Settlement Agreement and Release of Claims

This Settlement Agreement and Release of Claims (the “Settlement Agreement” or “Agreement”) is made effective as of the date all Parties have executed same (“Effective Date”), and is entered into by and between (1) AVID LIFE MEDIA, INC., an Ontario corporation (“ALM”), AVID DATING LIFE, INC., an Ontario corporation, dba Ashley Madison (“Avid Dating”), COUGAR LIFE, INC. an Ontario corporation (“Cougar Life”), ALM LABS, INC., an Ontario corporation, and NOEL BIDERMAN, an individual, and their affiliates, on one hand (and collectively referred to as “Avid”), and (2) DIGISEC MEDIA AS, a Norwegian company, DIGISEC LIMITED, a Cyprus company, DIGISEC GLOBAL IPR LIMITED, a Malta company, DIGISEC HOLDING LTD, a Malta company, and SIGURD VEDAL, an individual, and their affiliates, on the other hand (and collectively referred to as “Digisec”). Avid and Digisec will at times hereinafter be referred to collectively as “Parties,” and individually as “Party” (“Avid Party(ies)” and “Digisec Party(ies)” as the case may be). For these purposes, an “affiliate” is a person or entity controlled by, or in common control with, any Party, directly or indirectly, by ownership, or being an officer, or having a management or supervisorial board position.

The Parties agree as follows: DEFINITIONS

1. “Ashley Madison Service” means the married-attached dating services offered by Avid Dating and/or its affiliates throughout the world including that which is made available on the internet through various uniform resource locators which usually include the word “ashleymadison” as the second level domain name, without respect to the country code level domain name.

2. “Shush Image” means any image, including that used by Avid to identify its marital-attached dating service as exemplified in the imaged depicted in Exhibit A to this Agreement, which reflects at least a portion of a woman’s face with her hand raising her index finger vertically across the front of her lips. Shush Image shall also include the image of Noel Biderman with his hand raising his index finger vertically across the front of his lips, an example of such image depicted in Exhibit B to this Agreement.

3. “Ashley Madison Whisper Trade Dress” or “Whisper Trade Dress” means an image, as exemplified in the image depicted in Exhibit C to this Agreement, which reflects a woman whispering into a man’s ear from any distance such that the faces of both woman and man are visible with a hand raised near the lips of the woman whispering.

!1

4. “ASHLEY MADISON Service Mark” means the mark “ASHLEY MADISON” that is registered with, among other governmental agencies, the United States Patent and Trademark Office (Registration No. 2812950), and is used to identify the source of services provided by certain websites operated by Avid Dating, including, but not limited to ashleymadison.com.

5. The “ASHLEY MADISON ‘LIFE IS SHORT. HAVE AN AFFAIR’. Mark” means the mark “LIFE IS SHORT. HAVE AN AFFAIR.” that is registered with, among other governmental agencies, the United States Patent and Trademark Office (Registration No. 3745718), and is used to identify the source of the services provided by certain websites operated by Avid Dating, including but not limited to ashleymadison.com.

6. “ASHLEY MADISON Trademarks” means, collectively, the ASHLEY MADISON ‘LIFE IS SHORT. HAVE AN AFFAIR.’ Mark and ASHLEY MADISON Service Mark.

7. “Victoria Milan Service” means the married-attached dating services offered by any of the Digisec Parties and/or any of their affiliates throughout the world including that which is made available on the internet through various uniform resource locators which usually include the word “victoriamilan” as the second level domain name, without respect to the country code level domain name.

8. “VICTORIA MILAN Service Mark” means the mark “VICTORIA MILAN” that is registered with, among other governmental agencies, the United States Patent and Trademark Office (Registration No. 4,299,737), and is used to identify the source of services provided by certain websites operated by certain of the Digisec Parties, including, but not limited to victoriamilan.com.

9. “RELIVE THE PASSION - FIND YOUR AFFAIR Mark” means the mark “RELIVE THE PASSION - FIND YOUR AFFAIR” that is registered with, among other governmental agencies, the United States Patent and Trademark Office (Registration No. 4,431,266), and is used to identify the source of services provided by certain websites operated by certain of the Digisec Parties, including, but not limited to victoriamilan.com.

10. “Challenged Image” means the image that has been used on the VictoriaMilan.com and VictoriaMilan.us websites of a portion of a woman’s face with her hand raising her index finger vertically across the front of her lips, as depicted in Exhibit D to this Agreement.

11. “Actions” means the following proceedings: (1) the litigation brought by ALM and Avid Dating against Digisec Media AS et al, Case No. 12-CV-08602-JAK (the “Avid California

!2

Action”); (2) the litigation brought by Digisec Limited against Avid Life Media et al, Case No. 13-CV-01849-JAK (the “Digisec Action”); and (3) any litigation brought by Avid Dating Life, Inc. against Digisec Media AS, Digisec Ltd. (also known as Digisec Limited), and Sigurd Vedal in the Ontario Superior Court of Justice (CV-14-495795) (the “Avid Canada Action”). (The Avid California Action and the Digisec Action are collectively the “California Actions.”)

RECITALS

1. This Agreement has reference to the following recitals.

A. ALM and Avid Dating filed the Avid California Action on October 5, 2012. In the Avid California Action, ALM and Avid Dating claim among other things the Shush Image as a trademark for its Ashley Madison Site in, among other places, the U.S. In the Avid California Action, ALM and Avid Dating allege among other things that Digisec Media and Sigurd Vedal infringed the Shush Image. In response to the Avid California Action, Digisec Media and Sigurd Vedal deny all liability and all allegations of wrongdoing. B. Digisec Limited filed the Digisec Action in March, 2013. In the Digisec Action, Digisec claims among other things the Victoria Milan Service Mark as a trademark for its Victoria Milan service in, among other places, the U.S. In the Digisec Action, Digisec Limited alleges among other things that ALM, Avid Dating, Cougar Life, ALM Labs, and Noel Biderman infringed the Victoria Milan Service Mark. In response to the Digisec Action, the Avid Parties deny all liability and all allegations of wrongdoing. C. Avid Dating filed the Avid Canada Action in the Ontario Superior Court of Justice against Digisec Media AS, Digisec Ltd. (also known Digisec Limited), and Sigurd Vedal (CV-14-495795) for intellectual property infringement and breach of a confidentiality agreement, amongst other claims.

TERMS

In light of the definitions and recitals above (which are incorporated by this reference), and for the consideration set forth below, the Parties further agree as follows:

1. Purpose of Agreement; Representations. This Agreement is entered by the Parties in good faith for the purpose of settling the Actions. Each of the Avid Parties represents and warrants that such respective Avid Party controls the content for the Ashley Madison Service world wide. Each of the Digisec Parties represents and warrants that such respective Digisec Party controls the content on the Victoria Milan Service world wide. Each of the Parties respectively represents and warrants that it

!3

has not filed any lawsuits, actions, or proceedings against any of the other Parties except those expressly referenced herein.

2. Compromise Only. Each respective Party acknowledges that this Agreement affects, among other things, the settlement of claims and defenses in the Actions that are denied and contested by the opposing Party, and that nothing contained herein shall be construed as an admission of the existence, or lack, of liability or wrongdoing by or on behalf of any Party.

3. Avid Intellectual Property.

A. Shush Image. Each of the Digisec Parties (1) shall not contest, oppose, or otherwise challenge any of the Avid Parties’ trade dress rights in the Shush Image anywhere in the world, and (2) shall not use, display, or incorporate the Challenged Image or a Shush Image on any website (specifically including all websites promoting the Victoria Milan Service) or in any business that any of the Digisec Parties owns, operates, or controls, directly or indirectly, and (3) shall not use, display, incorporate, or make the subject of any trademark registration or any image as to give rise to a likelihood of confusion with the Shush Image on any website (specifically including all websites promoting the Victoria Milan Service) or in any business that any of the Digisec Parties owns, operates, or controls, directly or indirectly. For purposes of this provision 3.A., the determination of whether such likelihood of confusion exists under A (3) immediately above shall be made according to the United States Lanham Act (the “Lanham Act”) regardless of whether such infringement occurs inside or outside of the United States. For the sake of clarification, use by any Digisec Party of the images attached hereto as Exhibit E is prohibited by this provision.

B. Ashley Madison Trademarks. Each of the Digisec Parties (1) shall not contest, oppose, or otherwise challenge throughout the world the ASHLEY MADISON Service Mark and/or the LIFE IS SHORT. HAVE AN AFFAIR Mark, or close translations thereof, and (2) shall not use, display, or incorporate the ASHLEY MADISON Service Mark and/or the LIFE IS SHORT. HAVE AN AFFAIR Mark, or close translations thereof, on any website (specifically including all websites promoting the Victoria Milan Service) or in any business that any of the Digisec Parties owns, operates, or controls, directly or indirectly, and shall not use, display, or incorporate the phrase “HAVE AN AFFAIR” or exact translations thereof in any trademark, branding, or symbol for Digisec, and (3) shall not use, display,

!4

incorporate, or make the subject of any trademark registration as to give rise to a likelihood of confusion with the ASHLEY MADISON Service Mark and/or the LIFE IS SHORT. HAVE AN AFFAIR Mark, or close translations thereof, on any website (specifically including all websites promoting the Victoria Milan Service) or in any business that any of the Digisec Parties owns, operates, or controls, directly or indirectly. For purposes of this provision 3.B., the determination of whether such likelihood of confusion exists under B (3) immediately above shall be made according to the Lanham Act, regardless of whether such infringement occurs inside or outside of the United States. Notwithstanding the prohibitions in this provision 3.B., each of the Digisec Parties is not prohibited from making fair use of the Ashley Madison Trademarks. Nothing in this Agreement shall prohibit Digisec from using the phrase HAVE AN AFFAIR to make a fair use to describe its service offerings separate and apart from any tagline or trademark use of that phrase. For the sake of clarification of this provision 3.B., Digisec consents to, and agrees not to contest, oppose, or otherwise challenge, Avid’s use or registration of the taglines set forth in Exhibit F-1. For the sake of clarification, Avid consents to, and agrees not to contest, oppose, or challenge, Digisec’s use or registration of the taglines set forth in Exhibit F-2.

C. Ashley Madison Whisper Trade Dress. Each of the Digisec Parties (1) shall not contest, oppose, or otherwise challenge any of the Avid Parties’ trade dress rights in the Whisper Trade Dress anywhere in the world, (2) shall not use, display, or incorporate the Whisper Trade Dress on any website (specifically including all websites promoting the Victoria Milan Service) or in any business that any of the Digisec Parties owns, operates, or controls, directly or indirectly, and (3) shall not use, display, incorporate, or make the subject of any trademark registration any image as to give rise to a likelihood of confusion with the Whisper Trade Dress on any website (specifically including all websites promoting the Victoria Milan Service) or in any business that any of the Digisec Parties owns, operates, or controls, directly or indirectly. For purposes of this provision 3.C., the determination of whether such likelihood of confusion exists under C (3) immediately above shall be made according to the Lanham Act regardless of whether such infringement occurs inside or outside of the United States.

4. Liquidated Damages for Breach of Provision 3. In the event there is a breach of provision 3, following the Notice and Cure Provision set forth in provision 14, then, as liquidated damages without prejudice to filing claims for actual damages in any

!5

instances where such damages based on a breach are ascertainable and exceed liquidated damages, Digisec shall pay Avid Dating $10,000 for the first of any such breach established by the arbitrator in accordance with provision 14, $25,000 for the second of any such breach established by the arbitrator in accordance with provision 14, and $100,000 for the third and each subsequent breach established by the arbitrator in accordance with provision 14. The Parties respectively represent, warrant, and agree to and with the opposing Parties that the graduated payment(s) of $10,000, $25,000, and $100,000 each reflects a reasonable endeavor by the Parties to estimate a fair average compensation for any loss that may be sustained as a result of such breaches, the Parties acknowledging and agreeing that, among other things, damages for such breaches likely will increase over time.

5. Digisec Intellectual Property. Each of the Avid Parties shall not contest, oppose, or otherwise challenge throughout the world Digisec’s: ( i) VICTORIA MILAN Service Mark or close translations thereof; or, (ii) the RELIVE THE PASSION – FIND YOUR AFFAIR mark or close translations thereof.

6. Digisec Abandonment of Trademark and Trade Dress Applications and Registrations. Within twenty (20) days after the Effective Date, the Digisec Parties shall cause to be filed express abandonments of the Trademark Applications or shall surrender the Trademark Registrations, as applicable, that are identified in Exhibit G hereto, and shall take any and all other actions as are required to surrender and abandon same.

7. Avid’s Consent to Digisec’s New Images. Avid consents to the Digisec Parties’ use, and shall not contest, oppose, or otherwise challenge, anywhere in the world, use of the two images attached hereto as Exhibit H. Avid acknowledges that use of such images is not a breach of this Agreement.

8. Phase Out: Digisec shall phase out and cease all conduct that is prohibited by this Agreement, specifically including in provision 3 above, including its use of the Challenged Image, within three months after the Effective Date. Digisec’s right to phase out conduct prohibited by this Agreement does not extend to its conduct that is not occurring at the time the Agreement is effective. For the avoidance of doubt, no Notice of Dispute (as defined below) shall be delivered to the Digisec Parties until three months from the Effective Date except for Digisec’s conduct that is not occurring on the Effective Date. Avid shall not use in Denmark, Finland, Iceland,

!6

Norway, or Sweden the exact image or a modification thereof of the image attached hereto as Exhibit I for a period of three years following the Effective Date.

9. Domain Names. To the extent any of the Avid Parties owns any domain names incorporating the term Victoria Milan, or any other mark of Digisec that any of the Avid Parties is aware of, or any misspelling or variation thereof, each such Avid Party shall transfer such domains within thirty (30) days after the Effective Date to Digisec. To the extent any of the Digisec Parties owns any domain names incorporating the term Ashley Madison, or any other mark of Ashley Madison that any of the Digisec Parties is aware of, or any misspelling or variation thereof, each such Digisec Party shall transfer such domains within thirty (30) days after the Effective Date to the applicable Avid Party.

10. Other Intellectual Property.

a. Avid’s Intellectual Property. Each of the Digisec Parties shall discontinue engaging, and shall not forthwith engage, in any conduct that infringes the copyrights, trademarks, or trade dress of the Avid Parties, no matter the media or jurisdiction where the infringement occurs. Each of the Digisec Parties represents that it is unaware of its engaging in any conduct that constitutes an infringement of any material owned by any of the Avid Parties.

b. Digisec Intellectual Property. Each of the Avid Parties shall discontinue engaging, and shall not forthwith engage, in any conduct that violates the copyrights, trademarks, or trade dress of the Digisec Parties, no matter the media or jurisdiction where the infringement occurs. Each of the Avid Parties represents that it is unaware of its engaging in any conduct that constitutes an infringement of any material owned by any of the Digisec Parties. For purposes of this provision 10.b., the determination of whether the VICTORIA MILAN Service Mark has been infringed shall be made according to the Lanham Act regardless of whether such infringement occurs inside or outside of the United States

11. Keyword Purchasing. The Avid Parties will refrain from purchasing search engine keyword advertising that utilize or incorporate the Digisec Parties’ Victoria Milan Service Mark, or confusingly similar mis-spellings thereof. The Digisec Parties will refrain from purchasing search engine keyword advertising that utilize or incorporate the Ashley Madison Service Mark, or confusingly similar mis-spellings thereof.

!7

12. Notice of New Victoria Milan Websites. If a Digisec Party intends to publish and promote the Victoria Milan Service over the internet in a specific country or countries with a country or countries specific website which does (do) not have a country or countries specific Victoria Milan website as of the earliest date any Party hereto has executed this Agreement, then one or more of the Digisec Parties shall give two weeks prior notice to the Avid Parties. Such notice shall be specifically for the purpose of enabling the Avid Parties to monitor and reduce the likelihood of any Digisec Party’s potential breach of this Agreement, and Avid shall treat such information as a trade secret, shall maintain the confidentiality of any information received through this provision, shall not use this information for any unlawful purposes, and shall only disseminate the information to the Avid executives or employees or counsel necessary for Avid to determine whether Digisec intends to breach this Agreement and to enforce its rights under this Agreement. With each such notice, the Digisec Parties shall provide the Avid Parties with a color copy of the country or countries specific “homepage” with which it intends to publish or launch with respect to such specific country or countries. For the avoidance of doubt, an example of a country-specific homepage is attached hereto as Exhibit J. A list of the specific countries with Victoria Milan Service websites on the first date a Party has executed this Agreement (as shown on the Victoria Milan homepage) is attached hereto as Exhibit K.

13. Dismissal. Within five (5) business days after execution of the Settlement Agreement, the Parties shall (a) prepare, execute, and file a Stipulation for Dismissal, with prejudice, of the California Actions, each side to bear its own attorney’s fees and costs, and (b) prepare, execute, and file the necessary documents to dismiss the Avid Canada Action with prejudice.

14. Dispute Resolution. Each Party commits to operate its business ethically and in the spirit of “good faith” and fair competition in the future. In the event that the Parties have a controversy or claim(s) arising out of or relating to this Agreement, including the breach thereof, or to any other subject matter (“Dispute”), the complaining Party shall provide written notice of such dispute (“Notice of Dispute”) to the allegedly breaching Party by sending said Notice of Dispute to the persons and Parties listed in Section 17. Any one Notice of Dispute shall incorporate all issues that the Party may have with the other Party existing or believed or suspected to exist at the time the Notice of Dispute is served upon the opposing Party. For the first three Notices of Disputes, upon receipt of the respective Notice of Dispute, the allegedly breaching

!8

Party shall have five (5) business days to cure said dispute. After three Notices of Dispute that comply with this Agreement have been sent to one Party and such Party cures or has had a resolution of such Notices of Dispute resolved against that Party, then such reviewing Party shall no longer be afforded time to cure the basis for any fourth or subsequent dispute. Of the first three disputes, if the allegedly breaching Party cures said dispute within the allotted time, such Party shall not be subject to any liability under this Agreement or any other law. For the first three Disputes, if the Dispute is not resolved following the Notice of Dispute, the Parties will endeavor to resolve such Disputes through good faith business discussions between the Parties’ respective principals. Any Disputes that remain shall be determined by arbitration administered by the International Centre for Dispute Resolution (“ICDR”) in accordance with its International Arbitration Rules. The number of arbitrators shall be one. The place of arbitration shall be London, England, and the language of the arbitration shall be English. The arbitrator shall issue a final award on the merits within 60 days after the arbitrator’s appointment, and any hearing on the merits shall be limited to five days, which shall be consecutive if possible. If the Parties are unable to agree on a choice of arbitrator with experience within thirty (30) days, one arbitrator with experience in trademark matters or the subject matter of the dispute, if the dispute is not based upon the parties’ trademarks, shall be selected by the ICDR. Any arbitration proceeding shall incorporate all issues that the Party seeking arbitration may have with the other Party existing or believed or suspected to exist at the time the arbitration proceeding is commenced. The arbitrator shall award to the prevailing Party, if any, as determined by the arbitrator, its costs and expenses, including attorneys’ fees, travel and lodging. Judgment upon any award rendered by the arbitrator may be entered in any court of competent jurisdiction, and the non-prevailing Party shall bear the cost, including attorneys’ fees, of any enforcement proceedings. Upon filing of the arbitration proceeding, the Parties shall deposit in an escrow account or with the American Arbitration Association (“AAA”) or ICDR sufficient funds to cover the legal fees of the opposing Party to cover the award of fees and costs to the prevailing Party of the arbitration. In addition to the authority conferred on the arbitrator by the above-designated rules, the arbitrator shall have the power to grant any provisional measure deemed appropriate, including, but not limited to, provisional injunctive relief. With respect to substantive law, the Parties will attempt to agree in good faith regarding the applicable law, and if they are unable to agree, the question of controlling law shall be determined by the arbitrator; unless the substantive law is prescribed under this Agreement, such arbitrator shall

!9

determine the choice of law by determining the nation to which the allegedly infringing content is being directed. Notwithstanding the immediately preceding sentences of this provision 14, United States substantive law will apply exclusively with respect to the interpretation and enforcement of provision 3 above. For the avoidance of doubt, this Provision 14 prohibits any Party from splitting or otherwise breaking up claims or disputes into multiple Notices of Dispute or arbitration proceedings. By way of example, the Parties acknowledge and agree that the use of one allegedly infringing image by a Party in multiple jurisdictions during overlapping periods of time shall be the subject of one Notice of Dispute and/or arbitration proceeding. Further, if multiple Disputes are occurring simultaneously, the Parties agree that such disputes shall be the subject of one Notice of Dispute or arbitration proceeding; provided, however, that the Party giving Notice under this Provision 14 is under no obligation to join in a single Notice of Dispute conduct of which it is not actually aware. By way of further example, if one Party claims that another Party is breaching this Agreement by using a website that features two infringing images and also is breaching the Agreement by publishing on that website content that is copied, such alleged breaches shall be the subject of one Notice of Dispute and/or arbitration proceeding. No information concerning any arbitration, beyond the names of the Parties and the relief requested, may be unilaterally disclosed to a third party by any Party unless required by law. Any documentary or other evidence given by a Party or witness in the arbitration shall be treated as confidential by any Party whose access to such evidence arises exclusively as a result of its participation in the arbitration, and shall not be disclosed to any third party (other than a witness or expert), except as may be required by law.

15. Release from Claims.

a. Except for the obligations set forth herein, upon the Effective Date, the Avid Parties and any other entity that operates Ashley Madison Service, on behalf of themselves, and each of its/his/their parents, affiliated corporations, companies, divisions, officers, and directors, as well as on behalf of Noel Biderman (the “Avid Releasing Parties”) hereby release, acquit, and forever discharge Digisec Media AS, Digisec Limited, Digisec Global IPR Ltd., Digisec Holding Ltd., and Sigurd Vedal, and each of its/his/their respective parents, subsidiaries, and affiliated entities, including Vedal Holding AS, Digisec Media Ltd., Digisec Nordic IPR Ltd., Digimatch Holding Ltd., and the present and former officers, directors, shareholders, partners, managers, members, employees, agents, insurers, and

!10

attorneys of each of the foregoing persons and entities, and, where applicable, their respective predecessors, heirs, executors, assigns, successors, administrators, and representatives, and each of them, of and from any and all causes of action, claims for relief, lawsuits, charges, or complaints which the Avid Releasing Parties or any one of them hold in connection with the claims which were or could have been alleged in the Avid California Action and Avid Canada Action, known or unknown, and/or which exist based on circumstances that have occurred prior to or as of the Effective Date.

b. Except for the obligations set forth herein, upon the Effective Date, the Digisec Parties and any other entity that operates the Victoria Milan Service, on behalf of themselves, and each of its/his/their parents, affiliated corporations, companies, divisions, officers, and directors, (the “Digisec Releasing Parties”) hereby release, acquit, and forever discharge Avid Life Media, Inc. Avid Dating Life, Inc., Cougar Life, Inc., ALM Labs, Inc., and Noel Biderman, and each of its/his/their respective parents, subsidiaries, and affiliated entities, and the present and former officers, directors, shareholders, partners, managers, members, employees, agents, insurers, and attorneys of each of the foregoing persons and entities, and, where applicable, their respective predecessors, heirs, executors, assigns, successors, administrators, and representatives, and each of them, of and from any and all causes of action, claims for relief, lawsuits, charges, or complaints which the Digisec Releasing Parties or any one of them hold in connection with the claims which were or could have been alleged in the Digisec Action, known or unknown, and/or which exist based on circumstances that have occurred prior to or as of the Effective Date.

16. Section 1542 Waiver. Each Party acknowledges the risk that subsequent to the Effective Date, such Party may discover facts or may incur, suffer, or discover losses, damage, or injuries that are unknown and unanticipated at the time this Agreement is signed, which if known by such Party on the date of this Agreement, may have materially affected its decision to give the release contained in this Agreement. Despite this knowledge and understanding, each Party hereby assumes the risk of such unknown and unanticipated facts, and, except as otherwise provided in this Agreement, hereby waives any alleged right to set aside or rescind this Agreement and any and all rights under California Civil Code § 1542 (and similar laws in other jurisdictions) to the extent such section applies to the releases herein, which section

!11

has been duly explained to and is understood by each Party, and which reads as follows:

“A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing the release, which if known by him or her must have materially affected his or her settlement with the debtor.”

17. Notices and Timing of Notices. When notice or communication is required by this Agreement, such notice must be made at least by electronic mail to the following designees:

For ALM, Avid Dating, Cougar Life, ALM Labs, Inc., and/or Noel Biderman: Noel Biderman, Chief Executive Officer, Avid Life Media, Inc., noel.biderman@avidlifemedia.com; Avi.Weisman@avidlifemedia.com, General Counsel, Avid Life Media, Inc.; and Seth Gold, Esq., K&L Gates, LLP, seth.gold@klgates.com and Christina Goodrich, Esq., K&L Gates, LLP, christina.goodrich@klgates.com.

For Digisec Media AS, Digisec Limited, and Sigurd Vedal: Sigurd Vedal, Digisec Media AS, Digisec Limited, sigurd.vedal@digisecmedia.com , and Raffi V. Zerounian, Esq., rzerounian@gmail.com.

Notice shall be deemed to occur on the day it is sent electronically, unless it is sent after 10 a.m. U.S. and Canada Eastern Time, in which it case it shall be deemed to occur on the business day immediately following the day it was sent. Either Party may change the e-mail addresses and/or addresses for notice under this Agreement by providing written notice of such new e-mail addresses to each of the recipients listed in this Paragraph, or as subsequently designated under this procedure.

18. Binding Effect. The terms herein are binding on and inure to the benefit of the Parties’ successors, affiliates, and assignees (including any successor to any Party’s business or to all or substantially all of such Party’s assets). Notwithstanding the foregoing, this Agreement shall not be assigned by any Party without the consent of the other non-assigning Parties, except in connection with a sale of a given Party’s entire business or all or substantially all of its assets or a transaction between or among any of the Avid Parties, or a transaction between or among any of the Digisec Parties.

!12

19. Choice of Law. All questions with respect to the construction of this Agreement shall be governed by the substantive laws of the State of California.

20. Entire Agreement. This Agreement represents the entire agreement among the Parties with respect to its subject matter and supersedes, merges, and voids all prior and contemporaneous oral and written agreements and discussions with respect thereto. Each of the Parties covenants that it has not entered into this Agreement as a result of, or reliance on, any representation, agreement, inducement, or coercion, except to the extent specifically provided herein, that it has the power to enter into such Agreement, and that it has does not have any contractual obligations that would conflict with its obligations herein. Each Party further covenants that the consideration recited herein is the only consideration it is receiving for entering into this Agreement, and that no promises or representations of other or further consideration have been made by any person. This Agreement has been the subject of negotiations and discussions by and

between sophisticated Parties, which the Parties acknowledge were at arm’s length and

conducted by the Parties and their counsel. It has been and shall be construed to have been

drafted by all the Parties to it, so that any rule of construction construing ambiguities against

the drafter shall have no application to this Agreement.

21. Fees and Costs. Each Party shall bear its own attorney’s fees and costs in connection with this dispute and the settlement thereof. In any suit to enforce this Agreement after a final judgment of the assigned arbitrator or court, the prevailing Party shall be entitled to recover its reasonable attorneys’ fees and costs from the Party determined to have breached this Agreement.

!13

PARTY SIGNATURES IN ACKNOWLEDGEMENT OF THE FOREGOING

EACH PARTY HAS READ THE FOREGOING SETTLEMENT AGREEMENT AND RELEASE AND ACCEPTS AND AGREES TO THE PROVISIONS CONTAINED THEREIN AND HEREBY EXECUTES IT VOLUNTARILY AND WITH FULL UNDERSTANDING OF ITS CONSEQUENCES.

Dated: January , 2014 AVID LIFE MEDIA, INC.

By:____________________

Name: Noel Biderman

Its: Chief Executive Officer

Dated: January , 2014 AVID DATING LIFE, INC.

By:_____________________

Name:Noel Biderman

Its: Chief Executive Officer

Dated: January , 2014 COUGAR LIFE, INC.

By:_____________________

Name:Noel Biderman

Its: Chief Executive Officer

Dated: January , 2014 ALM LABS, INC.

!14

By:_____________________

Name:Noel Biderman

Its: Chief Executive Officer

Dated: January , 2014 NOEL BIDERMAN

By:_____________________

Name:Noel Biderman

Dated: January , 2014 DIGISEC MEDIA AS

By:____________________

Name: Sigurd Vedal

Its: Chief Executive Officer

Dated: January , 2014 DIGISEC LIMITED

By:_____________________

Name:___________________

Its:______________________

Dated: January , 2014 DIGISEC GLOBAL IPR LIMITED

!15

By:_____________________

Name:___________________

Its:______________________

Dated: January , 2014 DIGISEC HOLDING LTD.

By:_____________________

Name:___________________

Its:______________________

Dated: January , 2014 SIGURD VEDAL

By:_____________________

Name: Sigurd Vedal

!16

EXHIBIT A

!

!17

EXHIBIT B

!

!18

EXHIBIT C

!

!19

EXHIBIT D

!

!20

EXHIBIT E

!

!

!21

EXHIBIT F-1

Life is short. Have an affair. (English, Dutch - US, Canada, Australia, New Zealand, UK, Ireland, South Africa, India, Netherlands)

La vida es corta. Ten una aventura. (Spanish, Spanish (Latin American) - Mexico, Argentina, Colombia, Chile, Venezuela, Peru)

Das Leben ist kurz. Gönn' Dir eine Affäre. (German - Germany, Switzerland, Austria)

A vida é curta. Curta um caso. (Portuguese (Brazil) - Brazil)

La vita è breve. Concediti un'avventura. (Italian - Italy)

Elämä on lyhyt. Hanki salasuhde. (Finnish - Finland)

La vie est courte. Ayez une aventure. (French - France, Belgium, Luxembourg)

Livet er kort. Ha en affære. (Norwegian - Norway)

Η Ζωή είναι Σύντοµη. Κάνε µια σχέση. (Greek - Greece)

⼈人⽣生⼀一度。 不倫をしましょう (Japanese - Japan)

A vida é curta. Tenha um caso. (Portuguese - Portugal)

Livet är kort. Ha en affär. (Swedish - Sweden)

Livet er kort. Hav en affære. (Danish - Denmark)

!22

EXHIBIT F-2

Gjør livet levende – ha en affære (Norwegian/Norway) Gjør livet levende - Ha' en affære (Denmark/Danish) Gör livet levande - Ha en affär (Sweden/Swedish) Elvytä Intohimosi - Hanki Salasuhde (Finland/Finnish) Herleef de passie - Begin een Affaire (Netherland/Dutch) Revive la Pasión - Encuentra tu Aventura (Spain/Spanish) Lebe deine Leidenschaft - Find` deine Affäre (DACH/German) Reviva a paixão - Encontre um amante (Portugal & Brasil/Portuguese) Riscopri la Passione - Vivi un'avventura (Italy/Italian) Uwolnij pasję - Znajdź romans (Poland/Polish) Revivez la Passion - Trouvez une affaire (France/French) Zažij zas vášeň - najdi si milence, milenku (Czeck republic/Czech) Preži znovu vášeň - Nájdi si aférku (Slovakia) あのドキドキをもう⼀一度 - 不倫しませんか (Japan/Japanese)

!23

EXHIBIT G

U.S. Trademark Appl’n No. 86139897

U.S. Trademark Appl’n No. 86139924

Canada Trademark Appl’n No. 165567000

Canada Trademark Appl’n No. 165567100

Community Trademark Appl’n No. 12434189

Community Trademark Appl’n No. 12433652

Community Trademark Appl’n No. 12433744

Community Trademark Appl’n No. 12413548

Community Trademark Appl’n No. 12413555

Austria Trademark Appl’n No. 5782/2012 (LEBE DEINE LEIDENSCHAFT - HAB’ EINE AFFARE)

Benelux Trademark Appl’n No.1258099 (REVIVE LA PASSION - AYEZ UNE AVENTURE)

France Trademark Regist. No. 12 3958436 (REVIVEZ LA PASSION - AYEZ UNE AVENTURE)

Germany Trademark Appl’n No. 302012058670.8 (LEBE DEINE LEIDENSCHAFT - HAB’ EINE AFFARE)

Spain Trademark Appl’n No. 3053374 M0 (REVIVE LA PASION - TEN UN AVENTURA)

Switzerland Trademark Regist. No. 644006 (LEBE DEINE LEIDENSCHAFT - HAB’ EINE AFFARE)

!24

EXHIBIT H

!

!

!25

EXHIBIT I

!26

EXHIBIT J

!

!27

EXHIBIT K

!28