THIS DOCUMENT IS CONFIDENTIAL.

ACCESS IS PROHIBITED EXCEPT AS AUTHORIZED BY COURT ORDER.

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

YATRA ONLINE, INC.,

Plaintiff,

v.

EBIX, INC. and EBIXCASH TRAVELS,

INC.

Defendants.

C.A. No. 2020-0444-JRS

PUBLIC [REDACTED]

VERSION AS FILED ON

JUNE 17, 2020

VERIFIED COMPLAINT

Plaintiff Yatra Online, Inc. (“Yatra”), by and through its undersigned counsel,

brings this verified complaint (the “Complaint”) against defendants Ebix, Inc.

(“Parent”) and EbixCash Travels, Inc. (“Merger Sub” and, together with Parent,

“Ebix”) in connection with Ebix’s serial breaches of a merger agreement dated July

16, 2019 (the “Merger Agreement”) and a related merger extension agreement (the

“Extension Agreement”). Except for facts specifically pertaining to Yatra and its

own acts, the allegations in the Complaint are based upon information and belief,

which includes but is not limited to: (a) Ebix’s and Ebix’s representatives’

communications with Yatra and Yatra’s representatives; (b) Ebix’s public filings

with the United States Securities and Exchange Commission (the “SEC”); (c)

Yatra’s communications with the SEC regarding pertinent matters; (d) other publicly

available data; and (e) investigation by Yatra’s corporate and litigation counsel.

EFiled: Jun 17 2020 02:11PM EDT Transaction ID 65706550

Case No. 2020-0444-JRS