UnitedHealth Group (UNH)

15.1 Payment Of Costs Of Notice And Administration Of Settlement

The costs of notice and administration of this Settlement Agreement shall be paid solely out of the Cash Settlement Fund. In no event shall Defendants bear any responsibility for any such costs or expenses. Notwithstanding the above, the Company shall be solely responsible for: (i) the costs of collecting health care claims data from its claims systems in connection with the administration of this Settlement Agreement, including the dates Covered Out-Of-Network Services or Supplies were provided and the Allowed Amounts from January 1, 2002 until the Notice Date, and providing such health

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care claims data to the Claims Administrator; and (ii) the costs of identifying Settlement Class Members from its own business files and records for purposes of providing such data to the Claims Administrator for the dissemination of the Mailed Notice. Reasonable costs incurred by the Claims Administrator prior to the Effective Date shall be advanced by the Company, and the amount the Company is required to contribute to the Cash Settlement Fund shall be reduced by the amount of any such costs advanced. In the event that the Settlement does not become effective prior to the Funding Date, neither Settling Plaintiffs nor Settlement Class Counsel shall have any liability to repay any such costs advanced.