SUPERIOR COURT OF THE STATE OF CALIFORNIA,
COUNTY OF SAN MATEO IF YOU WERE A SUBSCRIBER OF AN INDIVIDUAL HEALTH PLAN
ISSUED BY ANTHEM BLUE CROSS LIFE AND HEALTH INSURANCE COMPANY
ON SEPTEMBER 23, 2010, YOU ARE ENTITLED TO RIGHTS UNDER A CLASS ACTION SETTLEMENT

A California Court authorized this notice. This is not a solicitation from a lawyer. YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT OBJECT Write to the Court about why you don’t like the settlement. DO NOTHING You will be a member of the class and will receive the rights under the settlement described in this Notice. Your options – and the deadlines to exercise them – are explained in this Notice. In this Notice, Anthem Blue Cross Life and Health Insurance Company is referred to as “Anthem”. What is this lawsuit and this settlement about? This lawsuit is about the manner in which Anthem calculates premiums for individual health insurance coverage. The lawsuit includes questions about a practice known as “closing” “blocks” of business. The lawsuit raises concerns that Anthem’s practices may isolate aging and less healthy persons in “blocks” with no ability to move to a different “block” due to an inability to pass medical underwriting. The concern is that these isolated “blocks” may be used as a basis for calculating premiums, with the result that premiums for these “blocks” consistently increase, due to the lack of new, healthy persons joining the risk pool. The settlement addresses these questions, which may arise as a consequence of the federal Health Care Reform, known as the “Patient Protection And Affordable Care Act” or “PPACA”. PPACA creates a distinction between “grandfathered” health care coverage and health care coverage sold after September 23, 2010. Generally speaking, Anthem cannot sell “grandfathered” health care coverage – products available as of March 23, 2010 – after September 23, 2010. This has the effect of preventing new persons from joining the “blocks” of business in existence as of March 23, 2010. Because new applicants cannot purchase grandfathered policies, the pool of risks insured by those grandfathered policies is likely to become older and less healthy than the pool of risks insured by new policies, increasing the cost of providing the coverage.

The cost of providing the coverage is the main factor determining price. Therefore, the price of the grandfathered products is likely to increase, potentially at an accelerated pace. It is difficult to predict when this phenomenon may begin to affect the price of the grandfathered policies. At the outset, new products – with increased, more costly benefits under PPACA – may have higher prices than grandfathered policies. Over time, as the pool of risks insured by grandfathered products ages and becomes less healthy, it is more likely that the price for grandfathered products will increase at a faster rate, and may exceed the price for new products. The settlement creates an “open enrollment” benefit for all Anthem individual health plan subscribers with individual health plans issued by Anthem Blue Cross Life and Health Insurance Company as of September 23, 2010. All Anthem individual health plan subscribers will be allowed to enroll in any new product without medical underwriting, at various times. A “new” product is a product that is not “grandfathered”. This benefit will permit Anthem subscribers to enroll in products they may not otherwise qualify for due to pre‐existing medical conditions. This benefit will be provided at the time the new products are first offered. This benefit will also be provided, from the effective date of the settlement until December 31, 2013, at any time Anthem increases rates for a “grandfathered” product, for subscribers in that “grandfathered” product. By providing the open enrollment benefit both when the new products are introduced and at each time price is increased for a grandfathered product, class members have options. As a class member, you can keep your current policy, and wait until price increases for that policy to decide if you want to change policies.

Who is included in the settlement class? Everybody subscribed to an Anthem Blue Cross Life and Health Insurance Company individual health care plan on September 23, 2010. The specific plans affected are identified as 3500 Deductible PPO non‐HSA; 3500 Deductible PPO HSA; Basic 1000; Basic 2500; CORE 5000; Lumenos 1500 w/Maternity; Lumenos 2500 w/Maternity; Lumenos 3000 w/Maternity; Lumenos 5000 w/Maternity; Lumenos 1500 w/o Maternity; Lumenos 3000 w/o Maternity; Lumenos 5000 w/o Maternity; ClearProtection 1000; ClearProtection 3300; ClearProtection 5000; CoreGuard 750; CoreGuard 1500; CoreGuard 2500; CoreGuard 3500; CoreGuard 5000; CoreGuard 7500; CoreGuard 10000; PPO Share 5000; PPO Share 5000‐R; PPO Share 1000; PPO Share 500; Premier 1000; Premier 1500; Premier 2500; Premier 3500; Premier 5000; Premier 6000; Right Plan 40 ‐ full Rx; Right Plan 40 w/$500 ded ‐ full Rx; Right Plan 40 ‐ Generic Rx; Right Plan 40 w/$500 ded ‐ Generic Rx; Right Plan 40 ‐ no Rx; PPO Saver; SmartSense 500 GenRX; SmartSense 1500 GenRX; SmartSense 2500 GenRX; SmartSense 5000 GenRX; SmartSense 500 FullRX; SmartSense 1500 FullRX; SmartSense 2500 FullRX; SmartSense 5000 FullRX; Tonik 1500; Tonik 3000; Tonik 5000. ‐ 2 ‐ Questions? Visit the settlement website at www.anthemsanmateosettlement.com What are the settlement benefits? At the time Anthem first offers new individual health care coverage products in accordance with the federal PPACA, all members of the settlement class will have the opportunity to enroll in any new product, without medical underwriting. The new products to be made available include new individual products sold by Anthem Blue Cross Life and Health Insurance Company and Blue Cross of California doing business as Anthem Blue Cross. From the effective date of this settlement until December 31, 2013, any time Anthem raises rates for a grandfathered health care coverage product, subscribers with that grandfathered product will have the opportunity to enroll in any product that is open for enrollment, without medical underwriting.

The open products to be made available include open individual products sold by Anthem Blue Cross Life and Health Insurance Company and Blue Cross of California doing business as Anthem Blue Cross. How do I claim my settlement benefits? You do not have to do anything in response to this notice to claim settlement benefits. Separate notices will be sent to you directly by Anthem with instructions on the actions you must take, and the applicable deadlines, each time a benefit is available. You must follow the directions given in those notices in order to obtain the settlement benefit. How do I know if enrolling in a new product is right for me? There are many considerations that may impact your decision each time the open enrollment benefit is made available to you. Separate notices will be sent to you directly by Anthem each time you are eligible for the open enrollment benefit. These notices will explain your options at that time, and will include a matrix of the plans available to you. You should carefully consider your decision each time the open enrollment benefit is offered. At that time, you will have the additional, specific information sent to you directly by Anthem Blue Cross Life and Health Insurance Company, and you will have the opportunity to consult with your broker and/or with Anthem representatives.

The specific notices sent each time the open enrollment benefit is made available will include contact information for Anthem representatives. Who represents my interests in this settlement? The Court has designated the plaintiffs who brought the lawsuit as the Class Representatives. Class Counsel is the lawyer for the Class. The Class Representatives and lawyer will act as your representatives for this settlement with Anthem. If you are a Class Member, you may, but are not required to, enter an appearance through counsel of your own choosing at your own expense. Details regarding the settlement hearing are provided below. If you do not do so, you will be represented by Class Counsel: Ronald S. Galasi, Esq. Law Offices Of Ronald S. Galasi 1350 Old Bayshore Highway, Suite 610 Burlingame, California 94010 Telephone: (650) 685‐6200 Email: galasi@msn.com Do I have to pay money to participate in the Class? No. You will not be personally responsible for any costs or attorney’s fees incurred in this lawsuit. If the Court approves the proposed settlement, Anthem will be required to pay a total sum of $600,000.00 to Class Counsel to cover all advocacy compensation including attorney’s fees to Class Counsel, expenses incurred by Class Counsel, plus any and all fees and expenses incurred by the Class Representatives or any consultants hired by Class Counsel in pursuing this lawsuit. What is the effect of the judgment in this class action? As a Class Member, you will be bound by any judgment benefitting or adverse to the Class and you may not maintain a separate lawsuit. You will have your claim for relief as stated in the Amended Consolidated Class Action Complaint decided in this lawsuit and receive any relief for the claims stated under the settlement. The judgment in this Class Action will also be binding as to any other claims or lawsuits you or other Class Members have outstanding. Any such claims, or future claims, which are covered by the Release included in the judgment in this Class Action, will be barred by the judgment in this case.

Can I exclude myself from the settlement? Because all health plan members should be treated the same, you may not exclude yourself from the settlement. ‐ 3 ‐ Questions? Visit the settlement website at www.anthemsanmateosettlement.com I wish to object to the settlement. How do I object? The Court has preliminarily approved the settlement. If there is something about the settlement you do not like, you may file an objection with the Court. You will still be in the settlement and you will still be bound by any judgment, if the Court gives final approval of this settlement. If you want to object, you must file your objection in writing with the Court. Your objection must include: (1) Your name, address and telephone number; (2) Your Anthem policy number (if available); (3) The reason you do not like the settlement; (4) The case name and number of the lawsuit which are Lichtman/Serencsa v. Anthem Blue Cross Life and Health Insurance Company, San Mateo County Superior Court Case Nos. CIV492028/CIV493800. You must file your written objection with the Court no later than February 15, 2011. The address for filing your objection is: San Mateo Superior Court Department 2 800 N. Humboldt San Mateo, California 94401 You must also mail or deliver copies of your objection to the attorneys in this case: Ronald S. Galasi, Esq. Law Offices Of Ronald S. Galasi 1350 Old Bayshore Highway, Suite 610 Burlingame, California 94010 Telephone: (650) 685‐6200 Email: galasi@msn.com Vanessa O. Wells Sedgwick, Detert, Moran & Arnold LLP One Market Plaza Steuart Tower, 8th Floor San Francisco, California 94105 Telephone: (415) 781‐7900 Email: vanessa.wells@sdma.com The written objections delivered to the Court and the attorneys must be postmarked by February 15, 2011, or your objection may not be considered. When and where will the Court decide whether to grant final approval of the settlement? The Court has scheduled a hearing at 9:00 a.m., on March 1, 2011, at the San Mateo Superior Court, Department 2, 800 N. Humboldt, San Mateo, California 94401. At this hearing, the Court will consider whether the settlement is fair, reasonable and adequate.

If there are objections, the Court will consider them. At the hearing, the Court will decide whether to grant final approval of the settlement. Additional Information Complete copies of the pleadings and other documents filed in the litigation may be examined and copied at any time during regular office hours at the offices of the Clerk of the Court, San Mateo Superior Court, 400 County Center, Redwood City, CA 94063. The settlement agreement and other information are also available on the Settlement website at www.anthemsanmateosettlement.com.
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You may also write to: Anthem Blue Cross Life Settlement, P.O. Box 2440, Faribault MN 55021‐9140. Additionally, you may call toll‐free 1‐(877) 522‐0171 for additional information. PLEASE DO NOT CALL OR WRITE TO THE COURT FOR INFORMATION OR ADVICE. Hon. Marie Weiner Dated: December 10, 2010 Judge of the Superior Court of the State of California, County of San Mateo ANTHEM BLUE CROSS LIFE SETTLEMENT ADMINISTRATOR PO BOX 2441 FARIBAULT MN 55021‐9141 PRESORTED FIRST-CLASS MAIL U.S. POSTAGE P A I D Rust Consulting, Inc.