Frequently Asked Questions

1. Why did I get the Postcard Notice?

The Court directed that the Postcard Notice be mailed to you because you or someone in your family or an investment account for which you serve as a custodian may have purchased the publicly traded common stock of Ryvyl and/or Greenbox POS during the Settlement Class Period. The Court also directed that the Notice be posted online on the Important Documents page of this website and mailed to you upon request to the Claims Administrator. The Court has directed the Claims Administrator to disseminate these notices because, as a potential Settlement Class Member, you have a right to know about your options before the Court rules on the proposed Settlement. Additionally, you have the right to understand how this class action lawsuit may generally affect your legal rights. If the Court approves the Settlement, and the Plan of Allocation (or some other plan of allocation), the claims administrator selected by Lead Plaintiff and approved by the Court will make payments pursuant to the Settlement after any objections and appeals are resolved.

The purpose of the Notice and this website is to inform you of the existence of this case, that it is a class action, how you might be affected, and how to exclude yourself from the Settlement Class if you wish to do so. It is also to inform you of the terms of the proposed Settlement, and of a hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement, the proposed Plan of Allocation and the motion by Lead Counsel for an award of attorneys’ fees and reimbursement of Litigation Expenses (the “Settlement Hearing”). See FAQ 10 for details about the Settlement Hearing, including the date and location of the hearing.

The issuance of the Notice is not an expression of any opinion by the Court concerning the merits of any claim in the Action, and the Court still must decide whether to approve the Settlement. If the Court approves the Settlement and a plan of allocation, then payments to Authorized Claimants will be made after any appeals are resolved and after the completion of all claims processing. Please be patient, as this process can take some time to complete.

2. What is this case about?

This litigation is about allegedly false and misleading statements made by Defendants concerning Ryvyl’s internal controls and financial results.

On February 1, 2023, a class action complaint was filed in the Court, styled Cullen v. Ryvyl Inc. f/k/a Greenbox POS, et al., 23-cv-0185-GPC-AGS.

By Order dated May 9, 2023, the Court appointed Scot S. Cook to serve as Lead Plaintiff and approved Lead Plaintiff’s selection of Glancy Prongay & Murray LLP as Lead Counsel for the putative class.

On June 30, 2023, Lead Plaintiff filed and served his Amended Class Action Complaint for Violations of the Federal Securities Laws (“Amended Complaint”) asserting claims against Defendants pursuant to Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) and Securities and Exchange Commission (“SEC”) Rule 10b-5 promulgated thereunder, and against the Individual Defendants under Section 20(a) of the Exchange Act. Lead Plaintiff also asserted claims pursuant to Sections 11, 12(a)(2), and 15 of the Securities Act of 1933 (“Securities Act”). Among other things, the Amended Complaint alleged that Defendants made materially false and misleading statements and/or failed to disclose that: (a) Ryvyl misrepresented its serious issues with its internal controls; (b) Ryvyl’s financial statements for December 31, 2021, through and including interim periods ended September 30, June 30, and March 31, 2022, contained errors resulting in overstatements of revenue, assets, and stockholders’ equity and understatements of losses; (c) Ryvyl would need to restate its previously issued financial statements for those periods; and (d) as a result, Defendants’ statements about the Company’s business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis. Lead Plaintiff further alleged that the alleged misrepresentations proximately caused class member losses when the truth was revealed. In addition to claims asserted against Defendants, the Amended Complaint also asserted claims against EF Hutton F/K/A Kingswood Capital Markets and R.F. Lafferty & Co. (“Underwriter Defendants”) and against former Company Chief Financial Officer (“CFO”) J. Drew Byelick (“Byelick”).

On August 14, 2023, Defendants and the Underwriter Defendants each filed motions to dismiss the Amended Complaint, and, on August 23, 2023, former CFO Byelick filed his motion to dismiss the Amended Complaint.

On September 28, 2023, Lead Plaintiff filed an omnibus opposition to the motions to dismiss filed by Defendants, the Underwriter Defendants, and defendant Byelick. Defendants, the Underwriter Defendants, and defendant Byelick subsequently filed reply papers in support of their respective motions to dismiss.

With briefing on the motions to dismiss complete, the parties attempted to negotiate a resolution of the Action through a mediation overseen by Jed Melnick, Esq., a well-respected mediator of complex cases. The mediation proved unsuccessful, and the litigation continued. The parties, however, continued their attempts to reach a resolution of the Action through efforts with Mr. Melnick.

On March 1, 2024, the Court issued an order Granting in Part and Denying in Part the pending motions to dismiss. Cullen v. Ryvyl Inc., No. 3:23-CV-0185-GPC-SBC, 2024 WL 898206 (S.D. Cal. Mar. 1, 2024).

On May 1, 2024, Lead Plaintiff filed and served his Second Amended Class Action Complaint for Violations of the Federal Securities Laws (“Second Amended Complaint”) in response to the Court’s order Granting in Part and Denying in Part the Amended Complaint. In light of the Court’s order, and the holdings contained therein, Lead Plaintiff decided to allege Exchange Act claims, but not Securities Act claims. Given the Court’s ruling, Lead Plaintiff also elected not to pursue claims against the Underwriter Defendants or defendant Byelick in the Second Amended Complaint.

On July 1, 2024, Defendants filed a motion to dismiss the Second Amended Complaint. Lead Plaintiff filed an opposition to Defendants’ motion on August 15, 2024, and Defendants filed a reply in support of their motion on September 16, 2024.

On October 21, 2024, the Court issued an order Granting in Part and Denying in Part Defendants’ Motion to Dismiss the Second Amended Complaint. Cullen v. Ryvyl Inc., No. 3:23-CV-0185-GPC-SBC, 2024 WL 4536471 (S.D. Cal. Oct. 21, 2024).

In response to the Court’s order, Lead Plaintiff filed and served his Third Amended Class Action Complaint for Violations of the Federal Securities Laws (“Complaint” or “Third Amended Complaint”) on November 12, 2024.

In the subsequent months, Defendants sought and received extensions to respond to the Third Amended Complaint as the Parties continued to explore the possibility of resolution of the Action through Mr. Melnick. These negotiations culminated in an agreement to settle the Action for the equivalent of one million dollars ($1,000,000.00) in cash and stock.

Lead Plaintiff’s and Defendants’ agreement in principle to settle the Action was memorialized in a term sheet (the “Term Sheet”). The Term Sheet sets forth, among other things, Lead Plaintiff’s agreement to settle and release all claims asserted against Defendants in the Action in return for the equivalent of one million dollars ($1,000,000.00) in cash and stock for the benefit of the Settlement Class, subject to certain terms and conditions and the execution of a customary “long form” stipulation and agreement of settlement and related papers.

Based on the investigation and mediation of the case and Lead Plaintiff’s direct oversight of the prosecution of this matter and with the advice of his counsel, Lead Plaintiff has agreed to settle and release the claims raised in the Action pursuant to the terms and provisions of the Stipulation, after considering, among other things: (a) the substantial financial benefit that Lead Plaintiff and the other members of the Settlement Class will receive under the proposed Settlement; and (b) the significant risks and costs of continued litigation and trial.

Defendants are entering into the Stipulation solely to eliminate the uncertainty, burden and expense of further protracted litigation. Each of the Defendants denies any wrongdoing, and the Stipulation shall in no event be construed or deemed to be evidence of or an admission or concession on the part of any of the Defendants, or any other of the Released Defendants’ Parties (defined in FAQ 6), with respect to any claim or allegation of any fault or liability or wrongdoing or damage whatsoever, or any infirmity in the defenses that the Defendants have, or could have, asserted. Similarly, the Stipulation shall in no event be construed or deemed to be evidence of or an admission or concession on the part of Lead Plaintiff of any infirmity in any of the claims asserted in the Action, or an admission or concession that any of the Defendants’ defenses to liability had any merit.

On August 20, 2025, the Court preliminarily approved the Settlement, authorized the Postcard Notice to be mailed to potential Settlement Class Members and the Notice to be posted online and mailed to potential Settlement Class Members upon request, and scheduled the Settlement Hearing to consider whether to grant final approval to the Settlement.

3. How do I know if I am affected by the Settlement? Who is included in the Settlement Class?

If you are a member of the Settlement Class, you are subject to the Settlement, unless you timely request to be excluded. The Settlement Class consists of:

“all persons and entities that purchased the publicly traded common stock of Ryvyl Inc. (NASDAQ: RVYL) and/or Greenbox POS (NASDAQ: GBOX) between May 13, 2021, and January 20, 2023, both dates inclusive, and were damaged thereby. “

Excluded from the Settlement Class are: (a) persons and entities that suffered no compensable losses; and (b)(i) Defendants; (ii) any person who served as a partner, control person, officer and/or director of the Company during the Settlement Class Period, and members of their Immediate Families; (iii) present and former parents, subsidiaries, assigns, successors, affiliates, and predecessors of the Company; (iv) any entity in which any excluded person or entity has or had a controlling interest; (v) any trust of which an Individual Defendant is the settlor or which is for the benefit of an Individual Defendant and/or member(s) of their Immediate Families; and (vi) the legal representatives, heirs, successors, predecessors, and assigns of any person or entity excluded under provisions (i) through (v) hereof.

Also excluded from the Settlement Class are any persons and entities who or which submit a request for exclusion from the Settlement Class that is accepted by the Court (see FAQ 10). For the avoidance of doubt, “affiliates” are persons or entities that directly, or indirectly through one or more intermediaries, control, are controlled by or are under common control with one of the Defendants.

Please Note: Receipt of the postcard notice does not mean that you are a Settlement Class Member or that you will be entitled to receive proceeds from the Settlement.

If you are a Settlement Class Member and you wish to be eligible to participate in the distribution of proceeds from the Settlement, you are required to file a Claim Form online here or submit the Claim Form that is available here or which can be mailed to you upon request to the Claims Administrator, and the required supporting documentation as set forth therein, postmarked or received no later than December 27, 2025.

4. What are Lead Plaintiff’s reasons for the Settlement?

Lead Plaintiff and Lead Counsel believe that the claims asserted against the Defendants have merit. They recognize, however, many offsetting factors such as the expense and length of the continued proceedings necessary to pursue their claims against the Defendants through trial and appeals, as well as the very substantial risks they would face in establishing liability and damages. For instance, in the March 1, 2024, order Granting in Part and Denying in Part Motions to Dismiss, the Court found that the Company’s restatement did not encompass the false and misleading statements alleged with respect to the claims alleged pursuant to the Securities Act.

Specifically, the Court held that “[t]he 2023 restatement of Ryvyl’s financial statements does not demonstrate anything about the Registration Documents because the Registration Documents depended on financial statements from 2019 and 2020, which were not restated.” Additionally, the Court held that some of the false and misleading statements with respect to the Exchange Act claims were not adequately alleged, and that Lead Plaintiff had sufficiently alleged scienter under the Exchange Act with respect to some Defendants, but not others. Furthermore, most of the damages alleged in the Action related to the claims brought pursuant to the Securities Act, which the Court found to be deficient. Defendants, moreover, were self-insured, thereby reducing or foreclosing any available source of recovery from insurance in the Action.

More broadly, for Lead Plaintiff to prevail at trial, he would have to prove each of the following elements: (i) falsity (i.e., that the Defendants made false statements); (ii) materiality (that the Defendants made false statements about a material fact); (iii) scienter (that there was a strong, or cogent inference that the Defendants made such materially false statements on purpose, or with deliberate recklessness); (iv) loss causation (that the Defendants’ materially false statements proximately caused the later decline in the Company’s stock price, not something else—like a weakening business overall); and (v) damages.

Each element had its respective risks. For instance, even if Lead Plaintiff could adequately prove falsity, he would still face a significant challenge in proving scienter with respect to some Defendants. Indeed, the Court granted Defendants’ motion to dismiss “as to Defendant Errez, and as to Defendants Chung, Nisan, and Ryvyl . . . for the alleged misstatements in the 2021 interim reports and accompanying SOX certifications, and additionally as to Defendant Chung for the alleged misstatements in the third quarter 2022 report and its accompanying SOX certification.”

Furthermore, the amount of damages for the remaining claims severely limited any potential recovery in the Action. Indeed, Lead Plaintiff’s best-case scenario for damages under the remaining Section 10(b) claims was, at most, $2.8 million ($2,800,000.00).

Simply put, if the litigation were to continue, Lead Plaintiff would need to prevail on multiple elements, and at several stages—motions for class certification, summary judgment, and trial—to recovery anything. And if he prevailed at all those stages, he would likely face appeals. Thus, there were very significant risks attendant to the continued prosecution of the Action, and even if Lead Plaintiff prevailed, it would be several years in the future.

In light of these risks and other considerations, the amount of the Settlement and the immediacy of recovery to the Settlement Class, Lead Plaintiff and Lead Counsel believe that the proposed Settlement is fair, reasonable, and adequate, and in the best interests of the Settlement Class. Lead Plaintiff and Lead Counsel believe that the Settlement provides a substantial benefit to the Settlement Class, namely the equivalent of one million dollars ($1,000,000) in cash and stock (less the various deductions described in the Notice and this website), as compared to the risk that the claims in the Action would produce a smaller, or no recovery, after class certification, summary judgment, trial and appeals, possibly years in the future.

Defendants have denied the claims asserted against them in the Action and deny having engaged in any wrongdoing or violation of law of any kind whatsoever. Defendants have agreed to the Settlement solely to eliminate the burden and expense of continued litigation. Accordingly, the Settlement may not be construed as an admission of any wrongdoing by Defendants.

5. What might happen if there were no Settlement?

If there were no Settlement and Lead Plaintiff failed to establish any essential legal or factual element of their claims against Defendants, neither Lead Plaintiff nor the other members of the Settlement Class would recover anything from Defendants. Also, if Defendants were successful in proving any of their defenses, either at summary judgment, at trial or on appeal, the Settlement Class could recover substantially less than the amount provided in the Settlement, or nothing at all.

6. How are Settlement Class members affected by the action and the Settlement?

As a Settlement Class Member, you are represented by Lead Plaintiff and Lead Counsel, unless you enter an appearance through counsel of your own choice at your own expense. You are not required to retain your own counsel, but if you choose to do so, such counsel must file a notice of appearance on your behalf and must serve copies of his or her appearance on the attorneys listed in FAQ 11.

If you are a Settlement Class Member and do not wish to remain a Settlement Class Member, you may exclude yourself from the Settlement Class by following the instructions in FAQ 10.

If you are a Settlement Class Member and you wish to object to the Settlement, the Plan of Allocation, or Lead Counsel’s application for attorneys’ fees and reimbursement of Litigation Expenses, and if you do not exclude yourself from the Settlement Class, you may present your objections by following the instructions in FAQ 11.

If you are a Settlement Class Member and you do not exclude yourself from the Settlement Class, you will be bound by any orders issued by the Court. If the Settlement is approved, the Court will enter a judgment (the “Judgment”). The Judgment will dismiss with prejudice the claims against Defendants and will provide that, upon the Effective Date of the Settlement, Lead Plaintiff and the other members of the Settlement Class, on behalf of themselves, and on behalf of any other person or entity legally entitled to bring Released Plaintiff’s Claims on behalf of the respective Settlement Class Members in such capacity only, shall be deemed to have, and by operation of law and of the judgment shall have, fully, finally and forever released each and every Released Plaintiff’s Claim against the Defendants and the other Released Defendants’ Parties, and shall forever be barred and enjoined from prosecuting, directly or indirectly, representatively, or in any other capacity, against any of the Released Defendants’ Parties any or all of the Released Plaintiff’s Claims. For more information about the Released Claims, please review the Notice and Stipulation and Agreement of Settlement.

7. How do I participate in the Settlement? What do I need to do?

To be eligible for a payment from the proceeds of the Settlement, you must be a member of the Settlement Class, and you must timely complete and return the Claim Form with adequate supporting documentation postmarked or received no later than December 27, 2025. You can submit a Claim Form and supporting documentation online here. Claim Forms are also available for download here, or you may request that a Claim Form be mailed to you by calling the Claims Administrator toll free at (833) 360-6785 or by emailing info@RyvylSecuritiesSettlement.com, or by mail addressed to: Ryvyl Securities Settlement, c/o Claims Administrator, P.O. Box 25419, Santa Ana, CA 92799. To file by mail or email, send your completed Claim form and supporting documentation to the Claims Administrator to the email address or mailing address above.

Please retain all records of your ownership of and transactions in Ryvyl and/or Greenbox common stock, as they may be needed to document your Claim. If you request exclusion from the Settlement Class or do not submit a timely and valid Claim Form, you will not be eligible to share in the Net Settlement Fund.

8. How much will my payment be?

At this time, it is not possible to make any determination as to how much any individual Settlement Class Member may receive from the Settlement.

Pursuant to the Settlement, Defendants have agreed to pay or caused to be paid the equivalent of one million dollars ($1,000,000.00) in cash and stock. If the Settlement is approved by the Court and the Effective Date occurs, the “Net Settlement Fund” (that is, the Settlement Fund less (a) all federal, state and/or local taxes on any income earned by the Settlement Fund and the reasonable costs incurred in connection with determining the amount of and paying taxes owed by the Settlement Fund (including reasonable expenses of tax attorneys and accountants); (b) the costs and expenses incurred in connection with providing notice to Settlement Class Members and administering the Settlement on behalf of Settlement Class Members; and (c) any attorneys’ fees and Litigation Expenses awarded by the Court) will be distributed to Settlement Class Members who submit valid Claim Forms, in accordance with the proposed Plan of Allocation or such other plan of allocation as the Court may approve.

The Net Settlement Fund will not be distributed unless and until the Court has approved the Settlement and a plan of allocation, and the time for any petition for rehearing, appeal or review, whether by certiorari or otherwise, has expired.

Neither Defendants nor any other person or entity that paid any portion of the Settlement Amount on their behalf are entitled to get back any portion of the Settlement Fund once the Court’s order or judgment approving the Settlement becomes Final. Defendants shall not have any liability, obligation or responsibility for the administration of the Settlement, the disbursement of the Net Settlement Fund or the plan of allocation.

Approval of the Settlement is independent from approval of a plan of allocation. Any determination with respect to a plan of allocation will not affect the Settlement, if approved.

Unless the Court otherwise orders, any Settlement Class Member who fails to submit a Claim Form postmarked or received on or before December 27, 2025, shall be fully and forever barred from receiving payments pursuant to the Settlement but will in all other respects remain a Settlement Class Member and be subject to the provisions of the Stipulation, including the terms of any Judgment entered and the releases given. This means that each Settlement Class Member releases the Released Plaintiff’s Claims (as defined in FAQ 6) against the Released Defendants’ Parties (as defined in FAQ 6) and will be enjoined and prohibited from filing, prosecuting, or pursuing any of the Released Plaintiff’s Claims against any of the Released Defendants’ Parties whether or not such Settlement Class Member submits a Claim Form.

Participants in and beneficiaries of a plan covered by ERISA (“ERISA Plan”) should NOT include any information relating to their transactions in Ryvyl common stock held through the ERISA Plan in any Claim Form that they may submit in this Action. They should include ONLY those shares of Ryvyl and/or Greenbox POS common stock that they purchased outside of the ERISA Plan. Claims based on any ERISA Plan’s purchases of Ryvyl and/or Greenbox POS common stock during the Settlement Class Period may be made by the plan’s trustees. To the extent any of the Defendants or any of the other persons or entities excluded from the Settlement Class are participants in the ERISA Plan, such persons or entities shall not receive, either directly or indirectly, any portion of the recovery that may be obtained from the Settlement by the ERISA Plan.

The Court has reserved jurisdiction to allow, disallow, or adjust on equitable grounds the Claim of any Settlement Class Member. Each Claimant shall be deemed to have submitted to the jurisdiction of the Court with respect to his, her or its Claim Form.

Only Settlement Class Members, i.e., persons and entities who purchased publicly traded Ryvyl and/or Greenbox POS common stock during the Settlement Class Period and were damaged as a result of the alleged fraud, will be eligible to share in the distribution of the Net Settlement Fund. Persons and entities that are excluded from the Settlement Class by definition or that exclude themselves from the Settlement Class pursuant to request will not be eligible to receive a distribution from the Net Settlement Fund and should not submit Claim Forms. Publicly traded Ryvyl and Greenbox POS common stock are the only securities included in the Settlement.

The Plan of Allocation is being proposed to the Court for its approval by Lead Plaintiff after consultation with his damages expert. The Court may approve this plan as proposed or it may modify the Plan of Allocation without further notice to the Settlement Class. Any Orders regarding any modification of the Plan of Allocation will be posted to the Important Documents page of this website.

9. What payment are the attorneys for the Settlement Class seeking? How will the lawyers be paid?

Each Settlement Class Member will be bound by all determinations and judgments in this lawsuit, whether favorable or unfavorable, unless such person or entity mails or delivers a written Request for Exclusion from the Settlement Class, addressed to the Claims Administrator at Ryvyl Securities Settlement, EXCLUSIONS, c/o Claims Administrator, P.O. Box 25419, Santa Ana, CA 92799. The exclusion request must be received by or postmarked no later than November 28, 2025. You will not be able to exclude yourself from the Settlement Class after that date.

Each Request for Exclusion must: (a) state the name, address, and telephone number of the person or entity requesting exclusion, and in the case of entities, the name and telephone number of the appropriate contact person; (b) state that such person or entity “requests exclusion from the Settlement Class in Cullen v. Ryvyl Inc. et al., Case No. 3:23-cv-00185-GPC-SBC”; (c) state the number of shares of publicly traded Ryvyl and Greenbox POS common stock that the person or entity requesting exclusion purchased and sold during the Settlement Class Period, as well as the dates and prices of each such purchase and sale; and (d) be signed by the person or entity requesting exclusion or an authorized representative. A Request for Exclusion shall not be valid and effective unless it provides all the information called for in this paragraph and is submitted within the time stated above or is otherwise accepted by the Court.

If you do not want to be part of the Settlement Class, you must follow these instructions for exclusion even if you have pending, or later file, another lawsuit, arbitration, or other proceeding relating to any Released Plaintiff’s Claim against any of the Released Defendants’ Parties.

If you ask to be excluded from the Settlement Class, you will not be eligible to receive any payment out of the Net Settlement Fund.

Defendants have the right to terminate the Settlement if valid requests for exclusion are received from persons and entities entitled to be members of the Settlement Class in an amount that exceeds an amount agreed to by Lead Plaintiff and Defendants.

10. What if I do not want to be a member of the Settlement Class? How do I exclude myself?

If you are unable to submit a Claim Form online here, you may download a paper Claim Form here, or request a copy of the paper Claim Form from the Claims Administrator via email at info@RyvylSecuritiesSettlement.com or by calling 866-675-2446.

As part of the Claim Form, you will be required to provide information necessary to substantiate the claim, including but not limited to: copies of third party documentary evidence of purchases and dispositions of the Security during the Relevant Period, as well as holdings of the Security at pertinent dates; any requested explanatory information or attestations; and/or any required personal identification information. If you are not a U.S. Person, as defined in Section IV of the Claim Form, you must also submit a completed IRS Form W-8BEN, W-8BEN-E, or other W-8 series form, which can be found by visiting the following IRS website: www.irs.gov/forms-instructions.

Claim Forms submitted via mail must be sent to the address provided on the Claim Form and postmarked (or if not sent by U.S. Mail, then received) by September 27, 2025.

If you submit a Claim Form that fails to provide all required information or is otherwise deficient; or your claim is denied, you will receive a Claim Status Notice advising you of the reason(s) why the claim is deficient or denied and explaining how to cure the deficiencies or request reconsideration.

11. When and where will the Court decide whether to approve the Settlement? Do I have to come to the hearing? May I speak at the hearing if I don’t like the Settlement?

Settlement Class Members do not need to attend the Settlement Hearing. The Court will consider any submission made in accordance with the provisions below even if a Settlement Class Member does not attend the hearing. You can participate in the Settlement without attending the Settlement Hearing.

The Settlement Hearing will be held on December 19, 2025, at 1:30 p.m. PT, before the Honorable Gonzalo P. Curiel at the United States District Court for the Southern District of California, James M. Carter and Judith N. Keep United States Courthouse, 333 West Broadway, Courtroom 12A, San Diego, CA 92101. At the Settlement Hearing, the Court will determine, among other things:

1. whether the proposed Settlement on the terms and conditions provided for in the Stipulation is fair, reasonable, and adequate to the Settlement Class, and should be finally approved by the Court;

2. whether, for purposes of the Settlement only, the Action should be certified as a class action on behalf of the Settlement Class, Lead Plaintiff should be certified as the class representative for the Settlement Class, and Lead Counsel should be appointed as class counsel for the Settlement Class;

3. whether the Action should be dismissed with prejudice against Defendants and the Releases specified and described in the Stipulation (and in the Notice) should be granted;

4. the fairness of the terms and conditions of the issuance of the Settlement Shares pursuant to an exemption from registration requirements under Section 3(a)(10) of the Securities Act in exchange for the settlement and release of the Released Plaintiff’s Claims against the Released Defendants’ Parties;

5. whether the proposed Plan of Allocation should be approved as fair and reasonable;

6. whether Lead Counsel’s application for an award of attorneys’ fees and Litigation Expenses should be approved; and

7. any other matters that may properly be brought before the Court in connection with the Settlement.

The Court reserves the right to certify the Settlement Class; approve the Settlement, the Plan of Allocation, and Lead Counsel’s motion for an award of attorneys’ fees and Litigation Expenses; and/or consider any other matter related to the Settlement at or after the Settlement Fairness Hearing without further notice to the members of the Settlement Class.

The date and time of the Settlement Hearing may be changed by the Court without further written notice to the Settlement Class. If you intend to attend the Settlement Hearing, you should confirm the date and time with Lead Counsel, check this website or the Court’s PACER site.

Any Settlement Class Member who or which does not request exclusion may object to the Settlement, the proposed Plan of Allocation or Lead Counsel’s motion for an award of attorneys’ fees and reimbursement of Litigation Expenses. Objections must be in writing. You must file any written objection, together with copies of all other papers and briefs supporting the objection, with the Clerk’s Office at the United States District Court for the Southern District of California at the address set forth below on or before November 28, 2025. You must also serve the papers on Lead Counsel and on Defendants’ Counsel at the addresses set forth below so that the papers are received by or postmarked no later than November 28, 2025.

Any objection: (a) must state the name, address, and telephone number of the person or entity objecting and must be signed by the objector; (b) must contain a statement of the Settlement Class Member’s objection or objections, and the specific reasons for each objection, including any legal and evidentiary support the Settlement Class Member wishes to bring to the Court’s attention; and (c) must include documents sufficient to prove membership in the Settlement Class, including the number of shares of Ryvyl and Greenbox POS common stock that the person or entity objecting purchased and sold during the Settlement Class Period, as well as the dates and prices of each such purchase and sale. You may not object to the Settlement, the Plan of Allocation or Lead Counsel’s motion for attorneys’ fees and reimbursement of Litigation Expenses if you exclude yourself from the Settlement Class or if you are not a member of the Settlement Class.

You may submit a written objection without having to appear at the Settlement Hearing. You may not, however, appear at the Settlement Hearing to present your objection unless you first submit and serve a written objection in accordance with the procedures described above, unless the Court orders otherwise.

If you wish to be heard orally at the hearing in opposition to the approval of the Settlement, the Plan of Allocation or Lead Counsel’s motion for an award of attorneys’ fees and reimbursement of Litigation Expenses, and if you timely submit a written objection as described above, you must also file a notice of appearance with the Clerk’s Office and serve it on Lead Counsel and Defendants’ Counsel at the addresses set forth above so that it is received on or before November 28, 2025. Persons who intend to object and desire to present evidence at the Settlement Hearing must include in their written objection or notice of appearance the identity of any witnesses they may call to testify and exhibits they intend to introduce into evidence at the hearing. Such persons may be heard orally at the discretion of the Court.

You are not required to hire an attorney to represent you in making written objections or in appearing at the Settlement Hearing. However, if you decide to hire an attorney, it will be at your own expense, and that attorney must file a notice of appearance with the Court and serve it on Lead Counsel and Defendants’ Counsel at the addresses set forth above so that the notice is received on or before November 28, 2025.

Unless the Court orders otherwise, any Settlement Class Member who does not object in the manner described above will be deemed to have waived any objection and shall be forever foreclosed from making any objection to the proposed Settlement, the proposed Plan of Allocation or Lead Counsel’s motion for an award of attorneys’ fees and reimbursement of Litigation Expenses. Settlement Class Members do not need to appear at the Settlement Hearing or take any other action to indicate their approval.

12. What if I bought shares on someone else’s behalf?

If you purchased the publicly traded common stock of Ryvyl and/or Greenbox POS, during the period from May 13, 2021, and January 20, 2023, both dates inclusive, for the beneficial interest of persons or organizations other than yourself, within seven (7) calendar days of receipt of the Claims Administrator’s notice of the Settlement you must do one of the following:

1. request from the Claims Administrator sufficient copies of the Postcard Notice to forward to all such beneficial owners and within seven (7) calendar days of receipt of those Postcard Notices forward them to all such beneficial owners; or

2. request from the Claims Administrator a link to the Notice and Claim Form and, within seven (7) calendar days of receipt of the link, email the link to all such beneficial owners for whom valid email addresses are available; or

3. provide a list of the names, mailing addresses and email addresses (to the extent available) of all such beneficial owners to the Claims Administrator using the link on the Nominees page, via email to broker@RyvylSecuritiesSettlement.com, or by mail at Ryvyl Securities Settlement, c/o Claims Administrator, P.O. Box 25419, Santa Ana, CA 92799, in which event the Claims Administrator shall promptly mail the Postcard Notice, or email a link to the Notice and Claim Form, to such beneficial owners.

Nominees that choose to follow procedures (a) or (b) shall also send a statement to the Claims Administrator confirming that the mailing or emailing was made as directed.

Upon full and timely compliance with these directions, nominees may seek reimbursement of their reasonable expenses actually incurred, not to exceed: (a) $0.02 per name, mailing address, and email address (to the extent available) provided to the Claims Administrator; (b) $0.02 per email for emailing notice; or (c) $0.02 per postcard, plus postage at the pre-sort rate used by the Claims Administrator, for mailing the Postcard Notice, by providing the Claims Administrator with proper documentation supporting the expenses for which reimbursement is sought. Any dispute concerning the reasonableness of reimbursement costs shall be resolved by the Court.

You are not authorized to print the Postcard Notice yourself. Postcard Notices may only be printed by the Court-appointed Claims Administrator.

13. Can I see the court file? Whom should I contact if I have questions?

This website and the Notice contains only a summary of the terms of the proposed Settlement. For more detailed information about the matters involved in this Action, you are referred to the papers on file in the Action, including the Stipulation, which may be inspected on the Court’s PACER website, or during regular office hours at the Office of the Clerk, United States District Court for the Southern District of California, 333 West Broadway, Suite 420, San Diego, CA 92101. Additionally, copies of the Stipulation and any related orders entered by the Court will be posted on the Important Documents page.

All inquiries concerning the Notice and the Claim Form should be directed to the Claims Administrator or Lead Counsel at:

Do not call or write the Court, the office of the Clerk of the Court, Defendants, or their Counsel regarding the Settlement.