SAR Rule 10b-5 Exposure Report 1Q 2026

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GLOBAL SCA RULE

10b-5 EXPOSURE

Global SCA Rule 10b-5 Exposure Amounted to $272 Billion in the First Quarter of 2026

Global exposure to Rule 10b-5 private securities-fraud litigation of U.S.-listed companies amounted to approximately $263 billion and $9 billion for U.S. and Non-U.S. Issuers, respectively. i Global fraud-on-the-market exposure rose by 157.6% compared to 4Q’25, driven by heightened filing activity, higher number of alleged corrective disclosures, and greater alleged shareholder losses, most notably in Barrows v. Oracle Corporation et al.

SAR analyzed 55 securities class actions (“SCAs”) against U.S. public corporations that were sued for alleged violations of the federal securities laws under Section 10(b) and 20(a) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, promulgated thereunder (the “Exchange Act”) during 1Q’26. ii SAR’s SCA data presented in this report excludes seven SCAs filed this past quarter (see Appendix-1).

Alleged market capitalization losses based on statistically significant residual stock price returns of U.S.listed corporations amounted to $272.3 billion in 1Q’26, a 157.6% increase from the prior quarter’s global exposure of $105.7 billion. Approximately $51.1 billion, or 15.8% of investor plaintiffs’ alleged market capitalization losses, do not surpass statistical thresholds of stock price reaction to warrant inclusion in a certified SCA. The share of alleged market capitalization losses with no back-end price impact is at its highest level since 1Q'23.

Global SCA Rule 10b-5 Litigation Exposure: Exposure to alleged violations of Rule 10b-5 against U.S. and Non-U.S. Issuers both increased in 1Q’26. Against U.S. Issuers, the increase was driven by a marked increase in observed filing frequency, with filings more than doubling from 25 in 4Q’25 to 52 in 1Q’26, and a surge in alleged corrective disclosures from 44 to 89 during the same period. While the number of econometrically deficient alleged stock drops also doubled from eight to 18, exposure per alleged corrective disclosure increased from $2.3 billion to $3.0 billion. Moreover, more than half of all Rule 10b-5 exposure against U.S. Issuers stemmed from the SCA in Barrows v. Oracle Corporation et al., underscoring the potential outsized impact of a single SCA filing on overall exposure. Non-U.S. Issuers also saw heightened activity, with the number of observed increasing from two to three, and alleged corrective disclosures climbing from three to four.

Trailing 12-month Settlement Values: Over the preceding 12-month period, from April of 2025 through the present, SAR-tracked private Rule 10b-5 settlements (excluding claims with attached Securities Act allegations) have increased in both reported frequency and average settlement values. Seven more claims were reported settled in the latter period than in the former, and the average settlement increased by 7.8%, from $28.8 million to $31.1 million.

Global Securities Class Action Rule

U.S. SCA Rule 10b-5 Exposure Amounted to $263 billion in the First Quarter of 2026

U.S. exposure to Rule 10b-5 private securities-fraud litigation against U.S. Issuers increased by 156.0% during the first quarter of 2026. iv The increase in U.S. SCA Rule 10b-5 Exposure is largely driven by one Exchange Act claim. Notwithstanding the effect of that claim, both observed filing frequency and the number of alleged corrective disclosures rose meaningfully in 1Q’26. Observed filing frequency increased from 25 Rule 10b-5 filings to 52, an alltime high. Alleged corrective disclosures rose from 44 in 4Q’25 to 89 in 1Q’26, representing a 102.3% increase and the highest level recorded since 3Q’24.

SAR analyzed 52 securities claims against U.S. issuers that were sued for alleged violations of the Exchange Act in 1Q’26.v U.S. SCA Rule 10b-5 Exposure (alleged market capitalization losses based on statistically significant residual stock price returns) of U.S. Issuers to claims that allege violations of the Exchange Act amounted to $263 billion. vi

U.S. SCA Rule 10b-5 Litigation Exposure: Investor plaintiffs’ alleged fraud-related market capitalization losses in 1Q’26 are largely attributable to Barrows v. Oracle Corporation et al. The case alone accounts for alleged market capitalization losses of $142.4 billion, or about 54%, of all exposure against U.S. Issuers. Exposure per Exchange Claim Act and per alleged corrective disclosure also increased. Exposure per claim increased from $4.1 billion in 4Q’25 to $5.1 billion in 1Q’26, a 23.1% uptick. Similarly, losses per alleged stock drop climbed by 26.6% to $3.0 billion.

1: U.S. SCA Rule 10b-5 Exposure of U.S. Issuers

[1] Identifed and analyzed first-filed SCA complaints that allege violations of Rule 10b-5. Excludes non-U.S. Issuers that trade on U.S. exchanges through ADRs.

[2] U.S. SCA Rule 10b-5 Exposure is equal to investor plaintiffs alleged market capitalization losses that may surpass back-end price impact thresholds based on exhibited residual stock price declines at the 95% confidence standard.

[3] The average aggregate market capitalization of U.S. Issuers for the corresponding quarter.

[4] The ratio of U.S. SCA Rule 10b-5 Exposure to the aggregate market capitalization of U.S. Issuers ([4] = [2] / [3]).

[5] Number of defendant U.S. Issuers divided by the aggregate number of U.S. issuers.

U.S. SCA Rule 10b-5 Exposure Rate increased from 0.14% in 4Q’25 to 0.37% in 1Q’26. Over the same period, the U.S. SCA Rule 10b-5 Litigation Rate more than doubled, rising from 0.70% to 1.47%, setting a new all-time high. The average aggregate market capitalization of U.S. Issuers declined by 0.7%, from $71.2 trillion in 4Q’25 to $70.8 trillion in 1Q’26, marking the first decline since 1Q’25.

Trailing

Rule 10b-5 Claim Deficiencies Against U.S. Issuers: Approximately $51.1 billion, or 16.3% of alleged market capitalization losses against U.S. Issuers, do not surpass statistical thresholds of stock price reaction at the 95% confidence standard to warrant inclusion in a certified SCA. As a result, $51.1 billion in alleged shareholder losses claimed during the first quarter of 2026 in first-filed SCAs against U.S. Issuers and certain directors and officers may not translate into potential aggregate damages.

Table 2: U.S. Issuer Econometric Summary of Residual Stock Price Reaction

[1] Identified and analyzed first-filed SCA complaints that allege violations of Rule 10b-5. Excludes non-U.S. Issuers that trade through ADRs.

[2] The number of alleged corrective disclosures identified in the sample of first-filed SCA complaints.

[3] Total U.S. SCA Rule 10b-5 Exposure for the identified sample of claims divided by the number of identified alleged corrective disclosures [2].

[4] The number of alleged corrective disclosures that do not exhibit a statistically significant one-day residual stock price return at the 95% confidence standard.

[5] The ratio of the number of alleged corrective disclosures that do not exhibit a statistically significant one-day residual stock price return at the 95% confidence standard to the total number of alleged corrective disclosures. ([5] = [4] / [2])

During 1Q’26, SAR analyzed 57 first-filed “stock-drop” SCAs filed against U.S. Issuers that allege violations of Rule 10b-5 via 99 claimed corrective events or truth-revealing disclosures.vii After analyzing and consolidating cases with seemingly related allegations against individual U.S. Issuers, SAR accounted for and analyzed 52 filed SCAs. A total of 89 alleged corrective disclosures were made in the 52 first-filed SCAs. viii

The number of alleged stock drops increased from 44 in 4Q’25 to 89 in 1Q’26, a rise of 102.3%. During 1Q’26, investor Plaintiffs alleged, on average, 1.7 corrective disclosures per first-filed SCA complaint. Of the 89 corrective disclosures alleged during 1Q’26, the allegedly related residual stock price decline of 18 (or 20.2%) did not surpass statistical thresholds of stock price reaction at the 95% confidence standard, which is highly unfavorable for plaintiffs to successfully establish back-end price impact.ix

This represents the highest proportion of corrective disclosures with price-impact deficiencies since 3Q'24.

20.2% of investor Plaintiffs’ alleged stock drops in the sample of first-filed class action complaints run afoul of the heightened pleading standards of loss causation because they lack statistical significance at the 95% confidence standard to merit potential aggregate shareholder damages after excluding non-company and non-fraud related factors. x

The percentage of alleged corrective disclosures with no price reaction at the 95% confidence standard has ranged between 13.1% and 20.2% over the preceding twelve months. The alleged market capitalization losses per alleged stock drop increased to $3.0 billion in the first quarter of 2026, up from $2.3 billion in 4Q’25.

SCA RULE 10b-5 EXPOSURE BY

INDUSTRY SECTOR FOR U.S. ISSUERS

Industry Sector Impact From Rule 10b-5 Litigation Exposure During the First Quarter of 2026

The industries most impacted by alleged market capitalization losses tied to statistically significant stock drop declines in 1Q’26 were Information Technology (71.6%), Health Care (14.4%), and Financials (4.3%). Together, these sectors accounted for 90.2% of total U.S. SCA Rule 10b-5 Exposure

SAR analyzed 52 first-filed SCAs in 1Q’26. Health Care companies accounted for 15 filings (29%), nine filings (17%) were made against Information Technology, and seven (13.5%) against companies in the Financials sector. No new SCAs were observed against companies in the Energy or Utilities sectors. Utilities companies have not faced Rule 10b-5 private securities litigation since 1Q’25.

Rule 10b-5 Litigation Exposure Industry Trends: In 1Q’26, the Information Technology sector recorded the largest U.S. SCA Rule 10b-5 Exposure at $188.3 billion, exceeding the second largest sector, Health Care, by more than $150 billion. Market capitalization losses in the IT sector were primarily driven by Barrows v. Oracle Corporation et al., which accounted for 75.6% of total sector exposure. At a per Exchange Act claim level, the Consumer Discretionary, Consumer Staples and Material sectors all recorded declines in exposure relative to 4Q’25, with Materials experiencing the steepest drop, falling from $18.3 billion to zero. Observed SCA filings rose across all sectors except Materials and Real Estate, which remained unchanged with one filing each.

Health Care recorded the highest number of alleged corrective disclosures with 21 in 1Q’26. It has consistently been ranked as the sector with the most alleged corrective disclosures since SAR began classifying companies by GICS® in 3Q’24. The IT and Financials sectors followed, with 17 and 12 alleged corrective disclosures, respectively. Exposure per alleged stock drop in Health Care increased from $1.1 billion in 4Q’25 to $1.8 billion, or 60.2%, in 1Q’26, the second consecutive quarterly increase in losses per stock drop. Driven by Barrows v. Oracle Corporation et al., the IT sector exhibited the highest exposure per alleged stock drop in 1Q’26 at $11.1 billion, representing a 28.8% increase from 4Q’25.

SCA RULE 10b-5

EXPOSURE OF U.S. LARGE CAP CORPORATIONS xi

Large Cap SCA Rule 10b-5 Exposure Amounted to $226 Billion During the First Quarter of 2026

The average aggregate market capitalization of U.S. Large Cap corporations, defined as those with market capitalizations greater than $10 billion, was approx. $65.9 trillion.xii This is a decrease of approximately 0.7% relative to 4Q’25. The return of the S&P 500, an index widely recognized as measuring the return to Large Cap companies, between January 1, 2026, and March 31, 2026, was -4.33%.

U.S. Large Cap Rule 10b-5 Litigation Exposure: U.S. Large Cap litigation exposure accounted for 86.0% of the aggregate market capitalization losses alleged against U.S. Issuers, and 83.0% of the global quantum. Exposure recorded the largest quarter-over-quarter increase since 1Q’23, rising from $87.6 billion in 4Q’25 to $226.1 billion in 1Q’26. The increase was driven by a significant rise in market capitalization losses per alleged stock drop, which climbed from $3.4 billion in 4Q’25 to $9.8 billion in 1Q’26, an increase of 191.8%. This steep increase coincided with a 4.33% negative return of the S&P 500, reinforcing the relationship between broader market downturns and elevated alleged market capitalization losses.

U.S. Large Caps exhibited $20.6 billion in statistically significant market capitalization losses per Exchange Act claim. This represents an increase of approximately $13.3 billion, or 181.6%, relative to 4Q’25.

The average number of corrective disclosures per Exchange Act lawsuit decreased from 2.17 to 2.09 quarter-over-quarter. Over the same period, the number of alleged stock drop declined from 26 to 23.

U.S. Large Caps recorded a 0.7% decline in average aggregate market capitalization compared to 4Q’25, marking the first quarter-overquarter decline in over a year.

SCA RULE 10b-5

Mid Cap SCA Rule 10b-5 Exposure Amounted to $18 Billion During the First Quarter of 2026

The average aggregate market capitalization of U.S. Mid Cap corporations, defined as those with market capitalizations between $2 billion and $10 billion, was approximately $3.9 trillion, an increase of 0.3% from 4Q’25.xiv The return of the S&P MidCap 400 between January 1, 2026, and March 31, 2026, was 2.50%.

U.S. Mid Cap Rule 10b-5 Litigation Exposure: Private Rule 10b-5 litigation exposure of U.S. Mid Cap accounted for 6.8% of the aggregate market capitalization losses alleged against U.S. Issuers, and 6.6% of the global quantum. The rise in exposure in 1Q’26 was driven by significant increases in observed filings and alleged corrective disclosures. The number of observed SCA filings against U.S. Mid Cap increased by 350%, from six cases in 4Q’25 to 27 in 1Q’26, setting a new all-time high. Alleged corrective disclosures increased fourfold, from 10 to 40, quarter-over-quarter.

U.S. Mid Caps exhibited $449 million in statistically significant market capitalization losses per alleged stock drop. This is a decrease of 66.0% relative to 4Q’25.

Mid Cap was the only market-cap based category to register an increase in average aggregate market capitalization in 1Q’26, albeit a modest one.

U.S. Mid Caps share of global private rule 10b-5 litigation exposure declined from 12.5% to 6.6% compared to 4Q'25.

Small Cap SCA Rule 10b-5 Exposure Amounted to $19 Billion During the First Quarter of 2026

The average aggregate market capitalization of U.S. Small Cap corporations, defined as those with market capitalizations less than $2 billion, was approximately $988 billion in 1Q’26, a decrease of 2.8% relative to 4Q’25.xvi The return of the S&P SmallCap 600 Index between January 1, 2026, and March 31, 2026, was 3.51%

U.S. Small Cap Rule 10b-5 Litigation Exposure: U.S. Small Cap litigation exposure accounted for 7.22% of the aggregate market capitalization losses alleged against U.S. Issuers, and 6.98% of the global quantum. The number of alleged corrective disclosures increased significantly from eight in 4Q’25 to 26 in 1Q’26 while the number of observed SCA filings doubled during the same period. At $19.0 billion, Small Cap SCA Rule 10b-5 Exposure is at an all-time high.

U.S. Small Cap defendant companies incurred $1.4 billion in statistically significant market capitalization losses per Exchange Act claim. This is an increase of 382.7%, or $1.1 billion, relative to 4Q’25.

U.S. Small Caps exhibited $731 million in statistically significant market capitalization losses per alleged stock drop. This represents an increase of $485 million, or 197.0%, compared to 4Q’25.

The average aggregate market capitalization of Small Cap defendant companies fell back below the $1 trillion threshold.

ADR SCA RULE

10b-5 EXPOSURE

ADR SCA Rule 10b-5 Exposure Amounted to $9 Billion During the First Quarter of 2026

U.S. exposure to Rule 10b-5 private securities-fraud litigation of Non-U.S. Issuers increased from $3.0 billion in 4Q’25 to $9.3 billion during the first quarter of 2026. The increase is driven by a $1.3 billion rise, or 133.6%, in exposure per alleged corrective disclosure.

SAR analyzed three securities claims against Non-U.S. Issuers that were sued for alleged violations of the Exchange Act in 1Q’26.xvii ADR SCA Rule 10b-5 Exposure Exposure alleged market capitalization losses based on statistically significant residual stock price returns) of Non-U.S. Issuers to claims that allege violations of the Exchange Act amounted to $9.3 billion.xviii

Non-U.S. Issuer Rule 10b-5 Litigation Exposure: Over the four most recent quarters, alleged market capitalization losses against Non-U.S. Issuers have shown notable variation. Exposure levels peaked sharply in 3Q’25 at $55.9 billion before settling to $9.3 billion in 1Q’26. Despite these fluctuations, ADR SCA Rule 10b-5 Exposure Rate remained relatively low, ranging from 0.01% to 0.16%, with litigation rates increasing modestly from 0.05% to 0.15%. Observed filings and alleged corrective disclosures showed a gradual rise, with filings increasing from one to three and disclosures from two to four. While exposure per alleged stock drop peaked at $55.9 billion in 3Q’25, it averaged approximately $3 billion across the other three quarters.

[1] Identified and analyzed first-filed SCA complaints that allege violations of Rule 10b-5 against non-U.S. Issuers.

ADR

Rule 10b-5 Exposure for Non-U.S. Issuers

Rule 10b-5 Claim Deficiencies Against Non-U.S. Issuers: All filings against Non-U.S. Issuers in 1Q’26 had econometric significance. In other words, all alleged shareholder losses against Non-U.S. Issuers surpass statistical thresholds of stock price reaction to warrant inclusion in a certified SCA. It is the fifth consecutive quarter where the number of deficient alleged corrective disclosures in ADR Rule 10b-5 filings is zero. Prior to these five quarters, Non-U.S. Issuers had exhibited more variability in corrective disclosures with price impact deficiencies than U.S. Issuers.

Table 8: Non-U.S. Issuer Econometric Summary of Residual Stock Price Reaction

[1] First-filed and analyzed SCA complaints that allege violations of Rule 10b-5 against non-U.S. Issuers that trade on U.S. exchanges through ADRs. Excludes U.S. Issuers. [2] The total number of alleged corrective disclosures identified in the sample of SCA complaints. [3] The total number of alleged corrective disclosures that do not exhibit a statistically significant one-day residual stock price return at the 95% confidence standard. [4] The ratio of the number of alleged corrective disclosures that do not meet statistical thresholds of back-end price impact to the total number of alleged corrective disclosures. ([4] = [3] / [2]).

EMPIRICAL RESULTS OF RULE 10b-5 SETTLEMENT ESTIMATES

Empirical Results of Estimates of Maximum Potentially Available Rule 10b-5 Aggregate Damages

The results of our on-going, independent, empirical analyses on SCA Rule 10b-5 settlements indicate that SAR’s Estimates of Maximum Potentially Available Rule 10b-5 Aggregate Damages continue to be statistically robust determinants of potential settlement amounts using a single explanatory variable.

Our empirical results demonstrate that our Estimates of Maximum Potentially Available Rule 10b-5 Aggregate Damages (calculated around the time when the corresponding securities class action complaints are filed) alone explains approximately 61% of the variation in settlement amounts in simple univariate regressions.xix Our results exhibit highly significant coefficient estimates indicating that a 10% increase in potential aggregate damages predicts an approximate 5.8% increase in the settlement amount. These results are robust and significantly more accurate than proxy-style damages estimate.xx

Rule 10b-5 Settlements to Max. Potential Damages

Rule 10b-5 Settlements to Max. Potential Damages

R2 = 0.61

When additional controls for the U.S. exchange, circuit court, and the plaintiff firm that represents the lead plaintiff are added, our Estimates of Maximum Potentially Available Rule 10b-5 Aggregate Damages can explain approximately 78% of Rule 10b-5 settlement variation as reported by the R-squared measure, and approximately 68% by the adjusted R-squared measure, with the damage’s coefficient indicating that a 10% increase in estimated damages predicts an approximate 5.0% increase in the settlement amount.

Data Science Key Takeaway: SAR's Maximum Potentially Available Rule 10b-5 Aggregate Damages Estimate is the single best predictor of settlement values, explaining over 60% of variation in settlement values in a simple univariate regression.

Rule 10b-5 Private Securities-Fraud Litigation Settlement Rates

Based on our robust empirical results on 276 settled Rule 10b-5 SCAs filed since June 2018, SAR computed the median settlement rates by taking the median quotient of claim-specific settlement amounts (as reported by Institutional Shareholder Services Securities Class Action Services) and our proprietary estimates of Maximum Potentially Available Rule 10b-5 Aggregate Damages.xxi

SAR estimates and tracks quarterly Rule 10b-5 Exchange Act median settlement rates to estimate more accurate potential settlement losses on a claim-specific basis. Estimates of Maximum Potentially Available Rule 10b-5 Aggregate Damages are categorized into severity bands based on the magnitudes of claim-specific loss severity. xxii

Table 9: SCA Rule 10b-5 Settlement Rates

The seven severity band ranges are based on SAR’s clustering analyses of our aggregate severity data and the relative frequency of complaints according to magnitude of estimated damages severity. The median settlement ranges of the bands are statistically distinct. We expect to further refine and add severity band ranges as our ratio population of settlement dollars to our Rule 10b-5 damages estimates expands and our statistical clustering analysis indicates meaningful distinction.

Data Science Key Takeaway: Since 4Q'24, the second-to-largest band, for claims with between $500 million and $1 billion in Estimated Maximum Potentially Available Rule 10b-5 Aggregate Damages, has increased the most in relative terms, with 11 settled claims added to the band, representing a growth rate of 58%. The severity band that has increased the most in terms of the absolute number of claims is the 4th band, representing claims with Estimated Maximum Potentially Available Rule 10b-5 Aggregate Damages of between $100 million and $300 million, which has added 16 claims over the last five quarters.

SAR presents this data and analysis to identify the leading cohort of top performing plaintiff securities class action law firms. To objectively evaluate plaintiffs’ counsel performance in a dynamic legal landscape, SAR utilized two sets of performance criteria to achieve a simple, yet robust, data-driven evaluation.

The first performance selection criterion is the frequency of attaining lead or co-lead counsel. The second is the aggregate settlement value on all settled cases in which a firm participated as lead, co-lead, liaison counsel, or additional counsel. This data is value-relevant to supplement a holistic evaluation of the magnitude of potential loss severity on active SCAs that allege violations of the Exchange Act according to the plaintiff law firms involved.

Primary Performance Factor: Frequency of Attaining Lead or Co-Lead

The Federal Judiciary has the power to assign lead or co-lead counsel privileges according to well-defined case precedent in the private enforcement regime of federal securities laws. To appoint the lead and/or co-lead law firms, the Courts place significant emphasis on the magnitude of trading losses allegedly caused by plaintiffs’ alleged securities fraud against issuers. Achieving lead or co-lead status on any federal securities class action assures the law firm(s) control over leadership, strategy, management, and most importantly – the percentage of the settlement fee award.

Most courts consider: "(1) the total number of shares purchased during the class period; (2) the net shares purchases during the class period (in other words, the difference between the number of shares purchased and the number of shares sold during the class period); (3) the net funds expended during the class period (in other words, the difference between the amount spent to purchase shares and the amount received for the sale of shares during the class period); and (4) the approximate losses suffered." ... While courts differ on the precise weight to apply to each factor, most courts agree that the fourth factor—the approximate losses suffered—is the most salient factor in selecting the lead plaintiff.

The magnitude of trading losses of the proposed lead plaintiff is a significant driver in the court’s selection criteria to decide which law firm(s) will ultimately lead the consolidated action. As a result, SAR’s primary performance selection criteria is the frequency of attaining lead or co-lead as determined by the Federal Judiciary.

Table 10 presents the top ten plaintiff securities class action law firms that exhibited the highest frequency of attaining lead or co-lead counsel in securities class actions that alleged violations of Rule 10b-5 during the preceding eight years.

The effectiveness of economic redress for allegedly defrauded investors in U.S. public companies is regularly evaluated based on the magnitude of aggregate settlements achieved by the participating law firms. As a result, SAR’s secondary performance selection criteria is the magnitude of aggregate settlements achieved by the participating law firms, whether or not they secured lead or co-lead status in the corresponding lawsuits.

Table 11 presents the results of the top ten plaintiff securities class action law firms that exhibited the greatest aggregate settlements in SCAs that alleged violations of Rule 10b-5 during the preceding eight years.

Table 11: Plaintiff Law Firm Aggregate Settlement Rankings

Aggregate Settlement Rankings: The number of settled cases decreased from 19 to 17 relative to 4Q’25. Bernstein Litowitz Berger & Grossman LLP had the highest increase in aggregate settlements, with a gain of $183.0 million. Kessler Topaz Meltzer & Check LLP and Pomerantz LLP followed with $91.0 million and $65.5 million, respectively. Among the Top 10 firms by aggregate settlements, four plaintiff law firms were not involved in any settlements in 1Q'26. Bernstein Litowitz Berger & Grossman LLP was the most active firm, serving as Lead or Co-Lead Counsel in 5 out of the 17 settled cases.

Selection of Top Performing Plaintiff Securities Class Action Law Firms

Selection of the top performing plaintiff securities class action law firms involved identifying those with both the highest frequency of attaining lead and co-lead counsel and achieved the greatest aggregate settlement amounts on the sample of cases analyzed.

Table 12 presents the top plaintiff securities class action law firms identified according to SAR’s two sets of performance criteria. These law firms had the highest frequency of securing lead or co-lead status and achieved the greatest monetary recompense due to allegedly defrauded investors. This table ranks the law firms according to average settlement among 276 settled SCAs.

Table 12: Top Performing Securities Class Action Plaintiff Law Firms

Top Performing Plaintiff Securities Class Action Law Firms: The ranking of SAR’s top performing securities class action law firms did not change with respect to 4Q’25. The top performing law firm continues to be Bernstein Litowitz Berger & Grossman LLP despite experiencing a reduction of almost $10 million in average settlement.

iGlobal SCA Rule 10b-5 Exposure amounts to the sum of U.S. Rule 10b-5 Exposure and ADR Rule 10b-5 Exposure estimates.

iiThis tally accounts for U.S. issuers of common stock and non-U.S. issuers that trade on U.S. exchanges through ADRs that are listed as defendants in first-filed SCA complaints filed during the first quarter of 2026 and allege shareholder damages. It also accounts for claims against such issuers in which Rule 10b-5 allegations were first made in amended filings during 1Q’26. A corporation that was sued a second or third time during the current quarter in non-amended filings is not accounted for in the current quarter’s tally. The tally excludes SCA complaints that were identified but not analyzed per Appendix-1

iiiBetween 1Q'20 and 1Q'2026, SAR's Global SCA Rule 10b-5 Exposure has exhibited an increasing trend of $7.4 billion per quarter, according to simple least-squares regression. That is, the trend since 1Q'20 has been for global market capitalization losses to increase by $7.4 billion every quarter.

ivFigures of Securities Class Action (SCA) Rule 10b-5 litigation exposure are based on identified and analyzed first-filed complaints for each claim filed during the corresponding quarter. They also include claims in which Rule 10b-5 allegations were first made in amended filings during the corresponding quarter. All federal SCA complaints are read by full-time human employees of SAR and screened for allegations that specifically allege violations of Rule 10b-5, define a specific Class Period, identify specific alleged misrepresentations, and allegedly related corrective disclosures. Proprietary non-ML and non-AI cloud-based technology is utilized and relied upon to capture, categorize, and database select constituent data components from each individual SCA complaint. Only the claimed stock price declines presented in the first-filed complaint against each defendant company are accounted for to estimate U.S. SCA Rule 10b-5 Exposure in this report. Measures of SCA exposure for each claim may increase or decrease as the case progresses through the class action life cycle. For purposes of this quarterly informative report, SCA Rule 10b-5 Exposure is not amended retroactively for cases that have been dismissed by the Court or voluntarily dismissed by plaintiffs.

vThis tally accounts for U.S. issuers of common stock that are listed as defendants in first-filed SCA complaints filed during the first quarter of 2026 and allege aggregate shareholder damages. It also includes claims in which Rule 10b-5 allegations were first made in amended filings during 1Q’26. A U.S. issuer of common stock that was sued a second or third time during the current quarter in non-amended filings is not accounted for in the current quarter’s tally. The tally excludes SCA complaints against U.S. issuers of common stock that were sued for alleged violations of the federal securities laws in a previous quarters. The tally also excludes cases that have been filed against international corporations that are listed on U.S. exchanges through American Depositary Receipts (ADRs). The tally excludes SCA complaints that were identified but not analyzed per Appendix-1

viA public corporation’s exposure to alleged violations of Rule 10b-5 is estimated by tracking the cumulative decline in market capitalization during a single market trading session (close-to-close event windows) that correspond with the timing of the claimed alleged corrective disclosures that surpass statistical thresholds of indirect price impact at the 95% confidence standard and are presented in a first–filed SCA complaint. See, Halliburton III 309 F.R.D. 251 (N.D. Tex. July 25, 2015) and Exxon 2023 WL 5415315 (N.D. Tex. Aug. 21, 2023). This figure excludes market capitalization declines of non-U.S. issuers that have been sued for alleged violations of the U.S. federal securities laws and trade on U.S. exchanges through American Depositary Receipts (ADRs).

viiSAR relies on Docket Alerts and Court Wire notifications attained from Thomson Reuters Westlaw. SAR professionals actively monitor and track case dockets to attain newly filed and amended SCA complaints.

viiiThis tally of alleged corrective disclosures includes those from SCA complaints first-filed in 1Q’26 and amended filings in which Rule 10b-5 allegations were first made in 1Q’26 against U.S. issuers of common stock. The tally excludes SCA complaints against companies for which there are relevant first-filed complaints in prior quarters.

ixSee, Halliburton Co. v. Erica P. John Fund, Inc., 134 S. Ct. 2398 (2014); Erica P. John Fund, Inc. v. Halliburton Co., 309 F.R.D. 251 (N.D. Tex. 2015); Goldman Sachs Group Inc. v. Arkansas Teacher Retirement System, 141 S. Ct. 1951 (2021); Arkansas Teacher Retirement System v. Goldman Sachs Group, Inc., 77 F.4th 74 (2d Cir. 2023).

xSee, Dura Pharmaceuticals, Inc. v. Broudo, No. 03-932, 2005 WL 885109 (2005).

xiLarge cap companies are the subset of defendant corporations with market capitalizations greater than $10 billion at the start of the Class Period alleged in the first-filed complaint.

xiiThis is the average total market capitalization of U.S. issuers of common stock that are listed on the NYSE or Nasdaq exchanges with market capitalizations greater than $10 billion between January 1, 2026 and March 31, 2026.

xiiiMid cap companies are the subset of defendant corporations with market capitalizations greater than $2 billion and less than $10 billion at the start of the Class Period alleged in the first-filed complaint.

xivThis is the average total market capitalization of U.S. issuers of common stock that are listed on the NYSE or Nasdaq exchanges with market capitalizations between $2 billion and $10 billion between January 1, 2026 and March 31, 2026.

xvSmall cap companies are the subset of defendant corporations with market capitalizations less than $2 billion at the start of the Class Period alleged in the first-filed complaint.

xviThis is the average total market capitalization of U.S. issuers of common stock that are listed on the NYSE or Nasdaq exchanges with market capitalizations less than $2 billion between January 1, 2026 and March 31, 2026.

xviiThis tally includes both SCA complaints against non-U.S. issuers that trade on U.S. exchanges first-filed in the current quarter and claims in which Rule 10b-5 allegations were first made in amended filings during the current quarter. A non-U.S. issuer of ADRs that was sued a second or third time during the current quarter is not accounted for in the current quarter’s tally. The tally excludes SCA complaints that were identified but not analyzed per Appendix-1

xviiiA non-U.S. issuer’s exposure to alleged violations of Rule 10b-5 is estimated by tracking the cumulative decline in market capitalization during open market trading sessions that correspond with the timing of the claimed alleged corrective disclosures that surpass statistical thresholds of indirect price impact and are presented in a first-filed SCA complaint.

xixThese results are based on a sample of 276 recently settled SCAs, and exclude settled SCAs that allege violations of both the Exchange Act and Securities Act. These specific performance metrics are based on log-log regressions that exclude the few settled cases for which Estimates of Maximum Potentially Available Rule 10b-5 Aggregate Damages are zero, due to all of the alleged stock drops exhibiting a non-statistically significant residual stock price decline at the 95% confidence standard and greatly prohibiting the determination of back-end stock price impact, in accordance with the Supreme Court ruling, in Arkansas Teachers Retirement System v. Goldman Sachs, made effective June 21, 2021. Non log-log regressions that include these fully deficient securities claims that settled for a monetary sum perform similarly in terms of their explanatory power.

xxThe applied methodology for accumulating maximum potential alleged artificial inflation that investors claim is embedded in the defendant’s price of common stock, is the industry-accepted constant dollar method. Aggregate market data supplied by S&P Global Market intelligence is used to compute an appropriate level of daily effective float by taking into consideration and accounting for the effects of insider holdings and short interest on a daily basis throughout the corresponding class period based on the allegations of the corresponding class action complaint. For purposes of this informative quarterly report, no reduction to issue-specific float is made to account for institutional investor trading volume that may not be affected by and during investor plaintiffs alleged class period. A refined estimate of effective float may be computed in a litigation-specific context to control for institutional holdings that may not warrant inclusion in the estimation of the defendant’s effective float for a more accurate estimation of Maximum Potentially Available Rule 10b-5 Aggregate Damages. An adjustment to exchange-reported trading volume is made to account for common stock traded by designated market-makers or broker dealers who are acting as market-makers. Other specific refinements to exchange-reported volume may be made in a litigation-specific context based on data attained through discovery, for example when tracing issues may be present. The estimation of allegedly damaged shares during the operative class periods are made by applying a pre-calibrated, and industry-accepted two-trader model with static model inputs for each of the respective investor cohorts. The use of an industry-accepted quantitative model is a widely accepted technique used in securities class action litigation by established Plaintiff and Defense experts to estimate the number of alleged and potentially damaged shares because class counsel may not have the ability to attain the entire universe of trading records of all participants in the market that bought and sold publicly traded common stock of the corresponding share class in the U.S.-listed company during investor plaintiffs alleged inflationary period. The Estimate of Maximum Potentially Available Rule 10b-5 Aggregate Damages is based on the attribution of 100% of the residual stock price decline for each alleged corrective disclosure that exhibited a statistically significant residual stock price decline at the 95% confidence standard and using a close-to-close, single trading session event window. The limitation to maximum potentially attributable artificial stock price inflation that investor plaintiffs allege to be embedded in the price of common stock may be refined in litigation-specific circumstances based on the results of news discovery analyses to determine the magnitude of potential confounding information disclosed to participants in the market on the affected day. The Estimate of Maximum Potentially Available Rule 10b-5 Aggregate Damages applies Section 21D(e) of the Private Securities and Litigation Reform Act of 1995 (PSLRA) 90-day look-back limitation on damages on the final alleged corrective disclosure that exhibited a statistically significant residual stock price decline at the 95% confidence standard and using a close-to-close, single trading session event window. In a litigation-specific circumstance, the 90-day look-back limitation to aggregate damages may applied and extended on all surviving alleged corrective disclosures that may exhibit back-end price impact which may further reduce the Estimates of Maximum Potentially Available Rule 10b-5 Aggregate Damages.

xxiTo maintain high standards of quality and objectivity in estimating banded median settlement rates on settled Rule 10b-5 claims, SAR reconciles the operative class period and corresponding alleged corrective disclosures with those presented in the Plan of Allocation post settlement approval when it is made publicly available.

xxiiSAR’s Estimate(s) of Maximum Potentially Available Rule 10b-5 Aggregate Damages for each identified case and its respective settlement amount are adjusted for inflation by conversion to 2025 dollar equivalents for the purposes of estimating median band settlement rates. The inflation adjustment for Estimate(s) of Maximum Potentially Available Rule 10b-5 Aggregate Damages is based on the end of Class Period of the operative complaint.

The following list includes Rule 10b-5 Exchange Act SCAs filed in 1Q'26 against U.S. Issuers of common stock or ADRs that were not analyzed by SAR. These cases were excluded for one or both of the following reasons: (1) insufficient pricing data to support a multivariate regression consistent with SAR’s quality control standards; and/or (2) the claims assert potentially novel theories of Rule 10b-5 liability.

U.S. Securities Class Action Rule 10b-5 Exposure Report Disclaimer

This securities litigation exposure research report presents the market capitalization losses of the alleged stock drops claimed by investor plaintiffs in first-filed Rule 10b-5 private securities-fraud class actions filed during the 1Q'26. SAR applies uniform, back-tested, regression-based event study analyses with court-approved parameters for accurate and verifiably independent estimates of litigation exposure according the allegations presented in the corresponding first-filed class action complaints.

All content published by SAR and presented in this quarterly securities litigation exposure research report is based on securities analytics research performed by professionals employed by SAR. SAR does not apply or rely on machine learning (ML) or artificial intelligence (AI) to compute the quantitative and statistical analyses presented herein.

Publicly available research published by SAR that contains economic estimates on the impact of securities litigation risk and potential litigation exposure are only estimates, and actual results may vary from those estimates or projections, which are based on many variables, assumptions, and forecasts, many of which are beyond the control of SAR and any of which may present differences with estimates that are quantified using different techniques that may not be accepted in legal proceedings across the U.S. Federal Judiciary.

No fraud or wrongdoing of any kind is alleged or implied by the information published and made publicly available by SAR in this research report.

Sources: ISS SCAS, FINRA, S&P Global Market Intelligence, S&P Dow Jones Indices, Thomson Reuters, SAR Platform® as of March 31, 2026.

Report Authors:

Nessim Mezrahi CEO

T: 202.891.360

E: Nessim@sarlit.com

Stephen Sigrist Senior Vice President

T: 202.891.3652

E: Stephen@sarlit.com

Rolando Hernandez Senior Analyst

T: 202.436.9994

E: Rolando@sarlit.com

About Securities Analytics Research (SAR): SAR LLC is a specialized data analytics company focused on securities litigation risk management analytics of U.S. public companies, founded in 2018 and based in Bethesda, MD. Through the SAR Platform®, users license verifiably independent and high-quality data analytics based on near real-time stock price performance in response to public companies' corporate disclosures. SAR is the developer and publisher of the SAR Risk Score®, which is assigned to issuers that trade on the NYSE or NASDAQ at the close of trading. SAR applies the court-approved event study methodology to test stock price reaction on the universe of corporate disclosures to accurately estimate the probability and magnitude of securities litigation risk impacting directors and officers. SAR provides verifiably independent securities class action settlement valuations as evidentiary support in mediated negotiations that resolve securities claims that allege violations of the federal securities laws under the Exchange Act of 1934 and Securities Act of 1933. The company is committed to the verifiable independence and accuracy of the licensed data and has been publishing quarterly statistical back-testing results since 2018. SAR does not rely on artificial intelligence (Al) or machine learning (ML) and operates in accordance with documented standard operating procedures with assigned process owners to ensure independent, human accountability. The company does not engage in economic consulting, nor places capital at risk on behalf of investors or insurers. SAR does not actively trade, hold, or intend to hold positions on the universe of equity issuances listed on the NYSE or NASDAQ, and whose principals and full-time professionals are restricted from actively trading.