Plaintiffs filed a class action complaint against Juniper on behalf of a class of Plan participants, alleging that Juniper violated ERISA by breaching fiduciary duties owed to the Plan and/or the Plan’ participants under ERISA by causing the Plan to incur higher administrative and investment fees and expenses than reasonable and necessary.

A complete description of Plaintiffs’ allegations is in the Amended Complaint, which is available on the Settlement Website. Juniper has denied and continues to deny Plaintiffs’ claims and allegations in their entirety, denies that it is liable at all to the Plaintiffs or the Class Members, and denies that the Plaintiffs, Class Members, or the Plan have suffered any harm or damage for which Juniper could or should be held responsible, as Juniper denies all allegations of wrongdoing and asserts that its conduct was lawful. Juniper is settling the Action solely to avoid the expense, inconvenience, and inherent risk and disruption of litigation.

The Court has not decided in favor of either side in this Action. Instead, both sides agreed to a settlement. That way, both sides avoid the cost and risk of a trial, and the affected current and former Plan participants will get substantial benefits that they would not have received if Plaintiffs had litigated the case and lost. The Plaintiffs and their attorneys believe the Settlement is in the best interests of the Class Members and the Plan.

The Court decided that everyone who fits this description is a Class Member:

All participants and beneficiaries of the Juniper Networks, Inc. 401(k) Plan beginning August 11, 2015, and running through the date of preliminary approval of the settlement.

The “Class Period” is defined as August 11, 2015 through September 15,2023, the date of Preliminary Approval.

Juniper has agreed to pay $3,000,000 into a Settlement Fund, which will be used to pay expenses associated with administering the Settlement, an independent fiduciary’s review of the settlement, attorneys’ fees, and case contribution awards to Plaintiffs (all of which must be approved by the Court), and benefits to Class Members.

The amount of each Class Member’s payment will be based in part on the amounts of his or her Plan account balances over the Class Period, and will be determined according to a Plan of Allocation.

Class Members do not have to submit claim forms in order to receive settlement benefits. The benefits of the Settlement will be distributed automatically once the Court approves the Settlement, either to Class Members’ Plan accounts (for Plan participants with a Plan account) or by check (for former Plan participants without a Plan account, and eligible Beneficiaries and Alternate Payees of Class Members).

If you are a current Plan participant with a Plan account, then you will receive your share of the Settlement Fund in the form of a deposit into your Plan account effective in due course once the Settlement has received final approval and/or after any appeals have been resolved in favor of the Settlement. The hearing to consider the final fairness of the Settlement is scheduled for January 18, 2024.

Any eligible Beneficiaries or Alternate Payees will receive their payment under the Settlement in the form of a check in due course once the Settlement has received final approval and/or after any appeals have been resolved in favor of the Settlement. If you are a former Plan participant without a Plan account, a check in the amount of your share of the Settlement Fund will be issued to you in due course once the Settlement has received final approval and/ or after any appeals have been resolved in favor of the Settlement.

All checks will expire and become void not later than 120 days after they are issued, if they have not been cashed. Any portion of the Settlement Fund remaining after distributions to Class Members, including costs and taxes, shall be paid to the Plan for the purpose of defraying administrative fees and expenses of the Plan. These payments may have certain tax consequences; you should consult your tax advisor. Class Counsel cannot provide tax advice concerning the settlement.

If the Court approves the Settlement, you will be bound by it and will receive whatever benefits you are entitled to under its terms. You cannot exclude yourself from the Settlement, but you may notify the Court of your objection to the Settlement.

If the Court approves the Settlement, it will do so under Federal Rule of Civil Procedure 23(b)(1), which does not permit Settlement Class Members to opt out of the Class.

You can object to the Settlement if you don’t like any part of it. If you object, you must give the reasons why you think the Court should not approve the Settlement. The Court will consider your views. Your objection to the Settlement must be postmarked no later than December 19, 2023 and must be sent to the Court and the attorneys for the Parties

See Section 15 of your Notice for complete instructions.