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877-411-5025

This official website is maintained by the Settlement Administrator under the supervision of the Plaintiffs' Counsel for Class Members in the Stockholder Class Action entitled “Drulias v. Affeldt, et al., Consol. C.A. No. 2024-0161-BWD” (Delaware Court of Chancery)

EIC Stockholder Litigation

All record and beneficial holders of EIC Class A Common Stock who purchased, acquired, or held such securities at any time between September 17, 2019 and May 3, 2021, and continued to hold  such stock as of 5:00 PM ET on May 3, 2021, and who elected not to redeem all or some of their EIC Class A Common Stock, including their successors in interest who obtained shares by operation of law

The information contained on this web page is only a summary of information presented in more detail in the Notice of Pendency and Proposed Settlement of Stockholder Class Action, Settlement Hearing, and Right to Appear, which you can access by clicking here. Because this website is just a summary, you should review the Notice for additional details.

Notice of Pendency of Class Action:  Please be advised that your rights will be affected by the above-captioned stockholder class action (the “Action”) pending in the Court of Chancery of the State of Delaware (the “Court”) if you were a public stockholder of EIC Class A Common Stock between September 17, 2019 and May 3, 2021 (the “Class Period”).

Notice of Settlement:  Please be advised that (i) Plaintiffs Dean William Drulias (“Drulias”) and Dominic McFee (“McFee”) (the “Plaintiffs”), on behalf of themselves and the Class (as defined herein), and (ii) Defendants Experience Sponsor, LLC (the “Sponsor”), Eric L. Affeldt, Martin Newburger, Brian C. Witherow, Rafael Pastor, Edward “Ted” Philip, Charlie Martin, and Michael Mohapp (the “EIC Defendants” and collectively with Sponsor, the “Defendants”) (together with Plaintiffs, the “Parties,” and each a “Party”), have reached a proposed settlement for $17,775,000.00 in cash (the “Settlement Amount”) as set forth in the Stipulation (the “Settlement”). The Settlement, if approved, will resolve all claims in the Action. 

All record and beneficial holders of EIC Class A Common Stock who purchased, acquired, or held such securities at any time between September 17, 2019 and May 3, 2021, and continued to hold  such stock as of 5:00 PM ET on May 3, 2021, and who elected not to redeem all or some of their EIC Class A Common Stock, including their successors in interest who obtained shares by operation of law, but excluding:  (i) Defendants; (ii) members of the immediate family of any Individual Defendant; (iii) any parent, subsidiary, or affiliate of any entity Defendant; (iv) any entity in which any Defendant or any other Excluded Person, or group of Excluded Persons, has, or had as of the Redemption Deadline, a controlling interest; (v) KSL Capital Partners LLC; (vi) Steele ExpCo Holdings, Inc.; (vii) Ross Aviation LLC; and (viii) the legal representatives, agents, affiliates, heirs, estates, successors, or assigns of any such Excluded Persons.

PLEASE NOTE: The Class is a non-opt-out settlement class pursuant to Delaware Court of Chancery Rules 23(a), 23(b)(1), and 23(b)(2). Accordingly, Class Members do not have the right to exclude themselves from the Class.

Please read the Notice to fully understand your rights and options. Copies of the Notice and Claim Form can be found in the menu of this page.

Payments to eligible claimants will be made only if the Court approves the Settlement and a Plan of Allocation, only after any appeals are resolved, and after the completion of all claims processing. Please be patient, as this process will take some time to complete.

Please read the Notice carefully. If you have questions, you may call the EIC Stockholder Litigation Help Line at 1-877-411-5025 or email Info@EICStockholderSettlement.com

CLASS MEMBERS’ LEGAL RIGHTS IN THE SETTLEMENT:
Description Due Date

TO RECEIVE A PAYMENT FROM THE SETTLEMENT 
CLASS MEMBERS MUST SUBMIT A PROOF OF CLAIM FORM. 

If you are a member of the Class, you may be eligible to receive a distribution from the Settlement proceeds. Eligible Class Members (defined in Paragraph 62 of the Notice) must submit a Claim Form in order to receive a distribution from the Settlement, if approved by the Court.Proofs of Claim must be postmarked or submitted online on or before May 18, 2026. If you are eligible to receive a distribution from the Settlement, it will be paid to you directly.  See Paragraphs 59-74 in the Notice for further discussion.

OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN MARCH 26, 2026.

If you are a member of the Class and would like to object to the proposed Settlement, the proposed Plan of Allocation, or Plaintiffs' Counsel’s request for a Fee and Expense Award (defined in Paragraph 77 of the Notice), you may write to the Court and explain the reasons for your objection.

ATTEND A HEARING ON APRIL 17, 2026, AT 1:30 p.m., AND FILE A NOTICE OF INTENTION TO APPEAR SO THAT IT IS RECEIVED NO LATER THAN MARCH 26, 2026.

Filing a written objection and notice of intention to appear that is received by March 26, 2026, allows you to speak in Court, at the discretion of the Court, about your objection. In the Court’s discretion, the April 17, 2026, hearing may be conducted by telephone or videoconference (see Paragraphs 78-80 in the Notice). If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection

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