Notice

NOTICE

Notice to the Class of the proposed Settlement is being provided in two forms – Mailed Notice and Publication Notice – in order to inform all Class members of their rights under the terms of the Settlement.

The Mailed Notice explains the case history; the Settlement reached; the plan of allocation; the procedure for obtaining final approval; and procedures for objecting to or commenting on the proposed settlement and/or the requested attorneys’ fee and class representative service awards once they are submitted.

The Mailed Notice, which was issued by the Notice Administrator on November 29, 2022, explains the case history; the Settlement reached; the plan of allocation; the procedure for obtaining final approval; and procedures for objecting to or commenting on the proposed settlement and/or Class Counsel’s request for litigation and settlement administration expenses, attorneys’ fee and service awards for the named Plaintiffs once they are submitted.

Each Mailed Notice is personal to the recipient and contains a specific estimate of the individual Class member’s Settlement Benefit based on the assumption that the Court grants
Class Counsel’s request for litigation and settlement administration expenses, attorneys’ fees and service awards for the named Plaintiffs in full and in accordance with the limitations set forth in the Agreement. The Mailed Notice informs Class members that should the deductions that the Court ultimately awards be less than the maximums, their resulting net benefit would be proportionately higher than estimated. Id. In that context, the Mailed Notice reminds Class members of their rights to object.

The Publication Notice was published in USA Today on November 21, 2022 and also discusses the case history, the proposed settlements, the procedure for obtaining final approval and procedures for objecting to or commenting on the settlements and/or Class Counsel’s request for litigation and settlement administration expenses, attorneys’ fees and service awards for the named Plaintiffs once they are submitted.