a. PICARD 1 Class Action
All persons who have registered and paid to participate in the 2020 IRONMAN® 5i50™
triathlon, the 2020 Sprint Mont-Tremblant triathlon, the 2020 IRONMAN 70.3® MontTremblant triathlon, and the 2020 IRONMAN® Mont-Tremblant triathlon (referred
collectively as the “2020 Tremblant Events”) which were cancelled due to the Covid-19
pandemic.

b. PICARD 2 Class Action
All persons who, since July 25, 2017, while residing in the Province of Quebec, have registered
and paid to participate in one of the IRONMAN® or Rock ’n’ Roll® Running Series events
organized by Ironman and WTC in Quebec and which took place or were scheduled to take
place after July 25, 2017.

The following allegations made by the Plaintiff were not proven in Court and are contested by Ironman and WTC, who maintain that they have complied at all times with all applicable legislation and did not commit any wrongdoing of any kind :

a. PICARD 1 Class Action
According to the Plaintiff, Ironman and WTC allegedly engaged in illegal conduct by
neglecting to immediately refund in full the registration fees paid by the members of the
PICARD 1 Class Action for the 2020 Tremblant Events that were cancelled due to the Covid19 pandemic.

b. PICARD 2 Class Action
According to the Plaintiff, Ironman and WTC allegedly required from the members of the
PICARD 2 Class Action a higher price than announced to register for the IRONMAN® or Rock ’n’ Roll® Running Series events organized by Ironman and WTC in Quebec and which took place or were scheduled to take place after July 25, 2017.

Without any admission of liability, for the purpose of avoiding a trial and the additional costs and expenses related thereto, Ironman and WTC agree to the following:

a. PICARD 1 Class Action
Ironman and WTC undertake to honor any refund request made by an eligible PICARD 1
Group Member who, for whatever reason, has not yet obtained a refund at the time of their request, subject to certain conditions.

b. PICARD 2 Class Action
Ironman and WTC implemented a change in business practice, on or around July 30, 2021, whereby new events organized by Ironman and WTC in Canada will now advertise an allin clusive price, excluding taxes and optional costs or services. Ironman and WTC also undertake to grant each eligible PICARD 2 Group Member benefits in the form of one (1) credit (the “Credit(s)”), regardless of the number of registrations made or amount of processing fees incurred by each eligible PICARD 2 Group Member. Each Credit can be turned in for a single, one-time use only, non-transferable, non-refundable, and non-cash convertible credit voucher with a value of CAD $5.98, to be used to register to an event organized by Ironman or WTC.

If you wish to remain a member of the Class Actions, you have no steps to undergo.
However, if you do not wish to be bound by the Class Actions (and the proposed Transaction) for any reason whatsoever, you will need to notify the court office of the Superior Court of Quebec a duly signed request for exclusion at 1, Notre-Dame Street East, Montreal, H2Y 1B6 before March 21, 2022, which includes the court docket number of the Class Action(s) from which you wish to opt out (S.C.M. no. 500-06-001093-208 for the PICARD 1 Class Action and/or S.C.M. no. 500-06-001119-219 for the PICARD 2 Class Action). If you choose to opt out of the Class Actions, you cannot receive any money or benefit from the proposed Transaction and you cannot object to it.

You have the right, as a Member of either the PICARD 1 or PICARD 2 groups (as defined
above), to object to the terms of this Transaction in the manner provided for in the Detailed
Notice and at the latest before May 3, 2022.

Velvet Payments Class Action Services​
5900 Andover Ave. Suite 1
Montreal, Quebec
H4T 1H5

Email: info@velvetpayments.com

Phone: 1-888-770-6892