X0306 4 2019-11-05 0 0001305323 Zovio Inc ZVO 0001453872 Clark Andrew S. 1811 E. NORTHROP BLVD. CHANDLER AZ 85286 1 1 0 0 Chief Executive Officer Common Stock 2019-11-05 4 P 0 150000 2.5767 A 383041 D Common Stock 513444 I By trust Represents the weighted average share price of an aggregate total of 150,000 shares purchased in the price range of $2.34 to $2.68 by the reporting person. The reporting person undertakes to provide upon request by the Commission staff, the issuer or a security holder of the issuer, full information regarding the number of shares purchased at each separate price. Shares held indirectly by the reporting person in the name of the Clark Family Trust, dated July 8, 1998, of which the reporting person is a trustee and in which the reporting person has a pecuniary interest. /s/ Diane L. Thompson, as Attorney-in-Fact 2019-11-06