Opendoor $39 Million Securities Class Action Settlement

Shareholders who purchased or otherwise acquired Opendoor Technologies Inc. (NASDAQ: OPEN; CUSIP: 683712103) common stock pursuant and/or traceable to the company’s de-SPAC merger or its February 2021 offering, or who purchased on the NASDAQ or any U.S.-based trading platform between Dec. 21, 2020, and Nov. 3, 2022, and suffered damages, may be eligible to claim a cash payment from a class action settlement.

Opendoor Technologies Inc. agreed to pay $39,000,000 to settle a class action lawsuit alleging it and certain defendants made materially false and misleading statements about the company’s proprietary pricing algorithm and its ability to adjust to changing market conditions. The lawsuit claimed these statements artificially inflated Opendoor’s stock price and caused investor losses when corrective information emerged.

Who is eligible to file a claim?

Class members must meet one or more of the following criteria:

• They purchased or otherwise acquired Opendoor common stock pursuant and/or traceable to the de-SPAC merger documents issued on or about Dec. 21, 2020.
• They purchased or otherwise acquired Opendoor common stock pursuant and/or traceable to the February 2021 offering documents issued on or about Feb. 4, 2021.
• They purchased Opendoor common stock on the NASDAQ or any U.S.-based trading platform between Dec. 21, 2020, and Nov. 3, 2022, inclusive, and were damaged thereby.

Both individuals and entities can be class members.

How much is the securities payout?

The total settlement fund is $39,000,000. The amount each class member may receive depends on several factors:

• The total number of valid claims filed
• The number of shares purchased or acquired
• The timing of purchases and sales
• The total recognized losses of all claimants

The settlement administrator will distribute settlement payments on a pro rata basis according to a court-approved plan of allocation:

• The average distribution per common share is approximately $0.04 per allegedly damaged share before deductions for attorneys’ fees and litigation expenses and approximately $0.03 per share after those deductions. Actual payments may be higher or lower depending on each claim and the total number of valid claims.
• The settlement administrator calculates each claimant’s payment using a recognized loss formula.
• For class members who purchased or acquired shares through the de-SPAC merger or the February 2021 offering, the settlement administrator will calculate purchases under Section 11 methodologies.
• For class members who purchased their shares on the open market during the class period, the administrator will apply a 90% discount to those purchases to reflect litigation risks, such as the dismissal of certain claims and tracing challenges.

• The settlement administrator will reduce payments on a pro rata basis if total recognized losses exceed the net settlement fund.
• Claimants whose payment would be less than $10 will not receive a payout.

How to claim a settlement payment

Class members can file a claim online or download, print and complete the PDF claim form and mail it to the settlement administrator. The claim deadline is Dec. 27, 2025.

Settlement administrator's mailing address: Opendoor Securities Settlement, c/o Verita Global LLC, P.O. Box 301171, Los Angeles, CA 90030-1171

Proof or documentation required to submit a claim

• All class members must provide the last four digits of their Social Security number or their full taxpayer identification number.
• They must also provide purchase, acquisition and sale information, including:
• Trade dates
• Number of shares purchased, acquired or sold
• Total purchase, sale or acquisition price

• Claimants must provide documentation to support their transactions in Opendoor common stock or SCH shares. Acceptable forms of proof include:
• Broker confirmation slips
• Broker account statements
• Authorized statements from a broker containing the transactional information found in a confirmation slip
• Other documentation the claims administrator deems adequate

$39 million settlement fund

The $39,000,000 settlement fund includes:

• Notice and administration costs: To be determined
• Attorneys’ fees: Up to $11,700,000
• Attorneys’ expenses: Up to $650,000
• Payments to eligible class members: The remainder of the fund

Important dates

• Deadline to request exclusion: Dec. 16, 2025
• Deadline to file a claim: Dec. 27, 2025
• Fairness hearing: Jan. 6, 2026

Why is there a class action settlement?

The class action lawsuit alleged Opendoor Technologies Inc. and certain defendants made false or misleading statements about the company’s proprietary pricing algorithm and its ability to adjust to market conditions, which allegedly caused Opendoor’s stock to trade at artificially inflated prices and investors to suffer losses when corrective information emerged.

The defendants denied all allegations of wrongdoing and liability but agreed to settle to avoid the costs, risks and delays of further litigation.

Sources

1. Class notice
2. Claim form
3. Settlement agreement