SAN DIEGO, Dec. 17, 2021 /PRNewswire/ --

SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK, COMMERCIAL DIVISION




CHESTER COUNTY EMPLOYEES
RETIREMENT FUND, Individually and on
Behalf of All Others Similarly Situated,

Plaintiff,

vs.

ALNYLAM PHARMACEUTICALS, INC.,
JOHN M. MARAGANORE, MICHAEL P.
MASON, DENNIS A. AUSIELLO,
MICHAEL W. BONNEY, JOHN K.
CLARKE, MARSHA H. FANUCCI, STEVEN
M. PAUL, DAVID E.I. PYOTT, PAUL R.
SCHIMMEL, AMY W. SCHULMAN,
PHILLIP A. SHARP, KEVIN P. STARR,
GOLDMAN SACHS & CO. LLC, J.P.
MORGAN SECURITIES LLC, BARCLAYS
CAPITAL INC., CREDIT SUISSE
SECURITIES (USA) LLC, PIPER JAFFRAY
& CO., JMP SECURITIES LLC, NEEDHAM
& COMPANY, LLC, CHARDAN CAPITAL
MARKETS, LLC and B. RILEY FBR, INC.
n/k/a B. RILEY SECURITIES, INC.,

Defendants.


Index No. 655272/2019

CLASS ACTION

The Honorable Robert R. Reed

Part 43





SUMMARY NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION

TO: ALL PERSONS WHO PURCHASED OR OTHERWISE ACQUIRED ALNYLAM PHARMACEUTICALS, INC. ("ALNYLAM" OR THE "COMPANY") COMMON STOCK PURSUANT OR TRACEABLE TO THE REGISTRATION STATEMENT ISSUED IN CONNECTION WITH ALNYLAM'S NOVEMBER 14, 2017 SECONDARY PUBLIC OFFERING (THE "OFFERING")1

YOU ARE HEREBY NOTIFIED that a hearing will be held on April 12, 2022, at 2:30 p.m., before the Honorable Robert R. Reed, J.S.C., at Part 43, via Microsoft Teams Virtual Platform, to determine whether: (1) the proposed settlement (the "Settlement") of the above-captioned action as set forth in the Stipulation of Settlement ("Stipulation")[2] for $7,000,000 in cash should be approved by the Court as fair, reasonable and adequate; (2) the Judgment as provided under the Stipulation should be entered; (3) to award Plaintiff's Counsel attorneys' fees and expenses out of the Settlement Fund (as defined in the Notice of Pendency and Proposed Settlement of Class Action ("Notice"), which is discussed below), and, if so, in what amount; (4) to award Plaintiff for representing the Settlement Class out of the Settlement Fund and, if so, in what amount; and (5) the Plan of Allocation should be approved by the Court as fair, reasonable and adequate.

This Action is a securities class action brought on behalf of those persons who purchased or acquired Alnylam common stock pursuant or traceable to the Registration Statement for the Offering, against Alnylam and certain of its officers and directors and the Offering's underwriters (collectively, "Defendants") for, among other things, allegedly misstating and omitting material facts from the Registration Statement filed with the U.S. Securities and Exchange Commission in connection with the Offering.  Plaintiff alleges that these purportedly false and misleading statements inflated the price of the Company's stock, resulting in damage to Settlement Class Members when the truth was revealed.  Defendants deny all of Plaintiff's allegations.

IF YOU PURCHASED OR ACQUIRED ALNYLAM COMMON STOCK BETWEEN NOVEMBER 14, 2017 THROUGH AND INCLUDING SEPTEMBER 12, 2019, YOUR RIGHTS MAY BE AFFECTED BY THE SETTLEMENT OF THIS ACTION.

To share in the distribution of the Settlement Fund, you must establish your rights by submitting a Proof of Claim and Release form ("Proof of Claim") by mail (postmarked no later than MARCH 17, 2022) or electronically (no later than MARCH 17, 2022).  Your failure to submit your Proof of Claim by March 17, 2022, will subject your claim to rejection and preclude your receiving any of the recovery in connection with the Settlement of this Action.  If you are a member of the Settlement Class and do not request exclusion therefrom, you will be bound by the Settlement and any judgment and release entered in the Action, including, but not limited to, the Judgment, whether or not you submit a Proof of Claim.

If you have not received a copy of the Notice, which more completely describes the Settlement and your rights thereunder (including your right to object to the Settlement), and a Proof of Claim, you may obtain these documents, as well as a copy of the Stipulation (which, among other things, contains definitions for the defined terms used in this Summary Notice) and other settlement documents, online at www.AlnylamSecuritiesLitigation.com, or by writing to:

Alnylam Securities Litigation Settlement
Claims Administrator
c/o Analytics Consulting, LLC
P.O. Box 2004
Chanhassen, MN  55317-2004

Inquiries should NOT be directed to Defendants, the Court, or the Clerk of the Court.

Inquiries, other than requests for the Notice or for a Proof of Claim, may be made to Plaintiff's Counsel:

ROBBINS GELLER RUDMAN & DOWD LLP
Theodore J. Pintar
655 West Broadway, Suite 1900
San Diego, CA 92101
Telephone: (800) 449-4900

IF YOU DESIRE TO BE EXCLUDED FROM THE SETTLEMENT CLASS, YOU MUST SUBMIT A REQUEST FOR EXCLUSION SUCH THAT IT IS POSTMARKED BY MARCH 22, 2022, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE. ALL MEMBERS OF THE SETTLEMENT CLASS WHO HAVE NOT REQUESTED EXCLUSION FROM THE SETTLEMENT CLASS WILL BE BOUND BY THE SETTLEMENT EVEN IF THEY DO NOT SUBMIT A TIMELY PROOF OF CLAIM.

IF YOU ARE A SETTLEMENT CLASS MEMBER, YOU HAVE THE RIGHT TO OBJECT TO THE SETTLEMENT, THE PLAN OF ALLOCATION, THE REQUEST BY PLAINTIFF'S COUNSEL FOR AN AWARD OF ATTORNEYS' FEES AND EXPENSES, AND/OR THE AWARD TO PLAINTIFF FOR REPRESENTING THE SETTLEMENT CLASS. ANY OBJECTIONS MUST BE FILED WITH THE COURT AND SENT TO PLAINTIFF'S COUNSEL AND DEFENDANTS' COUNSEL BYMARCH 22, 2022, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE.

DATED: DECEMBER 17, 2021

BY ORDER OF THE SUPREME COURT OF NEW YORK COUNTY OF NEW YORK: COMMERCIAL DIVISION

1 For purposes of this Settlement only, the Settlement Class includes persons who purchased or otherwise acquired Alnylam common stock between November 14, 2017 and September 12, 2019, inclusive.
2 The Stipulation can be viewed and/or obtained at www.AlnylamSecuritiesLitigation.com.

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SOURCE Robbins Geller Rudman & Dowd LLP