Case Overview

Between August 10, 2022 and May 21, 2024 inclusive, CAE Inc. and its officers, Marc Parent and Sonya Branco (the “Defendants”), published documents that contain misrepresentations and omit to disclose material facts relating to, among other things, eight firm-fixed-priced defense contracts that had a disproportionate impact on the overall profitability of the company’s “defense and security” business segment.

The effect of Defendants’ misconduct was to artificially inflate the value of CAE Inc.’s securities. As a result, members of the proposed class acquired CAE Inc.’s securities at artificially inflated prices that did not reflect their true value.

When the truth emerged after market close on May 21, 2024, the value of CAE Inc.’s securities plummeted, resulting in a loss to the members of the proposed class.  

The proposed class action seeks to obtain a judgment ordering the Defendants to pay damages to each member of the proposed class.  

Members of the Proposed Class

You are a member of the proposed class action if you acquired one or more of CAE Inc. common shares between August 10, 2022 and May 21, 2024 inclusive, and still held all or some of those common shares at any time between February 14, 2024 and May 22, 2024, inclusive.    

Notice to Members

Mouvement d’éducation et de défense des actionnaires v. CAE inc., Marc Parent et Sonya Branco

No : 500-06-001312-244

NOTICE OF CLASS MODIFICATION IN THE CLASS ACTION

You are subject to this notice if you purchased one or more securities of CAE Inc. other than common shares (the “Excluded Members”) between August 10, 2022 and May 21, 2024 (the “Class Period”). Read this notice carefully as it may affect your rights.

On June 6, 2024, a motion for authorization to institute a class action was filed on behalf of the following persons (the “Class”):

All persons who acquired one or more CAE Inc. securities between August 10, 2022 and May 21, 2024, inclusive and who still held some or all of these securities at market open on May 22, 2024.

The class action seeks to hold CAE Inc. Marc Parent and Sonya Branco (collectively, the “Defendants”) liable for allegedly breaching their obligations under the Securities Act (Québec) and the Civil Code of Québec.  The class action alleges that the Defendants published or permitted the publication of documents and/or made public statements containing false and misleading information and/or failed to disclose material facts in connection with eight fixed-price contracts in CAE’s Defence sector and/or failed to timely inform the Class of a material change in the activity, operation, or capital of CAE Inc.

On July 28, 2025, the Superior Court of Québec authorized the modification of the Class’s description.  The new Class description is the following:

All persons who acquired one or more CAE Inc. common shares between August 10, 2022, and May 21, 2024, inclusive and who still held some or all of these common shares at any time between February 14, 2024 and May 22, 2024, inclusive.

The order authorizing the modification can be viewed by accessing the following link: http://www.scott-scott.ca/wp-content/uploads/2025/07/2025-07-28-Jugement-RE-De-bene-esse-Avis.pdf.

As a result of this change, the prescription begins to run anew for any recourse that the Excluded Members may have for any right arising from the same source.

QUESTIONS

All questions may be sent to the Class’s attorneys at the following addresses:

Mtre Emilie B. Kokmanian
Scott+Scott Attorneys at Law, LLP
230 Park Ave, 24^th Fl.
New York, New York, 10029
Telephone: 646-992-4754
Fax: 212-223-6334
Email: [email protected]

Or

Mtre Jacquelin Charbonneau-Dufresne
Belleau Lapointe, LLP
300 Place d’Youville, Suite B-10
Montréal, Québec H2Y 2B6
Telephone: 514-987-6700
Fax: 514-987-6886
Email: [email protected]

The parties’ arguments regarding the motion for authorization to institute a class action have not been heard by the Court and no decision has been made regarding the Defendants’ potential liability.

This notice and its publication were approved by the Superior Court of Québec.

Case Status

On June 10, 2024, an Application for Authorization to Institute a Class Action and for Authorization to Bring an Action for Damages under article 225.4 of the Securities Act, CQLR c V-1.1 was filed before the Superior Court of Québec.  

On July 11, 2024, the Plaintiff filed a De Bene Esse Application to Amend the Application for Authorization to Institute a Class Action. The application was granted by the Court on October 15, 2024.

On May 20 2025, the Plaintiff filed a second De Bene Esse Application to Amend the Application for Authorization to Institute a Class Action. This application was granted by the Court on July 28, 2025 along with Plaintiff’s proposed notice to members, a copy of which is appended to the Order bearing that date reproduced under the “Proceedings and Judgments” heading below.

The class action is currently at the authorization stage.

Proceedings and Judgments

• Application for Authorization to Institute a Class Action and for Authorization to Bring an Action for Damages under article 225.4 of the Securities Act (in French only)
• De Bene Esse Application to Amend the Application for Authorization to Institute a Class Action (in French only)
• Order dated October 15, 2024 (in French only)
• Amended Application for Authorization to Institute a Class Action and for Authorization to Institute a Class Action and for Authorization to Bring an Action for Damages under article 225.4 of the Securities Act – July 11, 2024 (in French only)
• Second De Bene Esse Application to Amend the Application for Authorization to Institute a Class Action (in French only)
• Order dated July 28, 2025 (in French only)
• Reamended Application for Authorization to Institute a Class Action and for Authorization to Bring an Action for Damages under article 225.5 of the Securities Act – May 20, 2025 (in French only)