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Iomega Class Action Lawsuit Proposed Settlement

 IN THE CHANCERY COURT OF THE STATE OF DELAWARE
 IN AND FOR NEW CASTLE COUNTY

__________________________________________
                                          )
BRANDON COX, by EDWARD COX,               )
his natural guardian and next friend,     )
JOHN KREPS, and MARK                      )
SOLOMON, M.D.,                            )
Individually and On Behalf of All Others  )
Similarly Situated,                       )
                                          )
Plaintiffs,                               )
                                          )     Civil Action No.:
v.                                        )      15809
                                          )
IOMEGA CORPORATION,                       )
Defendant.                                )
                                          )
__________________________________________)


 NOTICE OF PENDENCY OF CLASS ACTION
 AND HEARING ON PROPOSED SETTLEMENT

TO: ALL PERSONS WHO PURCHASED IOMEGA ZIP(r), JAZ(r), AND 
DITTO(tm) DRIVES BETWEEN JULY 16, 1994 AND SEPTEMBER 1, 
1997

THIS NOTICE IS GIVEN TO INFORM YOU OF THIS CLASS ACTION WHICH 
IS PENDING, ON YOUR BEHALF, IN THIS COURT.  THIS NOTICE IS ALSO GIVEN 
TO ADVISE YOU OF THE PROPOSED SETTLEMENT OF THIS CLASS ACTION.  IF 
THE SETTLEMENT IS APPROVED BY THE COURT, CERTAIN BENEFITS WILL BE 
CONFERRED ON THE MEMBERS OF THE CLASS.  THIS NOTICE CONCERNS YOUR 
LEGAL RIGHTS.  PLEASE READ IT CAREFULLY.

NOTHING IN THIS NOTICE SHOULD BE CONSTRUED AS AN EXPRESSION BY 
THE COURT ABOUT THE MERITS OF THIS LAWSUIT OR THE SETTLEMENT.

DEFINITIONS

The following terms are defined in the Stipulation of 
Settlement of Class Action as set forth below:

1. "Call Center Knowledgebase" or "Database" means a 
computer database to contain problem and associated solution 
information regarding each Iomega computer data storage device 
("drive"), including Iomega Zip, Jaz, and Ditto drives, along with 
other Iomega products.  The Database is to be updated regularly and 
promptly based on information generated by Iomega personnel from 
internal Iomega product testing, customer interaction by telephone, 
the internet, and other means.  The information housed in the 
Database will be accessible by or provided as applicable through the 
Virtual Consultant, the IVR System, the Iomega "Fax-Back" program, 
and Iomega technical support personnel.

2. "Charged Customer" means each person within the Class who 
Iomega charged either $14.99 for a technical support call in 
connection with a Zip or Ditto drive, or $19.99 for a technical 
support call in connection with the Jaz drive.

3. "Claimant" means any Class Member who does not file a 
valid and timely Request for Exclusion, as provided in the Notice.

4. "Class" means the Class Representatives and all other 
similarly situated persons in the United States who purchased Iomega 
drives, including Zip, Jaz, or Ditto drives between July 16, 1994 and 
September 1, 1997.  Excluded from the Class are Iomega, any entity in 
which Iomega has a controlling interest and their directors and 
senior officers.

5. "Class Claims" shall refer to any manner of action and 
causes of action, claims, suits, arbitrations, obligations, debts, 
demands, agreements, promises, liabilities, damages, judgments, 
decrees, controversies, costs and expenses, or attorneys fees, 
whether based on federal law, state law, common law or otherwise, 
foreseen or unforeseen, matured or unmatured, known or unknown, 
accrued or unaccrued, suspected or unsuspected (whether class or 
individual in nature), which have been, ever could have been, or can 
hereafter be asserted by the Plaintiffs, the Class Members, or the 
Claimants, or any one of them, against Iomega or the Releasees, in 
connection with, arising out of, or relating in any way to (a) the 
Complaint, or (b) the acts, failures to act, omissions, 
misrepresentations, statements, misstatements, facts, events, 
transactions, occurrences, or other subject matters set forth, 
alleged, embraced, encompassed, or otherwise referred to in or 
underlying the Complaint, including, without limitation, any and all 
claims or cross-claims for violations of federal, state, common or 
other law arising from such subject matters.

6. "Class Counsel" means Lawrence E. Feldman, Kenneth J. 
Benton, Gail L. Gottehrer, Lawrence E. Feldman & Associates, 
Jenkintown Plaza, 101 Greenwood Ave., Suite 230, Jenkintown, PA 
19046, Mark C. Rifkin, Greenfield & Rifkin LLP, 800 Times Building, 
Ardmore, PA 19003, and Jeffrey S. Goddess and Joseph A. Rosenthal, 
Rosenthal, Monhait, Gross & Goddess, P.A., Suite 1401, Mellon Bank 
Center, P.O. Box 1070, Wilmington, DE 19899-0170.


7. "Class Member" means the Plaintiffs and any 
Person who fits within the definition of the Class.

8. "Class Period" means the period between July 
16, 1994 and September 1, 1997.

9. "Class Representatives" means, collectively, 
Brandon Cox, a fifteen year old minor residing at 7715 
Rosehill Road in Lenexa, Kansas and bringing this action 
through Edward Cox, his father, natural guardian and next 
friend; John Kreps, an adult individual residing at 4020 
Lakewood Drive, Ft. Worth, Texas; and Mark Solomon, M.D., 
an adult individual residing at 965 Dale Road in 
Meadowbrook, Pennsylvania, and, as applicable, their 
predecessors, subsidiaries, affiliates, officers, 
directors, partners, employees, agents, servants, 
assignees, licensees, heirs, successors, and/or other 
transferees or representatives.

10. "Complaint" means the Complaint filed on July 
18, 1997 and the First Amended Complaint filed on August 
22, 1997 in the Litigation.

11. "Court" means the Court of Chancery of the 
State of Delaware in and for New Castle County.

12. "Final Approval" means approval of this 
settlement by the Court as fair, reasonable and adequate 
pursuant to Delaware Chancery Court Rule 23(e) containing 
in substance the provisions set forth in paragraph H 
below and in substantially the form of the Final Order 
and Judgment.

13. "Final Order and Judgment" means an order of 
the Court granting Final Approval in substantially the 
form of the Final Judgment and Order of Dismissal which 
is attached hereto as Exhibit 2.

14. "Interactive Voice Response System" or "IVR 
System" means a 24-hour automated, interactive telephone 
technical support system capable of responding, through 
use of a decision tree and pre-recorded voice responses, 
to customer technical support inquiries about Iomega Zip, 
Jaz, and Ditto drives.  Said system will allow a customer 
calling for technical support to save his or her 
technical support session so that the session can be 
resumed in a subsequent telephone call without 
reinitiation of the session from the beginning.

15. "Iomega" means Iomega Corporation, a Delaware 
corporation with its principal place of business in Roy, 
Utah, its predecessors, subsidiaries, affiliates, 
officers, directors, partners, employees, agents, 
servants, assignees, licensees, successors, and/or other 
transferees or representatives.


16. "Iomega's Counsel" means Jeffrey B. Rudman, 
James W. Prendergast, and Gabrielle R. Wolohojian, Hale 
and Dorr LLP, 60 State Street, Boston, Massachusetts 
02109, and Jesse A. Finkelstein, Richards Layton & 
Finger, One Rodney Square, P.O. Box 551, Wilmington, 
Delaware 19899.

17. "Iomega Warranty" or "Warranty" means the 
written Iomega product warranty accompanying a drive or 
other Iomega product, whether designated as or otherwise 
deemed a "full" or "limited" warranty under the Magnuson-
Moss Consumer Products Warranties Act, 15 U.S.C. (S)2301 
et seq., and the rules, regulations, and interpretations 
promulgated thereunder ("MMA").

18. "Litigation" means the class action entitled 
Brandon Cox, by Edward Cox, his natural guardian and next 
friend, John Kreps, and Mark Solomon, M.D., Individually 
and on Behalf of All Others Similarly Situated, v. Iomega 
Corporation, Civil Action No. 15809, now pending before 
the Court.

19. "Notice" means the Notice of Pendency of Class 
Action and Hearing on Proposed Settlement to be sent 
and/or otherwise made available to members of the Class, 
as set forth below in paragraph E below, in substantially 
the form attached as Exhibit A to the Preliminary Order.

20. "Notice Costs" means the costs of physical 
preparation, including duplication, printing, mailing and 
publication expenses (but specifically excluding all 
Class Counsel's fees and Class Counsel's costs) incurred 
in connection with providing notice of this Stipulation 
and the proposed settlement to the Class via the Notice 
and Summary Notice.

21. "Person" means, without limitation, any 
individual, corporation, partnership or any other entity, 
and his, her, or its legal representative.

22. "Plaintiffs" means Brandon Cox, by Edward Cox, 
his natural guardian and next friend, John Kreps, Mark 
Solomon, M.D., and, as applicable, their predecessors, 
subsidiaries, affiliates, officers, directors, partners, 
employees, agents, servants, assignees, licensees, heirs, 
successors, and/or other transferees or representatives.

23. "Preliminary Order" means the order of the 
Court approving the form and manner of notice to the 
Class containing in substance the provisions set forth in 
paragraph F below and in substantially the form of the 
Order Re: Hearing and Approval of Form and Manner of 
Giving Notice to Class which is attached hereto as 
Exhibit 1.

24. "Releasees" means Iomega, and its present and 
former trustees, directors, partners, principals, 
officers, employees, attorneys, insurers, parents, 
subsidiaries, affiliates, divisions, and any predecessor 
or successor partnerships, corporations or entities, and 
any person or entity controlled by them or controlling 
them.

25. "Request for Exclusion" means a request by a 
Class Member to be excluded from the Class pursuant to 
Delaware Chancery Court Rule 23.


26. "Settlement Effective Date" means, as more 
fully set forth in paragraph C(2) below, the date by 
which the Court's approval of this settlement becomes 
final and all appeals, if any, have been exhausted.

27. "Settlement Hearing" means the hearing held by 
the Court to consider Final Approval of this settlement, 
pursuant to Delaware Chancery Court Rule 23(e).

28. "Stipulation" means this Stipulation of 
Settlement of Class Action and all exhibits attached 
hereto.

29. "Summary Notice" means the Summary Notice of 
Pendency of Class Action and Hearing on Proposed 
Settlement, to be published in USA Today, the Wall Street 
Journal, PC Magazine, PC World and on Iomega's World Wide 
Web page, as set forth below in paragraph E below, in 
substantially the form attached as Exhibit B to the 
Preliminary Order.

30. "Virtual Consultant" means a 24-hour automated 
and interactive technical support system to be maintained 
on Iomega's World Wide Web internet page, that will be 
based upon case-based reasoning technology capable of 
responding to customer technical support inquiries 
through (1) a basic single question/single answer format, 
(2) a more advanced multiple question/multiple answer 
format, (3) a decision tree format, and (4) generated 
case queries using fuzzy logic.  Said system also will 
include an on-line tutorial to instruct the user in 
operation of the system and will provide technically 
feasible graphics illustrating the most frequently asked 
technical support questions concerning Zip, Jaz and Ditto 
drives.  The system will be designed to permit access by 
at least 250 concurrent users.

 BACKGROUND AND DESCRIPTION OF THIS LITIGATION

1. On July 18, 1997, this class action was 
brought by plaintiffs Brandon Cox, a fifteen year old 
minor, through Edward Cox, his father, natural guardian 
and next friend, John Kreps, and Mark Solomon, M.D. 
(collectively, the "Class Representatives") against 
Iomega Corporation ("Iomega").  On August 22, 1997, the 
plaintiffs filed a First Amended Complaint.


2. The plaintiffs brought this lawsuit on 
behalf of themselves and all others similarly situated, 
claiming, among other things, that the warranties on 
Iomega's Zip, Jaz and Ditto drives implied that Iomega 
would provide technical support at no charge to customers 
with technical questions or problems.  The plaintiffs 
also claimed that where customers with Zip, Jaz, and 
Ditto drives called Iomega's customer or technical 
support lines for help, they were put on hold for 
unreasonably long periods.  The plaintiffs further 
challenged the description of the Warranty issued by 
Iomega for certain of its Zip, Ditto, and Jaz drives.  
The plaintiffs alleged that the long hold times, the fees 
charged for certain technical support calls, and the 
wording of Iomega's warranties gave rise to claims under 
the Magnuson-Moss Consumer Products Warranties Act, 15 
U.S.C. (S)2301 et seq. ("MMA") and the regulations 
promulgated in connection therewith, breach of warranty, 
the Delaware Consumer Fraut Act, 6 Del.C. (S)(S)2511-
2526, breach of the implied convenant of good faith, and 
sought declaratory action.
   
3. On January 23, 1998, the parties to this 
lawsuit filed with the Court a Stipulation of Settlement 
of Class Action ("Stipulation") and jointly requested 
that the Court certify this case as a class action, with 
Brandon Cox, through Edward Cox, his father, natural 
guardian and next friend, John Kreps, and Mark Solomon, 
M.D. to serve as representatives of the Class.

4. For the purposes of this settlement, the 
Court has entered an Order which preliminarily determined 
that the Plaintiffs fairly and adequately represent the 
interests of the Class and are proper parties to assert 
any and all Class Claims in the action.  The Court also 
has preliminarily certified that this action shall and 
may be maintained as a class action, by the plaintiffs as 
class representatives.  The Class consists of:

All persons in the United States who purchased 
Iomega data storage devices, including Zip, 
Jaz or Ditto drives between July 16, 1994 and 
September 1, 1997.

Excluded from the Class are Iomega, any entity in which 
Iomega has a controlling interest, and any of Iomega's 
subsidiaries, affiliates, officers, directors, or 
employees.  

5. Iomega denies any liability or 
wrongdoing which is alleged in the Complaint and in the 
First Amended Complaint, but has decided to enter into 
this settlement in order to confer substantial benefits 
upon its customers.

6. The Court has not ruled on the merits of 
the claims asserted by the plaintiffs in the Complaint or 
the First Amended Complaint.

7. Counsel for the plaintiffs and the Class 
have made a thorough investigation of the law and facts 
relating to the allegations of the Complaint and the 
First Amended Complaint and the defenses likely to be 
asserted by Iomega. In addition, Counsel has diligently 
reviewed the nature of the relief proposed herein.  That 
investigation has included study of publicly available 
information, as well as analysis of thousands of 
documents produced by Iomega.  As part of their 
investigation of the claims raised in the Complaint and 
the defenses to be raised by Iomega to those claims, 
Counsel for the plaintiffs have also taken confirmatory 
discovery, including depositions of: (a) Iomega's Senior 
Director of Customer Satisfaction who is responsible for 
customer and technical support and for the proposed 
relief contained herein, (b) Iomega's head of 
advertising, and (c) Iomega's consultant charged with 
collecting information identifying potential members of 
the Class.

 THE PROPOSED SETTLEMENT

8. Under the Stipulation:


a. For the two year period beginning on the 
Settlement Effective Date, Iomega shall at its 
expense establish and maintain a Virtual 
Consultant, a 24-hour automated and interactive 
technical support system to be maintained on 
Iomega's World Wide Web internet page, based upon 
case-based reasoning technology capable of 
responding to customer technical support inquiries 
through (1) a basic single question/single answer 
format, (2) a more advanced multiple 
question/multiple answer format, (3) a decision 
tree format, and (4) generated case queries using 
fuzzy logic.  Said system also includes an on-line 
tutorial to instruct the user in operation of the 
system and provides technically feasible graphics 
illustrating the most frequently asked technical 
support questions concerning Zip, Jaz and Ditto 
drives.  The system will be designed to permit 
access by at least 250 concurrent users.

b. For the two year period beginning on the 
Settlement Effective Date, Iomega shall at its 
expense establish and maintain the IVR System, a 
24-hour automated, interactive telephone technical 
support system capable of responding, through use 
of a decision tree and pre-recorded voice 
responses, to customer technical support inquiries 
about Iomega Zip, Jaz, and Ditto drives.  Said 
system will allow a customer calling for technical 
support to save his or her technical support 
session so that the session can be resumed in a 
subsequent telephone call without reinitiation of 
the session from the beginning.   The IVR System 
shall be available toll free to all Iomega 
customers at no charge and shall permit the user at 
any time to transfer to an automated Iomega 
customer support dialogue menu through which a 
caller may reach the Iomega Customer Support line 
referenced in paragraph 8(d) below. 

c. For the two year period beginning on the 
Settlement Effective Date, Iomega shall at its 
expense commit to limit "hold" times for technical 
support regarding Iomega's Zip, Jaz, and Ditto 
drives to ten (10) minutes on an average monthly 
basis.  If the average "hold" time, as calculated 
at month's end, exceeds ten (10) minutes because 
call volume is higher than projected, then Iomega 
shall use its reasonable efforts to reduce the 
"hold" times to ten (10) minutes or below within 
forty-five (45) days after the end of the month 
during which average "hold" times of greater than 
ten (10) minutes were first discovered.


d. For the two year period beginning on the 
Settlement Effective Date, Iomega shall at its 
expense establish, maintain, and make available to 
all Iomega customers at no charge a toll-free 
"customer support" telephone line, connected 
through an existing toll-free Iomega telephone 
number.  The "customer support" line will be 
staffed with personnel trained and equipped to 
answer non-technical questions relating to Iomega 
products and services and, where necessary, will 
refer customers to an appropriate department or 
service area, including technical support (except 
that a referral to technical support may involve a 
charge consistent with Iomega's current policies 
and practices regarding imposition of a charge for 
technical support).  Customer support agents will 
be members of Iomega's Executive Response Center 
and will be authorized to resolve product concerns, 
service complaints, and other issues raised by 
customers.  During this period, Iomega will commit 
to limit "hold" times on the customer support line 
to ten (10) minutes on an average monthly basis.  
If the monthly average exceeds ten (10) minutes 
because call volume is higher than projected, then 
Iomega shall use its reasonable efforts to reduce 
the "hold" times to ten (10) minutes or below 
within forty-five (45) days after the end of the 
month during which average "hold" times of greater 
than ten (10) minutes was first discovered.

e. For the two year period beginning on the 
Settlement Effective Date, Iomega shall provide 
telephone technical support to Jaz and Ditto drive 
customers toll free and at no charge for a period 
of thirty (30) days from the date of the customer's 
first call, provided that the customer's first call 
falls within the product warranty period.

f. Iomega shall maintain a computer 
Database to contain problem and associated solution 
information regarding Iomega Zip, Jaz, and Ditto 
drives, along with other Iomega products.  The 
Database is to be updated regularly and promptly 
based on information generated by Iomega personnel 
from internal Iomega product testing, customer 
interaction by telephone, the internet, and other 
means.  The information housed in the Database will 
be accessible by or provided as applicable through 
the Virtual Consultant, the IVR System, the Iomega 
"Fax-Back" program, and Iomega technical support 
personnel.

g. For the two year period beginning on the 
Settlement Effective Date, Iomega shall provide 
telephone technical support to Zip, Jaz, and Ditto 
drive customers, toll free and at no charge, for 
technical issues not addressed by the Database at 
the time of the customer's telephone call, as will 
be determined, in good faith, by the Iomega 
technical support technician handling the 
customer's telephone call.  Upon a determination 
that a technical issue is addressed by the Database 
and that the customer's technical support call will 
be charged, the customer shall be entitled, at his 
or her request, to receive from Iomega by e-mail, 
fax, or letter, a written description of the 
resolution's derivation from the Database. Once a 
resolution for a technical issue has been posted to 
the Database, Iomega may assess its regular charge 
for customers that thereafter raise the same 
technical issue.

h. For those Charged Customers not opting 
out of this proposed settlement, Iomega shall 
extend the Iomega Warranty on their drive for a 
period of six months, measured as the later of: (i) 
a period of six months from the expiration date of 
the original warranty, or (ii) a period of six 
months from the Settlement Effective Date.


i. For a period of six months following the 
Settlement Effective Date, those members of the 
Class who purchased a Zip drive between January 1, 
1996 and September 1, 1997 (the purchase date being 
deemed to be 90 days from the date of manufacture 
as determined by the product serial number), who do 
not opt out of the settlement and who were not 
charged a technical support fee, shall be entitled 
to one call to Iomega's telephone technical support 
line at a price representing a discount of $5.00 
off of the price charged by Iomega for technical 
support.

j. For the two year period beginning on the 
Settlement Effective Date, Iomega shall provide 
Class Counsel with quarterly status/summary reports 
describing the nature of the most frequently 
received customer complaints regarding the relief 
provided herein.  Such reports shall be provided on 
a confidential basis and shall be usable only in 
the Litigation.  The reports shall not identify the 
names of Iomega customers and shall report on 
customer complaints in summary form only.

k. Iomega shall revise and redesign the 
Iomega Warranty (a) to designate the warranty 
conspicuously as a "limited" warranty under the 
MMA, (b) to identify clearly a toll-free customer 
support telephone number attended by Iomega 
representatives capable of answering customer 
questions about warranty performance, (c) to 
identify clearly the fees or charges (if any) that 
apply for telephone technical support, and (d) to 
identify clearly any other limitations or 
exclusions under the warranty.  Iomega shall also 
revise, redesign, and/or sticker its Zip, Jaz, and 
Ditto drive product packaging (a) to indicate that 
only a "limited" warranty is provided, and (b) to 
identify the fees or charges (if any) that apply to 
telephone technical support.

l. Subject to possible unavailability due 
to binding confidentiality obligations to third 
parties, Iomega shall provide to Class Counsel a 
status report of its progress, whether achieved 
individually or jointly conducted with third 
parties, in resolving issues of interoperability 
between certain printers sharing the parallel port 
of a user's computer with Iomega's Zip drives. 

9. Based on the discovery conducted to date 
and their overall investigation in pursuit of their 
claims, as well as substantial arms-length negotiations 
between counsel, and considering the benefits of the 
settlement to the Class, and the risks associated with 
further litigation (including the uncertainty of trial 
and the delay associated with any appeal), the plaintiffs 
and their counsel have concluded that the proposed 
settlement is fair, reasonable, and adequate.  Based upon 
these considerations, the plaintiffs and their counsel 
have concluded that it is in the best interests of the 
plaintiffs and the Class to settle the claims asserted in 
this lawsuit on the terms and conditions agreed upon in 
the proposed settlement.

10. The proposed settlement provides 
significant benefits to the plaintiffs and the Class and 
will eliminate the burden and expense of further 
litigation and the risk that nothing will be recovered 
for the plaintiffs or the Class if the case goes to 
judgment, and it will finally put to rest the claims of 
the plaintiffs individually and on behalf of the Class 
that were or could have been made against Iomega in this 
action.


11. The proposed settlement will become 
effective if the conditions of the Stipulation are met 
and if the Court enters a final judgment which approves 
the settlement (the "Final Judgment") and the Final 
Judgment is affirmed, if there is any appeal, or is no 
longer subject to appeal.

12. If the proposed settlement is approved 
by the Court, all Claimants will be deemed to have 
released and discharged all Class Claims, which are 
generally described in paragraph 2 above, against Iomega 
and all present and former directors, officers, trustees, 
employees, insurers, affiliates and partners of Iomega, 
and shall be barred from asserting any Class Claim 
against Iomega and all present and former directors, 
officers, trustees, employees, insurers, affiliates, and 
partners of Iomega.

13. If the proposed settlement is approved 
by the Court, Iomega shall be barred from asserting any 
compulsory counterclaims which could have been raised by 
Iomega in this lawsuit against the plaintiffs and the 
Claimants and shall be conclusively deemed to have 
released such compulsory counterclaims.

14. Iomega, the plaintiffs and the Claimants 
would not be released from any claims which arise under 
the Stipulation or after the settlement is finalized.

15. The plaintiffs and the Class have been 
represented in this litigation by the following law 
firms:

Lawrence E. Feldman
Kenneth J. Benton
Gail Gottehrer
Lawrence E. Feldman & Associates
Jenkintown Plaza
101 Greenwood Ave., Suite 230
Jenkintown, PA  19046

Mark C. Rifkin
Greenfield & Rifkin LLP
800 Times Building
Ardmore, PA  19003

Jeffrey S. Goddess
Joseph A. Rosenthal
Rosenthal, Monhait, Gross & Goddess, P.A.
Suite 1401
Mellon Bank Center
P.O. Box 1070
Wilmington, DE  19899-0170



16. Class Counsel will request from the 
Court an award of attorneys' fees and reimbursement of 
expenses.   Class Counsel collectively will request an 
award of attorneys' fees in the amount of six hundred 
thousand dollars ($600,000), and reimbursement of 
expenses in the amount of fifty thousand dollars 
($50,000).  In addition, Class Counsel will be entitled 
to bill Iomega for legal bills up to a total of 
$50,000.00 for services rendered to class members in 
responding to questions about the settlement after the 
Settlement Effective Date.

 YOUR CHOICES AS A CLASS MEMBER

17. If you are a member of the Class, as 
defined above, you have the following choices:

a. If you wish to participate in the 
settlement as a member of the Class, you do 
not need to appear at the hearing discussed 
below, or take any other action to participate 
in this settlement.  If the proposed 
settlement is approved by the Court, Iomega 
will take the actions described above in 
Paragraph 8.

b. You may, if you desire, file a signed, 
written request to be excluded from the Class. 
 If you request to be excluded from the Class, 
you will not be entitled to the benefits of 
the settlement as set forth above in Paragraph 
8; you will not be bound by judgments for or 
against the Class; and you will retain any 
individual rights you may have with respect to 
Class Claims.  Any member of the Class who 
wants to be excluded from the Class must do so 
in writing.  Such request for exclusion shall 
clearly indicate that the sender requests to 
be excluded from the Class and shall state:  
(1) the name and address of the person seeking 
exclusion; (2) the Iomega product(s) 
purchased; and (3) the date(s) on which the 
product(s) were purchased.  Requests for 
exclusion that do not include such information 
will not be effective.  Any request for 
exclusion must be received no later than 
fifteen (15) days prior to the Settlement 
Hearing and copies must be sent to the 
following:

Lawrence E. Feldman, Esq.
Lawrence E. Feldman & Associates
Jenkintown Plaza
101 Greenwood Ave., Suite 230
Jenkintown, PA  19046

Joseph A. Rosenthal
Rosenthal, Monhait, Gross & Goddess, P.A.
P.O. Box 1070
Wilmington, DE 19899-0170

Class Counsel

-and-


James W. Prendergast, Esq.
Hale and Dorr LLP
60 State Street
Boston, MA  02109

Jesse A. Finkelstein
Richards, Layton & Finger
P.O. Box 551
Wilmington, Delaware  19899

Counsel for Iomega

c. You may, if you desire, appear at the 
Settlement Hearing to object to the proposed 
settlement or to the application for 
attorneys' fees and reimbursement of expenses, 
if you have not requested to be excluded from 
the Class.  To do so, you must file a written 
notice of objection, together with a statement 
of your reasons, with the Court.  Any such 
objection should be directed to the Court as 
follows: Brandon Cox, et. al. v. Iomega 
Corporation, Civil Action No. 15809,  Court of 
Chancery of Delaware, 1020 North King Street, 
Wilmington, Delaware 19801.  To be considered 
by the Court, all objections must be received 
on or before the fifteenth day before the 
Settlement Hearing and copies must also be 
sent to: 

Lawrence E. Feldman, Esq.
Lawrence E. Feldman & Associates
Jenkintown Plaza
101 Greenwood Ave., Suite 230
Jenkintown, PA  19046


Joseph A. Rosenthal
Rosenthal, Monhait, Gross & Goddess, P.A.
P.O. Box 1070
Wilmington, DE 19899-0170

Class Counsel

-and-

James W. Prendergast, Esq.
Hale and Dorr LLP
60 State Street
Boston, MA  02109


Jesse A. Finkelstein
Richards, Layton & Finger
P.O. Box 551
Wilmington, Delaware  19899

Counsel for Iomega


 SETTLEMENT HEARING

18. On April 3, 1998 at 11:00 AM 
a hearing will be held in the Court of 
Chancery of the State of Delaware located at 
the Daniel L. Herrmann Courthouse, 1020 North 
King Street, Wilmington, Delaware, to 
determine whether the settlement should be 
approved by the Court as fair, reasonable and 
adequate, and whether judgment should be 
entered thereon.  The Court will also consider 
at this Hearing the request of Class Counsel 
for an award of attorneys' fees and 
reimbursement of expenses for the services 
they have rendered in this litigation.  Any 
award of attorneys' fees or reimbursement of 
expenses that the Court awards will be paid by 
Iomega.

19. Your attendance at the 
settlement hearing is not required.  However, 
you may be heard orally at the hearing in 
opposition to the proposed settlement or Class 
Counsels' application for attorneys' fees and 
expenses, only if you have not requested to be 
excluded from the Class and have timely filed 
written objections in the manner described in 
subparagraph 17(c) above.  You may also enter 
an appearance through an attorney.  If you do 
not do so, you will be represented in this 
action by Class Counsel.

20. The Court reserves the right 
to extend any of the deadlines set forth 
herein, or to allow late filings of requests 
for exclusion or objections to the settlement, 
for good cause shown.

21. The Hearing may be 
rescheduled by the Court without further 
notice to the Class.

 EXAMINATION OF PAPERS

22. This is only a summary of 
the circumstances surrounding the lawsuit, the 
claims and defenses asserted, the proposed 
settlement, and the matters related to the 
lawsuit.  For more detailed information you 
may review the Stipulation and related 
documents and other papers on file in the 
litigation, which may be inspected during 
regular business hours at the office of the 
Register in Chancery, Court of Chancery of the 
State of Delaware, 1020 North King Street, 
Wilmington, Delaware 19801.  If you have any 
questions about this Notice, the settlement, 
or the lawsuit generally, you should direct 
them to:  Iomega Cox Settlement Administrator, 
P.O. Box 8028, Newport Beach  California  
92658-8028, tel. no.
(888) 229-0971.



PLEASE DO NOT CALL THE COURT.

___________________________
Register in 
Chancery

DATED: January 26, 1998

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