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NOTICE OF PROPOSED CLASS ACTION SETTLEMENT - page 1 / 4

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NOTICE OF PROPOSED CLASS ACTION SETTLEMENT

This notice pertains to a class action lawsuit called Carole Eustice v. Network Associates, Inc., Case No. CIV 210925, pending in the Superior Court of California, County of Ventura.

IF YOU ARE A U.S. RESIDENT AND YOU LICENSED VERSIONS 3 OR 4 OF MCAFEE VIRUSSCAN SOFTWARE, YOU MAY BE A MEMBER OF THE CLASSFOR WHOM RELIEF IS BEING SOUGHT AND YOU SHOULD READ THIS NOTICE.

On April 7, 2004, the Court certified a class that includes all U.S. residents who licensed versions 3 or 4 of McAfee VirusScan software. The Class does not include U.S. residents who did not license versions 3 or 4 of McAfee VirusScan software. The Class also does not include non- U.S. residents.

WHAT IS THIS CLASS ACTION ABOUT? Plaintiffs allege that Network Associates has violated California state law and breached their license agreements by failing to provide free lifetime updates to purchasers of versions 3 and/or 4 of McAfee VirusScan software. The class action asserts claims under California Business and Professions Code §§ 17200 et seq. and California Civil Code §§ 1770 et seq. Network Associates denies the allegations. The Court has not made any determination about the merits of Plaintiffs’ claims or the denials and other defenses of Network Associates. The Court has ruled that the named Plaintiffs in this class action (Carole Eustice and William Hansult) may represent the Class described above.

The parties have come to a settlement. Network Associates agrees to give each Class member a free download of the perpetual version of one of the following: (i) McAfee VirusScan version 8, (ii) AntiSpyware version 1.0 or (iii) QuickClean version 4.01 (or the most recent versions at the time of download) software from mcafee.com.

Your free download will be available until July 16, 2004. To obtain your free download of the Software, go to http://download.mcafee.com/updates/notice/ and complete an on-line form certifying that you are a member of the Class.

You must download your Software by July 16, 2004. The offer may not be used in conjunction with any other promotional offer or coupon and may only be used on mcafee.com. A maximum of one Software download may be redeemed per household.

Under the settlement, Class Counsel will receive $227,000 in attorneys’ fees, costs and expenses from Network Associates. Class Members are not personally liable for any such fees or expenses.

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