PayPal Holdings, Inc. (PYPL) Loss Submission Form

The Klein Law Firm announces that a class action complaint has been filed on behalf of shareholders of PayPal Holdings, Inc. (NASDAQ: PYPL) who purchased shares between February 14, 2017 and December 1, 2017. The action, which was filed in the United States District Court for the Northern District of California, alleges that the Company violated federal securities laws.

In particular, the complaint alleges that (1) TIO's data security program was inadequate to safeguard the personally identifiable information of its users; (2) the vulnerabilities threatened continued operation of TIO's platform; (3) PayPal’s revenues derived from its TIO services were thus unsustainable; (4) consequently, PayPal had overstated the benefits of the TIO Acquisition; and (5) as a result, PayPal’s public statements were materially false and misleading at all relevant times. On November 10, 2017, PayPal suspended its TIO services, pending a security review, stating that it had discovered security vulnerabilities on the TIO platform and that the TIO data security program did not meet PayPal’s standards. Then on December 1, 2017, PayPal disclosed that personal information for roughly 1.6 million TIO users had potentially been compromised as a result of the previously announced security vulnerabilities.

Shareholders have until February 5, 2018 to petition the court for lead plaintiff status. Your ability to share in any recovery does not require that you serve as lead plaintiff. You may choose to be an absent class member.

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Keep Me Informed

The Klein Law Firm does not share your information with others. There is no cost or obligation. This submission does not create an attorney-client relationship. If we believe that you might be an appropriate lead plaintiff, we will contact you to discuss whether to establish an attorney-client relationship.

I am ready to join the action

This letter confirms that you have retained The Klein Law Firm to represent you as a named plaintiff in a shareholder action involving PayPal Holdings, Inc.

We agree to advance all expenses in the litigation, which means that you are not liable to pay any of the expenses of the lawsuit, whether attorneys' fees or costs. Regardless of the result, we will never ask you to directly pay for any attorneys' fees or costs. Should we obtain a favorable result, we may ask the court to award us compensation to be paid by the defendants or as a portion of any class benefit, but, again, we will never ask you to directly pay any of the costs of this litigation.

As the client you are entitled to direct the litigation in any way you deem proper, and may at any time order us to dismiss the case or opt-out. Should you choose to do so, we will never ask you to reimburse us directly for any legal fees or expenses. During the course of this litigation, we may employ and/or work with other law firms to prosecute your case.

We look forward to representing you and other PayPal Holdings, Inc. shareholders.

Sincerely,

The Klein Law Firm

Joseph Klein

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