the chief executive, had a 17 per- Lachlan Murdoch, C.E.O. of Fox, said that a drop in ratings was expected. Reddit was also widely praised cent jump in pretax profit, to $305 sister network Fox Business have incredibly talented editors, I’m for a five-second commercial that million. It logged an 8 percent gain given significant airtime to per- confident that will be the case.” aired during the Super Bowl on in sales, to $4 billion, for the three sonalities and anchors who have “In the journalism trade, you acquired last year, also helped in- Last month, The Times elevat- Sunday, which became one of the months ending in December, what sown doubt about the election re- work out what your market is and crease revenue to the TV unit. Al- ed Clifford J. Levy from metro edi- most talked-about ads on a day the company considers its second sults. The suit names the Fox an- produce the best product you can though it is still a money-losing tor to deputy managing editor and that was crowded with talked- fiscal quarter. chors Maria Bartiromo, Lou possibly produce,” he said. “At Fox enterprise, Tubi is expected to named Kathleen Kingsbury to an- Dobbs and Jeanine Pirro. Mr. other masthead position, opinion about ads. Reddit’s spot, which re- Despite losing the ratings News, the success of Fox News double its revenue to about $300 Dobbs’s show was abruptly can- editor. Late last year, Carolyn quired viewers to pause their tele- crown to CNN in recent weeks, throughout its entire history has million for the fiscal year ending celed last week, bringing his dec- Ryan rose from associate manag- vision screens to read it, pro- Fox News is still a profit machine. been to provide the absolute best in June, the company said. The cable division had a 1 percent ade-long run at the company to an news and opinion for a market ing editor to deputy managing edi- claimed, “Wow, this actually tor, and the national editor, Marc gain in revenue, to $1.49 billion, end. that we believe is firmly center- worked.” Viewers scrambled to Michael Grynbaum contributed Lacey, was promoted to assistant and a 3 percent increase in pretax The financial penalty sought by right.” grab screenshots of one of the Smartmatic appears to closely reporting. managing editor. profit, to $571 million. He seemed unconcerned about shortest-ever Super Bowl ads to mirror the amount of profit Fox Advertising increased 31 per- the rise in far-right news outlets post to social media. Corporation generates. For calen- Reddit has had its share of con- cent, to $441 million, but the fees that have had record ratings in re- IN THE UNITED STATES BANKRUPTCY COURT Co-Counsel to the Debtors: Steven N. Serajeddini, P.C., KIRKLAND paid by cable operators to carry dar year 2020, the company made FOR THE EASTERN DISTRICT OF VIRGINIA,RICHMOND DIVISION & ELLIS LLP, 601 Lexington Avenue, New York, New York 10022 -and- troversy over the years. The com- cent weeks. 1 the network fell 3 percent, to $928 about $3.1 billion in pretax earn- In re: LETOTE,INC., et al. , ) Chapter 11, Case No.20-33332 (KLP) David L.Eaton,Jaimie Fedell, KIRKLAND & ELLIS LLP ,300 North LaSalle, pany has long been criticized for ings. Fox has filed a motion to dis- “We believe where we’re tar- Debtors. ) (Jointly Administered) Chicago,Illinois 60654 -and- Michael A.Condyles,Peter J.Barrett,Jeremy million, as more people cut the NOTICE OF HEARING TO CONSIDER CONFIRMATION S.Williams, Brian H.Richardson, KUTAK ROCK LLP , 901 East Byrd Street, its laissez faire approach to con- miss the suit. geted to the center-right is exactly OFTHE CHAPTER 11 PLAN FILED BYTHE DEBTORS Suite 1000,Richmond,Virginia 23219-4071;(ii) U.S.Trustee: Office of the cord. UnitedStatesTrusteefortheEasternDistrictofVirginia,101WestLombard tent moderation, which allowed where we should be targeted,” he AND RELATED VOTING AND OBJECTION DEADLINES Lachlan Murdoch trumpeted Fox News also faces competi- PLEASE TAKE NOTICE THAT on February 5, 2021, the United States Street,Suite 2625,Baltimore,MD 21201 -and- Office of the United States racist, sexist and troll-filled com- tion from newer news media out- said. “We believe that’s where, po- BankruptcyCourtfortheEasternDistrictofVirginia(the“Court”)enteredan Trustee for the Eastern District of Virginia, 701 East Broad Street, Suite the cable news network’s per- litically, Americans are.” order [Docket No.905] (the“Disclosure Statement Order”): (a) authorizing 4000,Richmond,VA 23219; and (iii) Counsel to the Official Committee munities to flourish. At one point, formance, downplaying the re- lets that tack even further to the LeTote,Inc.anditsaffiliateddebtorsanddebtorsinpossession(collectively, of Unsecured Creditors Appointed in These Chapter 11 Cases: Jay right, such as OANN and News- The company’s Fox broadcast the“Debtors”),to solicitacceptancesforthe JointChapter11PlanofLeTote, R. Indyke, Ian Shapiro, Evan Lazerowitz, Paul Springer, COOLEY LLP, 55 Reddit refused to remove subfo- cent drop in viewership. Inc.and its Debtor Affiliates (as modified,amended,or supplemented from HudsonYards,NewYork,NewYork 10001 -and- Cullen Speckhart, COOLEY rums dedicated to racist commen- max. Fox loyalists seemed to have stations helped drive much of the time to time, the“Plan”); 2 (b) approving the Disclosure Statement for the LLP, 1299PennsylvaniaAvenue,NWSuite700,Washington,DC20003. “The Fox News Channel fin- quarter’s growth as local net- Joint Chapter 11 Plan of LeTote,Inc.and its Debtor Affiliates (the“Disclosure ADDITIONALINFORMATION tary, citing the need for free and ished the quarter with its highest turned on the network after it Statement”) as containing “adequate information” pursuant to section Obtaining Solicitation Materials .The materials in the Solicitation called the presidential election for works had record political adver- 1125 of the Bankruptcy Code;(c) approving the solicitation materials and Package are intended to be self-explanatory. If you should have any unfettered speech. average ratings,” he said on an documents to be included in the solicitation packages (the “Solicitation questions or if you would like to obtain additional solicitation materials Joseph R. Biden Jr., with some tising during the presidential elec- Packages”); and (d) approving procedures for soliciting, receiving, and (or paper copies of solicitation materials if you received a CD-ROM or flash In recent years, the company earnings call with analysts. “We drive), please feel free to contact the Debtors’ Notice and Claims Agent, viewers flocking to competitors. tion season. The broadcast divi- tabulatingvotesonthePlanandforfilingobjectionstothePlan. has changed its tune on content are now seeing expected audience PLEASETAKEFURTHERNOTICETHAT thehearingatwhichtheCourt by: (i) accessing the Debtors’ restructuring website at https://cases. When asked about the ratings sion had a 10 percent bump in ad will consider Confirmation of the Plan (the“Confirmation Hearing”) will stretto.com/letote;(ii)writingtotheNoticeandClaimsAgentatLeToteInc. moderation. Since Steve Huff- pullback since the election,” a phe- BallotingProcessingCenter,c/oStretto,410Exchange,Suite100 , Irvine,CA dollars, to $1.8 billion. commence on March 18, 2021, at 1:00 p.m. prevailing Eastern Time, man, a Reddit co-founder, re- nomenon that he said was “consis- declines and the impending battle before the Honorable Keith L. Phillips, in the United States Bankruptcy 92602; (iii) calling the Notice and Claims Agent at 855-217-8030; or (iv) for its core audience, Mr. Murdoch The addition of Tubi, the ad-sup- Court for the Eastern District of Virginia,located at 701 East Broad Street, emailing [email protected]. You may also obtain copies of any turned as chief executive in 2015, tent with prior election cycles.” He Suite 5100, Richmond,VA 23219-1888 or by electronic means, including pleadings filed in the Chapter 11 Cases for a fee via PACER at:http://www. hesitated before answering. ported free streaming service Fox telephone or video conference, as directed by the court. Additional vaeb.uscourts.gov. Please be advised that the Notice and Claims Agent is the start-up has overhauled and expects audiences to eventually informationregardingproceduresforhearingsbeforetheCourt,including authorized to answer questions about, and provide additional copies of, fine-tuned its content policies. return to the network. telephonic and/or videoconference hearings consistent with the Protocol solicitation materials, but may not advise you as to whether you should in Response to Public Health Emergency, in light of the ongoing public votetoacceptorrejectthePlan. Reddit has barred communities of The company also announced a IN THE UNITED STATES BANKRUPTCY COURT Contract or Unexpired Lease: (a) is listed on the schedule of “Rejected response to COVID-19 is available by visiting the Court’s website at: The Plan Supplement . The Debtors will file the Plan Supplement SOUTHERN DISTRICT OF TEXAS,HOUSTON DIVISION Executory Contracts and Unexpired Leases”contained in Exhibit 8.1 of the https://www.vaeb.uscourts.gov/. (as defined in the Plan) on or before March 1,2021 ,and will serve notice Nazis and other far-right contin- multiyear renewal contract for ) on all Holders of Claims entitled tovote on the Plan,whichwill: (a) inform In re: NOBLE CORPORATION PLC, Chapter 11 Plan(asamended);or(b)asotherwiseprovidedinthePlan. PLEASE BE ADVISED : THE CONFIRMATION HEARING MAY BE (n/k/a Noble Holding ) PLEASETAKEFURTHERNOTICE thatproofsofClaimassertingClaims partiesthattheDebtorsfiledthePlanSupplement;(b)listtheinformation gents. In June, it banned The_Do- Suzanne Scott, the head of the net- Case No.20-33826 (DRJ) CONTINUEDFROMTIMETOTIMEBYTHECOURTORTHEDEBTORS WITHOUT Corporation plc), et al. , ) arising from the rejection of the Executory Contracts and Unexpired FURTHER NOTICE OTHER THAN BY SUCH ADJOURNMENT BEING containedinthePlanSupplement;and(c)explainhowpartiesmayobtain 1 (Jointly Administered) nald, a subforum dedicated to sup- work, dispelling any concerns Debtors. ) Leases pursuant to the Plan or otherwise must be filed with the Claims ANNOUNCED IN OPEN COURT OR BY A NOTICE OF ADJOURNMENT FILED copiesofthePlanSupplement. that she may be replaced given its NOTICE OF EFFECTIVE DATE and Solicitation Agent no later than thirty (30) days after the later of the WITHTHECOURTANDSERVEDONALLPARTIESENTITLEDTONOTICE. BINDINGNATUREOFTHEPLAN : porters of President Donald J. PLEASE TAKE NOTICE that on November 20,2020 (the“Confirmation EffectiveDateortheeffectivedateofrejection. CRITICALINFORMATIONREGARDINGVOTINGONTHEPLAN IFCONFIRMED,THEPLANSHALLBINDALLHOLDERSOFCLAIMSAND Trump, which the company said recent ratings performance. Date”), the United States Bankruptcy Court for the Southern District of PLEASE TAKE FURTHER NOTICE that with respect to each Executory Voting Record Date .The voting record date is January 29, 2021 , INTERESTSTOTHEMAXIMUMEXTENTPERMITTEDBYAPPLICABLE Texas (the “Court”), entered the Order Approving the Modified Second Contract or Unexpired Lease listed on the schedule of“Rejected Executory whichisthedatefordeterminingwhichHoldersofClaimsinClass3orClass LAW,WHETHERORNOTSUCHHOLDERWILLRECEIVEORRETAINANY had repeatedly broken its rules “Suzanne’s track record of suc- AmendedJointPlanofReorganizationofNobleCorporationplc(n/k/aNoble Contracts and Unexpired Leases”in Exhibit 8.1 of the Plan (as amended), 4areentitledtovoteonthePlan. PROPERTYORINTERESTINPROPERTYUNDERTHEPLAN,HASFILED cess, innovative spirit and dedica- Holding Corporation plc) and Its Debtor Affiliates [Docket No. 723] (the the Confirmation Order constitutes an order of the Court approving such VotingDeadline . ThedeadlineforvotingonthePlanison March10, APROOFOFCLAIMINTHECHAPTER11CASES,ORFAILEDTOVOTETO against harassment and other be- “Confirmation Order”),confirming the plan of reorganization (the“Plan”) rejectionspursuanttosections365and1123oftheBankruptcyCodeasof 2021,at5:00p.m. prevailingEasternTime(the“VotingDeadline”). Ifyou ACCEPTORREJECTTHEPLANORVOTEDTOREJECTTHEPLAN. havior. tion to excellence make her the oftheabove-captioneddebtors(collectively,the“Debtors”). thedatesetforthonExhibit8.1. receivedaSolicitationPackage,includingaBallotandintendtovoteonthe Dated: February8,2021, /s/ JeremyS.Williams , KUTAKROCKLLP, Michael ideal person to continue to lead PLEASE TAKE FURTHER NOTICE that, pursuant to the Plan, the PLEASE TAKE FURTHER NOTICE that, counterparties to Executory Planyou must : (a)followtheinstructionscarefully;(b)complete all ofthe A.Condyles (VA 27807),Peter J.Barrett (VA 46179),Jeremy S.Williams (VA Reddit said it planned to use the Debtorsarerequiredtofilethis NoticeofEffectiveDate withinareasonable Contracts or Unexpired Leases that are deemed rejected have the right to required information on the ballot;and (c) execute and return your com- 77469),Brian H.Richardson (VA 92477),901 East Byrd Street,Suite 1000, new injection of capital to expand and grow Fox News,” Lachlan periodaftertheEffectiveDate. assertanyClaimonaccountoftherejectionofsuchExecutoryContractsor pleted Ballot according to and as set forth in detail in the voting instruc- Richmond, Virginia 23219-4071, Telephone: (804) 644-1700, Facsimile: Murdoch said in a statement on PLEASE TAKE FURTHER NOTICE that the Effective Date of the Plan Unexpired Leases,including under section 502(g) of the Bankruptcy Code, tionssothatitis actuallyreceived bytheDebtors’noticeandclaimsagent, (804)783-6192,Email:[email protected],Peter.Barrett@ its community of more than 50 occurredonFebruary5,2021.AllconditionsinArticle12.2ofthePlanhave subjecttocompliancewiththerequirementssetforthinthePlan. Stretto(the“NoticeandClaimsAgent”)onorbeforetheVotingDeadline. A KutakRock.com, [email protected], Brian.Richardson@ Tuesday. beensatisfiedorwaivedpursuanttoArticle12.3ofthePlan. PLEASE TAKE FURTHER NOTICE that the Plan and its provisions are failuretofollowsuchinstructionsmaydisqualifyyourvote . KutakRock.com, Co-Counsel to the Debtors and Debtors in Possession -and- million daily active users. That in- PLEASE TAKE FURTHER NOTICE that, except as otherwise set forth binding upon and inure to the benefit of the Debtors, the Reorganized CRITICALINFORMATIONREGARDINGOBJECTINGTOTHEPLAN KIRKLAND & ELLIS LLP, KIRKLAND & ELLIS INTERNATIONAL LLP, The network did not disclose in the Plan, the Confirmation Order, or any other order of the Court, all Debtors, all current and former Holders of Claims, all current and former ARTICLEVIIIOFTHEPLANCONTAINSRELEASE,EXCULPATION,AND Steven N.Serajeddini,P.C.(admitted pro hac vice ),601 Lexington Avenue, cludes courting more influencers 2 the exact length or financial terms requests for payment of an Administrative Claim must be filed with the Holders of Interests,and all other parties-in-interest and their respective INJUNCTIONPROVISIONS,AND ARTICLEVIII.ECONTAINSATHIRD- New York, New York 10022, Telephone: (212) 446-4800, Facsimile: (212) and content creators, a move it Claims and Solicitation Agent on or before the date that is thirty (30) days heirs,successors,andassigns. PARTYRELEASE .THUS,YOUAREADVISEDTOREVIEWANDCONSIDERTHE 446-4900, Email: [email protected] -and- KIRKLAND & of the deal. aftertheEffectiveDate.HoldersofAdministrativeClaimsthatarerequired PLEASE TAKE FURTHER NOTICE that copies of the Confirmation PLANCAREFULLYBECAUSEYOURRIGHTSMIGHTBEAFFECTEDTHEREUNDER. ELLIS LLP, KIRKLAND & ELLIS INTERNATIONAL LLP, David L. Eaton made when it bought the short- to, but do not, file and request payment of such Administrative Claim(s) OrderandthePlanandalldocumentsfiledintheDebtors’chapter11cases Plan Objection Deadline . The deadline for filing objections to the (admitted prohacvice ),Jaimie Fedell (admitted prohacvice ),300 North La But hanging over the compa- by the applicable Administrative Claims Bar Date shall be forever barred, are publicly available and may be obtained by (a) visiting the Debtors’ Plan is March 10,2021,at 5:00 p.m., prevailing EasternTime (the“Plan Salle Street,Chicago,Illinois 60654,Telephone:(312) 862-2000,Facsimile: form video platform Dubsmash, a ny’s financial future is a defama- estopped,andenjoinedfromassertingsuchAdministrativeClaimsagainst restructuring website at: https://dm.epiq11.com/noble, (b) calling the ObjectionDeadline”).AllobjectionstothereliefsoughtattheConfirmation (312) 862-2200, Email: [email protected], jaimie.fedell@ rival to TikTok, in December. Red- the Debtors or their property and such Administrative Claims shall be Debtors’restructuringhotlineat(855)917-3560(tollfreeU.S.)or+1(503) Hearing must :(a) be in writing;(b) conform to the Bankruptcy Rules,the kirkland.com, Co-CounseltotheDebtorsandDebtorsinPossession tion lawsuit recently brought deemeddisallowedinfullasoftheEffectiveDate. 597-7713(non-U.S.parties);or(c)[email protected]. Local Rules, and any orders of the Court; (c) state, with particularity, the 1 A complete list of each of the Debtors in these chapter 11 cases may dit, which has more than 700 PLEASE TAKE FURTHER NOTICE that pursuant to Article VIII of the 1 Due to the large number of Debtors in these jointly administered legal and factual basis for the objection and, if practicable, a proposed be obtained on the website of the Debtors’ claims and noticing agent against Fox Corporation by a lit- Plan,except as otherwise provided in the Plan,the Confirmation Order,or chapter11cases,acompletelistoftheDebtorsisnotprovidedherein.Such modification to the Plan (or related materials) that would resolve such at http://cases.stretto.com/letote. The location of the Debtors’ service workers, also said it would double tle-known technology provider. anyotherOrderoftheCourt,eachExecutoryContractandUnexpiredLease informationmaybeobtainedathttps://dm.epiq11.com/noble. objection; and (d) be filed with the Court (contemporaneously with a addressis250VeseyStreet,22ndFloor,NewYork,NewYork10281 . that number this year. is deemed automatically assumed pursuant to sections 365 and 1123 of 2 Capitalizedtermsusedbutnototherwisedefinedhereinshallhavethe proof of service) and served upon the following parties so as to be actu- 2 Capitalized terms not otherwise defined herein have the same The suit, filed by Smartmatic, the Bankruptcy Code as of the Effective Date, unless any such Executory meaningsascribedtotheminthePlan. ally received on or before the Plan Objection Deadline: (i) Proposed meaningsassetforthinthePlan.