Summary Notice of Pendency and Proposed Settlement of Class Action for All Purchasers or Acquirers of Fluor Corporation Common Stock

SEATTLE, June 23, 2022 /PRNewswire/ --

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS

SUMMARY NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION

TO: All persons or entities who purchased, or otherwise acquired, the common stock of Fluor Corporation ("FLUOR") (NYSE: FLR) between August 14, 2013 and February 14, 2020, both dates inclusive.

YOU ARE HEREBY NOTIFIED, pursuant to Rule 23 of the Federal Rules of Civil Procedure and an Order of the United States District Court for the Northern District of Texas that a hearing will be held on November 7, 2022, at 10:00 a.m. before the Honorable Brantley Starr, United States District Judge, at the courthouse for the United States District Court, Northern District of Texas, 1100 Commerce Street, Courtroom 1525, Dallas, TX 75242 for the purpose of determining: (1) whether the proposed Settlement of the claims in the above-captioned Action for consideration in the amount of Thirty-Three Million dollars($33,000,000) should be approved by the Court as fair, reasonable, and adequate; (2) whether the Plan of Allocation is fair and reasonable, and should be approved; (3) whether Lead Counsel's application for an award of attorneys' fees of up to thirty percent (30%), and payment of litigation costs and expenses of not more than two hundred thousand dollars ($200,000.00), plus interest on such fees and expenses, and awards for Lead Plaintiffs of not more than seventy-five thousand dollars($75,000.00) in the aggregate, all to be paid from the Settlement Fund, should be approved; and (4) whether this Action should be dismissed with prejudice against the Defendants as set forth in the Stipulation of Settlement dated March 25, 2022 (the "Stipulation"), filed with the Court.

YOU ARE ALSO NOTIFIED, that the Court has certified a class of investors for settlement purposes only ("Settlement Class") and you may be a member of the Settlement Class ("Settlement Class Member"). The proposed Settlement Class will consist of all persons or entities who purchased, or otherwise acquired, the common stock of Fluor (NYSE: FLR) between August 14, 2013 and February 14, 2020, both dates inclusive (the "Settlement Class Period"). Excluded from the Settlement Class are the Defendants; members of the immediate families of the Individual Defendants; Fluor's subsidiaries and affiliates; any person who was an officer or director during the Settlement Class Period; any entity in which any Defendant has a controlling interest; the judges presiding over the Action and the immediate family members of such judges; the legal representatives, heirs, successors and assigns of any such excluded person or entity; and persons who submit valid and timely requests for exclusion from the Settlement Class.

If you purchased or acquired Fluor common stock during the Settlement Class Period, your rights may be affected by this Action and the Settlement thereof, including the release and extinguishment of claims you may possess relating to your ownership interest in Fluor common stock. You may obtain copies of the Notice of Proposed Settlement of Class Action, Motion for Attorneys' Fees and Expenses, and Settlement Fairness Hearing ("Notice") and the Proof of Claim and Release Form, and the Stipulation by downloading them at the Settlement website at: www.FluorSecuritiesSettlement.com. If you are unable to do so, you may contact the Claims Administrator to obtain copies:

Fluor Securities Settlement
c/o JND Legal Administration
P.O. Box 91325
Seattle, WA 98111
Tel: (888) 964-2130
info@FluorSecuritiesSettlement.com

The case has been litigated since May 25, 2018. Lead Plaintiffs plead that, in violation of the U.S. federal securities laws, Defendants made material misrepresentations and omissions, with scienter, concerning the business operations, accounting treatment, and financial reporting concerning Fluor's fixed-price projects causing Fluor's common stock price to be inflated during the Settlement Class Period. Lead Plaintiffs further plead that revelation of Defendants' fraud caused statistically significant stock declines, thereby injuring Lead Plaintiffs and the Settlement Class of investors. Defendants have denied and continue to deny these allegations and that they committed any act or omission giving rise to any liability or violation of the law. The Settlement will resolve the lawsuit and the Released Claims as to the Defendants and other Released Parties. Lead Plaintiffs and the Settlement Class are represented by Lead Counsel who may be reached by contacting: Matthew L. Tuccillo or Jennifer B. Sobers, Pomerantz LLP, 600 Third Avenue, 20th Floor, New York, NY 10016, (212) 661-1100 and/or Darryl Alvarado or Ellen Gusikoff Stewart, Robbins Geller Rudman & Dowd LLP, 655 West Broadway, Suite 1900, San Diego, CA 92101, (800) 449-4900.

If you are a Settlement Class Member, in order to share in the distribution of the Net Settlement Fund, you must submit a Proof of Claim and Release Form received by mail or online no later than October 14, 2022, establishing that you are entitled to recovery. Unless you submit a written exclusion request, you will be bound by any Judgment rendered in the Action whether or not you make a claim.

If you want to be excluded from the Settlement Class, you must submit to the Claims Administrator a request for exclusion, in accordance with the procedures set forth in the long-form Notice, so that it is received no later than October 17, 2022. If you decide to exclude yourself from the Settlement Class and wish to file your own individual lawsuit based on the Released Settlement Class Claims, Defendants may argue that you face a time bar under applicable statutes of limitation or repose, risks that you should discuss with an appropriate legal advisor. All members of the Settlement Class who have not requested exclusion from the Settlement Class will be bound by any Judgment entered in the Action pursuant to the Settlement Stipulation.

If you are a Settlement Class Member and do not exclude yourself, you can object to the Settlement, Plan of Allocation, or Lead Counsel's request for an award of attorneys' fees and expenses and awards to Lead Plaintiffs in the manner and form explained in the detailed long-form Notice and received no later than October 17, 2022.

Any questions regarding the Settlement should be directed to Lead Counsel for the Settlement Class.

PLEASE DO NOT CONTACT THE COURT, THE CLERK'S OFFICE, THE DEFENDANTS, OR DEFENDANTS' COUNSEL REGARDING THIS NOTICE.

BY ORDER OF THE COURT
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS

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SOURCE JND Legal Administration