Robbins Geller Rudman & Dowd LLP, Berger Montague PC and Shapiro Haber & Urmy LLP Announce Proposed Settlement in the Luckin Coffee Inc. Securities Litigation

The following statement is being issued by Robbins Geller Rudman & Dowd LLP, Berger Montague PC and Shapiro Haber & Urmy LLP regarding the Luckin Coffee Inc. Securities Litigation:

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK: COMMERCIAL DIVISION

TO: ALL PERSONS AND ENTITIES (AND THEIR BENEFICIARIES) WHO, AT ANY TIME, PURCHASED OR OTHERWISE ACQUIRED LUCKIN COFFEE INC. (“LUCKIN”) CONVERTIBLE NOTES ISSUED ON OR ABOUT JANUARY 10, 2020 (THE “CONVERTIBLE NOTES”) AND WHO DID NOT RELEASE CLAIMS BASED ON THEIR PURCHASE OR ACQUISITION OF THE CONVERTIBLE NOTES IN CONNECTION WITH LUCKIN’S NOTEHOLDER SCHEME OF ARRANGEMENT, OR OTHERWISE (“SETTLEMENT CLASS” OR “SETTLEMENT CLASS MEMBERS”)

THIS NOTICE WAS AUTHORIZED BY THE COURT. IT IS NOT A LAWYER SOLICITATION. PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY.

YOU ARE HEREBY NOTIFIED that a hearing will be held on January 31, 2023, at 9:30 a.m., before the Honorable Andrew Borrok, Supreme Court of the State of New York, County of New York: Commercial Division, 60 Centre Street, Courtroom 238, New York, NY 10007, to determine whether: (1) the proposed settlement (the “Settlement”) of the above-captioned action as set forth in the Stipulation of Settlement (“Stipulation”)¹ for $7,000,000 in cash should be approved by the Court as fair, reasonable, and adequate; (2) the Judgment as provided under the Stipulation should be entered; (3) to award Plaintiffs’ Counsel attorneys’ fees and expenses out of the Settlement Fund (as defined in the Notice of Proposed Settlement of Class Action (“Notice”), which is discussed below), and, if so, in what amount; (4) to award Plaintiffs for representing the Settlement Class out of the Settlement Fund and, if so, in what amount; and (5) the Plan of Allocation should be approved by the Court as fair, reasonable, and adequate.

This Action is a consolidated securities class action brought on behalf of those persons who purchased or acquired Luckin Convertible Notes, against Luckin and certain of its current and former officers and directors and the Convertible Notes underwriters (collectively, “Defendants”) for, among other things, allegedly misstating and omitting material facts from the Prospectus filed with the U.S. Securities and Exchange Commission in connection with the offering of the Convertible Notes. Defendants deny all of Plaintiffs’ allegations.

IF YOU PURCHASED OR ACQUIRED LUCKIN CONVERTIBLE NOTES, YOUR RIGHTS MAY BE AFFECTED BY THE SETTLEMENT OF THIS ACTION.

To share in the distribution of the Settlement Fund, you must establish your rights by submitting a Proof of Claim and Release form (“Proof of Claim”) by mail (postmarked no later than January 30, 2023) or electronically (no later than January 30, 2023). Your failure to submit your Proof of Claim by January 30, 2023, will subject your claim to rejection and preclude your receiving any of the recovery in connection with the Settlement of this Action. If you are a member of the Settlement Class and do not request exclusion therefrom, you will be bound by the Settlement and any judgment and release entered in the Action, including, but not limited to, the Judgment, whether or not you submit a Proof of Claim.

If you have not received a copy of the Notice, which more completely describes the Settlement and your rights thereunder (including your right to object to the Settlement), and a Proof of Claim, you may obtain these documents, as well as a copy of the Stipulation (which, among other things, contains definitions for the defined terms used in this Summary Notice) and other settlement documents, online at www.LuckinConvertibleNotesSettlement.com, or by writing to:

Luckin Convertible Notes Settlement

Claims Administrator

c/o Gilardi & Co. LLC

P.O. Box 6177

Novato, CA 94948-6177

Inquiries should NOT be directed to Defendants, the Court, or the Clerk of the Court.

Inquiries, other than requests for the Notice or for a Proof of Claim, may be made to Lead Counsel:

IF YOU DESIRE TO BE EXCLUDED FROM THE SETTLEMENT CLASS, YOU MUST SUBMIT A REQUEST FOR EXCLUSION SUCH THAT IT IS POSTMARKED BY DECEMBER 27, 2022, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE. ALL MEMBERS OF THE SETTLEMENT CLASS WHO HAVE NOT REQUESTED EXCLUSION FROM THE SETTLEMENT CLASS WILL BE BOUND BY THE SETTLEMENT EVEN IF THEY DO NOT SUBMIT A TIMELY PROOF OF CLAIM.

IF YOU ARE A SETTLEMENT CLASS MEMBER, YOU HAVE THE RIGHT TO OBJECT TO THE SETTLEMENT, THE PLAN OF ALLOCATION, THE REQUEST BY PLAINTIFFS’ COUNSEL FOR AN AWARD OF ATTORNEYS’ FEES AND EXPENSES, AND/OR THE AWARDS TO PLAINTIFFS FOR REPRESENTING THE SETTLEMENT CLASS. ANY OBJECTIONS MUST BE FILED WITH THE COURT AND SENT TO LEAD COUNSEL AND LUCKIN’S COUNSEL BY DECEMBER 27, 2022, IN THE MANNER AND FORM EXPLAINED IN THE NOTICE.

_______________________

¹ The Stipulation can be viewed and/or obtained at www.LuckinConvertibleNotesSettlement.com.

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