SUMMARY OF THE CASE AND SETTLEMENT

1. Description of the Action and the Settlement Class:  The Notice relates to a proposed Settlement of claims in a pending securities class action brought by investors alleging, among other things, that defendants Hub f/k/a Mount Rainier Acquisition Corp. (“Mount Rainier”), and defendants Eyal Moshe, Hugo Goldman, Uzi Moscovich a/k/a Azriel Moskovic, Zeev Zell, Moshe Raines, Manish Agarwal, Moti Franko, and Matthew Kearney (collectively, “Individual Defendants”; and together with Hub, “Defendants”) violated the federal securities laws by disseminating materially false and misleading information to the investing public regarding (i) whether the investors in a $50 million private investment in public equity (“PIPE”) facility were committed; (ii) the strength of the Company’s internal controls in light of undisclosed embezzlement by corporate insiders; and (iii) their portrayal of Hub Cyber Security (Isreal) Ltd. (“Legacy Hub”) as a cash-positive, “established business” with a “client base” and “established products” when, in fact, Legacy Hub’s flagship product was nowhere near ready for market.  A more detailed description of the Action is set forth in paragraphs 11-23 of the Notice.  The proposed Settlement, if approved by the Court, will settle claims of the Settlement Class, as defined in paragraph 24 of the Notice .
2. Statement of the Settlement Class’s Recovery:  Subject to Court approval, Plaintiffs, on behalf of themselves and the Settlement Class, have agreed to settle the Action in exchange for a settlement payment of $11,000,000 in cash (the “Settlement Amount”) to be deposited into an escrow account.  The Net Settlement Fund (i.e., the Settlement Amount plus any and all interest earned thereon (the “Settlement Fund”)) less (a) any Taxes, (b) any Notice and Administration Costs, (c) any Litigation Expenses awarded by the Court, and (d) any attorneys’ fees awarded by the Court) will be distributed in accordance with a plan of allocation that is approved by the Court, which will determine how the Net Settlement Fund shall be allocated among members of the Settlement Class.  The proposed plan of allocation (the “Plan of Allocation”) is set forth on pages 10-13 of the Notice.
3. Estimate of Average Amount of Recovery Per Share of Hub common stock:  Assuming that all Settlement Class Members elect to participate in the Settlement, the estimated average recovery (before the deduction of any Court-approved fees, expenses and costs as described herein) per eligible share of Hub common stock is $0.12.  Settlement Class Members should note, however, that the foregoing average recovery per share of Hub common stock is only an estimate.  Some Settlement Class Members may recover more or less than this estimated amount depending on, among other factors, when and at what prices they purchased, acquired, and/or sold their Hub common stock, and the total number of valid Proof of Claim and Release Forms (“Claim Forms”) submitted.  Distributions to Settlement Class Members will be made based on the Plan of Allocation set forth herein (see pages 10-13 of the Notice ) or such other plan of allocation as may be ordered by the Court.
4. Average Amount of Damages Per Share of Hub Common Stock:  Plaintiffs and Defendants do not agree on the average amount of damages per share of Hub common stock that would be recoverable if Plaintiffs were to prevail in the Action.  Among other things, Defendants do not agree with the assertion that they violated the federal securities laws or that any damages were suffered by any members of the Settlement Class as a result of their conduct.
5. Attorneys’ Fees and Expenses Sought:  Court-appointed Lead Counsel, Glancy Prongay & Murray LLP and The Law Offices of Jacob Sabo (collectively, “Lead Counsel”), which have been prosecuting the Action on a wholly contingent basis since their appointment as Lead Counsel in 2023, have not received any payment of attorneys’ fees for their representation of the Settlement Class and have advanced the funds to pay expenses necessarily incurred to prosecute this Action.  Lead Counsel will apply to the Court for an award of attorneys’ fees in an amount not to exceed 33⅓% of the Settlement Fund.  In addition, Lead Counsel will apply for reimbursement of Litigation Expenses paid or incurred in connection with the institution, prosecution and resolution of the claims against the Defendants, in an amount not to exceed $205,000, which may include an application for reimbursement of the reasonable costs and expenses incurred by Plaintiffs directly related to their representation of the Settlement Class in an amount not to exceed $30,000.  Any fees and expenses awarded by the Court will be paid from the Settlement Fund.  Settlement Class Members are not personally liable for any such fees or expenses.  Estimates of the average cost per affected share of Hub common stock, if the Court approves Lead Counsel’s fee and expense application, is $0.04 per eligible share.
6. Identification of Attorneys’ Representatives:  Plaintiffs and the Settlement Class are represented by Casey E. Sadler, Esq. of Glancy Prongay & Murray LLP, 1925 Century Park East, Suite 2100, Los Angeles, CA 90067, (310) 201-9150, settlements@glancylaw.com, and Jacob Sabo, Esq., Law offices of Jacob Sabo, 22a Mazzeh Street, Tel-Aviv, Israel, (++972) 39070770, jsabo53@gmail.com.
7. Reasons for the Settlement:  Plaintiffs’ principal reason for entering into the Settlement is the substantial immediate cash benefit for the Settlement Class without the risk or the delays inherent in further litigation.  Moreover, the substantial cash benefit provided under the Settlement must be considered against the significant risk that a smaller recovery – or indeed no recovery at all – might be achieved after contested motions, a trial of the Action and the likely appeals that would follow a trial.  This process could be expected to last several years.  Defendants, who deny all allegations of wrongdoing or liability whatsoever, are entering into the Settlement solely to eliminate the uncertainty, burden and expense of further protracted litigation.