NOTICE OF CLASS ACTION SETTLEMENT

UNITED STATES DISTRICT COURT

[________________________________] DISTRICT OF [________________________________]

Case No.: [________________________________]

NOTICE OF PROPOSED CLASS ACTION SETTLEMENT

IF YOU [________________________________], YOU MAY BE ENTITLED TO BENEFITS FROM A CLASS ACTION SETTLEMENT.

A COURT AUTHORIZED THIS NOTICE. THIS IS NOT A SOLICITATION FROM A LAWYER.

PLEASE READ THIS NOTICE CAREFULLY. YOUR LEGAL RIGHTS ARE AFFECTED WHETHER YOU ACT OR DO NOT ACT.

SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

WHAT THIS NOTICE CONTAINS

1. Why Did I Get This Notice?
2. What Is This Lawsuit About?
3. Why Is This A Class Action?
4. Why Is There A Settlement?
5. How Do I Know If I Am Part of the Settlement?
6. What Does the Settlement Provide?
7. How Do I Submit A Claim?
8. What Am I Giving Up If I Stay In The Settlement Class?
9. How Do I Exclude Myself From The Settlement?
10. How Do I Object To The Settlement?
11. When And Where Is The Court Hearing?
12. Who Represents The Class?
13. How Will The Lawyers Be Paid?
14. How Do I Get More Information?

1. WHY DID I GET THIS NOTICE?

You received this Notice because records indicate that you may have [________________________________] during the period from [__/__/____] to [__/__/____].

This Notice explains:
- The lawsuit and the Settlement;
- Your legal rights and options;
- What benefits are available;
- Who is eligible; and
- How to get a payment or exclude yourself.

The Court overseeing this case is the United States District Court for the [________________________________] District of [________________________________]. The lawsuit is known as [________________________________] v. [________________________________], Case No. [________________________________].

The people who sued are called "Plaintiffs" or "Class Representatives." The company they sued, [________________________________], is called "Defendant."

2. WHAT IS THIS LAWSUIT ABOUT?

The lawsuit claims that Defendant [________________________________].

Specifically, Plaintiffs allege that:

☐ [________________________________]
☐ [________________________________]
☐ [________________________________]

Defendant denies all of the claims in the lawsuit and maintains that it did nothing wrong. The Court has not decided who is right.

3. WHY IS THIS A CLASS ACTION?

In a class action, one or more people called "Class Representatives" sue on behalf of themselves and other people who have similar claims. Together, all of these people are the "Class" or "Class Members."

A class action resolves the issues for all Class Members at once, except for those who exclude themselves from the Class.

4. WHY IS THERE A SETTLEMENT?

The Court has not decided in favor of either side. Instead, both sides agreed to a settlement. By agreeing to settle, both sides avoid the costs and risks of a trial, and Class Members who submit valid claims will receive compensation.

The Class Representatives and their attorneys believe the Settlement is in the best interests of the Class.

5. HOW DO I KNOW IF I AM PART OF THE SETTLEMENT?

You are a member of the Settlement Class if you meet the following definition:

Settlement Class: All persons in the United States who [________________________________] during the period from [__/__/____] to [__/__/____] (the "Class Period").

Excluded from the Settlement Class are:
- Defendant, its officers, directors, employees, agents, and legal representatives;
- Any judge assigned to this case and their immediate family members;
- Persons who timely and validly request exclusion from the Settlement Class;
- [________________________________]

If you are not sure whether you are included in the Settlement Class, you may call [________________________________] or visit [________________________________] for more information.

6. WHAT DOES THE SETTLEMENT PROVIDE?

A. Monetary Benefits

Defendant has agreed to pay $[________________________________] to create a Settlement Fund.

After deducting Court-approved attorneys' fees, litigation costs, service awards to the Class Representatives, and notice and administration costs, the remaining amount (the "Net Settlement Fund") will be distributed to Class Members who submit valid Claim Forms.

Estimated Payment Per Class Member: Each Class Member who submits a valid Claim Form is estimated to receive approximately $[________________________________].

Note: The actual payment amount may vary depending on the number of valid claims submitted.

[OR]

Tiered Benefits:
- Class Members who [________________________________]: Up to $[________________________________]
- Class Members who [________________________________]: Up to $[________________________________]
- Class Members who [________________________________]: Up to $[________________________________]

B. Non-Monetary Benefits

In addition to monetary payments, Defendant has agreed to:

☐ [________________________________]
☐ [________________________________]
☐ [________________________________]

7. HOW DO I SUBMIT A CLAIM?

To receive a payment from the Settlement, you must submit a Claim Form.

Online:

You may submit a Claim Form online at: [________________________________]

By Mail:

You may download a Claim Form from the website above or request one by calling [________________________________]. Complete the form and mail it to:

[________________________________] Settlement Administrator
[________________________________]
[________________________________]
[________________________________]

Deadline:

Your Claim Form must be submitted online or postmarked by [__/__/____].

What You Need to Submit:

☐ Completed Claim Form with your name and contact information
☐ Proof that you are a Class Member, such as [________________________________]
☐ Your signature under penalty of perjury
☐ [________________________________]

8. WHAT AM I GIVING UP IF I STAY IN THE SETTLEMENT CLASS?

Unless you exclude yourself, you will remain a member of the Settlement Class. If the Settlement is approved and becomes final, you will be bound by its terms and will give up your right to sue Defendant for the claims covered by the Settlement.

The specific claims you are releasing are described in the Settlement Agreement, which is available at [________________________________].

9. HOW DO I EXCLUDE MYSELF FROM THE SETTLEMENT?

If you do not want to be part of the Settlement and want to keep your right to sue Defendant on your own, you must exclude yourself.

To exclude yourself:

Send a letter to the Settlement Administrator that includes:
1. Your name, address, telephone number, and signature;
2. The name of this case: [________________________________] v. [________________________________], Case No. [________________________________];
3. A statement that you want to be excluded from the Settlement Class;
4. [________________________________]

Mail your exclusion request to:

[________________________________] Settlement Administrator
[________________________________]
[________________________________]
[________________________________]

Deadline:

Your exclusion request must be postmarked by [__/__/____].

Effect of Exclusion:

If you exclude yourself:
- You will NOT receive any payment from this Settlement;
- You will NOT be bound by any judgment in this case;
- You will keep your right to sue Defendant on your own about the claims in this case.

10. HOW DO I OBJECT TO THE SETTLEMENT?

If you are a Class Member and do not exclude yourself, you may object to the Settlement if you do not think it is fair, reasonable, or adequate.

To object:

You must file a written objection with the Court AND mail a copy to Class Counsel and Defendant's Counsel.

Your objection must include:
1. Your name, address, telephone number, and signature;
2. The name of this case: [________________________________] v. [________________________________], Case No. [________________________________];
3. A statement that you are a member of the Settlement Class;
4. A detailed statement of your specific objections and the reasons for them;
5. Any supporting documents or legal authority;
6. Whether you intend to appear at the Final Approval Hearing, and if so, a list of any witnesses you may call and any exhibits you may introduce;
7. If you are represented by an attorney, your attorney's name, address, telephone number, and signature;
8. A list of all other class action cases in which you or your attorney have filed objections in the past five years;
9. [________________________________]

File With the Court:

Clerk of the Court
United States District Court for the [________________________________] District of [________________________________]
[________________________________]
[________________________________]

Mail Copies To:

Class Counsel:
[________________________________]
[________________________________]
[________________________________]

Defendant's Counsel:
[________________________________]
[________________________________]
[________________________________]

Deadline:

Your objection must be filed with the Court and mailed to counsel by [__/__/____].

11. WHEN AND WHERE IS THE COURT HEARING?

The Court will hold a Final Approval Hearing to decide whether to approve the Settlement as fair, reasonable, and adequate.

Date: [__/__/____]
Time: [____] a.m./p.m.
Location: [________________________________]
[________________________________]
Courtroom [____]

At the hearing, the Court will also consider Class Counsel's request for attorneys' fees and costs, and the request for service awards to the Class Representatives.

You are not required to attend the hearing. Class Counsel will represent the Class at the hearing. However, you may attend at your own expense. If you filed an objection, you may ask to speak at the hearing by indicating in your objection that you intend to appear.

Note: The date and time of the hearing may change. Check the settlement website at [________________________________] for updates.

12. WHO REPRESENTS THE CLASS?

The Court has appointed the following attorneys to represent the Class ("Class Counsel"):

[________________________________]
[________________________________]
[________________________________]
[________________________________]
Telephone: [________________________________]
Email: [________________________________]

You do not need to hire your own lawyer because Class Counsel is working on your behalf. However, if you want your own lawyer, you may hire one at your own expense.

13. HOW WILL THE LAWYERS BE PAID?

Class Counsel will ask the Court to approve payment of attorneys' fees up to $[________________________________] [or up to [____]% of the Settlement Fund], plus reimbursement of litigation costs up to $[________________________________].

Class Counsel will also ask the Court to approve service awards of $[________________________________] to each Class Representative for their service on behalf of the Class.

The Court will decide the amounts to award. These amounts will be paid from the Settlement Fund before distribution to Class Members.

14. HOW DO I GET MORE INFORMATION?

This Notice is a summary. For more information:

Visit the Settlement Website:

[________________________________]

Call the Settlement Administrator:

[________________________________] (Toll-Free)
Available [____] a.m. to [____] p.m. [Time Zone], Monday through Friday

Write to the Settlement Administrator:

[________________________________] Settlement Administrator
[________________________________]
[________________________________]

Review Court Documents:

You may examine the Settlement Agreement, pleadings, and other records in this case at the Office of the Clerk of the Court:

Clerk of the Court
United States District Court for the [________________________________] District of [________________________________]
[________________________________]
[________________________________]

IMPORTANT DATES TO REMEMBER

DO NOT CALL OR WRITE THE COURT OR THE CLERK'S OFFICE FOR INFORMATION ABOUT THIS SETTLEMENT.

DATED: [__/__/____]

BY ORDER OF THE COURT
UNITED STATES DISTRICT COURT
[________________________________] DISTRICT OF [________________________________]

This Notice was authorized by the United States District Court for the [________________________________] District of [________________________________]. This is not a solicitation from a lawyer.