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UNITED STATES DISTRICT COURT
<br />DISTRICT OF NEW JERSEY
<br />Civil Action No. 16-md-2687 (JLL) (JAD)
<br />In Re: LIQUID ALUMINUM SULFATE
<br />ANTITRUST LITIGATION
<br />If You Purchased Liquid Aluminum Sulfate In The United States Directly From
<br />A Defendant From January 1, 1997 Through February 28, 2011,
<br />You Could Be Affected By A Proposed Class Action Settlement
<br />A federal court authorized this Notice. This is not a solicitation from a lawyer You are not being sued.
<br />This notice ("Notice") .is being sent to you pursuant to Rule 23 of the Federal Rules of Civil Procedure and an
<br />Order of the United States District Court for the District of New Jersey ("Court"). The purpose of this Notice is to
<br />advise you of the pendency of the class action lawsuit called In. Re: Liquid Aluminum Sulfate Antitrust Litigation
<br />("Action") and the proposed partial settlement ("Settlement") reached in the Action between Direct Purchaser
<br />Class Plaintiffs' and settling defendants GEO Specialty Chemicals, Inc. ("GEO"), Kenneth A. Ghazey and Brian
<br />C. Steppig (collectively, the "GEO Settling Parties")? The Court preliminarily approved the Settlement on July 19,
<br />2018. Please Note: The Settlement does not release any claims of Direct Purchaser Class Plaintiffs and the
<br />other members of the Direct Purchaser Settlement Class (as defined below) against any other Defendant in
<br />the Action and litigation against those Defendants is ongoing.'
<br />Pursuant to the Settlement, GEO, on behalf of itself and the GEO Settling Parties, has agreed to: (i) pay a total of
<br />$10,796,800 in cash; (ii) pay up to $13,527,400 from a sale of all or substantially all of GEO's equity interests,
<br />a merger of GEO and another entity, or a sale of all or substantially all of CEO's assets (collectively, a "Sale"),
<br />EBITDA -based payments, and/or shareholder dividends; and (iii) provide certain cooperation measures in the
<br />ongoing litigation of the Action against the Non -Settling Defendants. The GEO Settling Parties deny all of Direct
<br />Purchaser Class Plaintiffs' claims and deny all wrongdoing, but have agreed to settle in order to avoid the cost and
<br />risk of a trial.
<br />This, lawsuit involves liquid aluminum sulfate or "Alum." Alum is a chemical utilized by municipalities and
<br />industries for a variety of uses including, inter alfa, treating drinking water, controlling algae in lakes and ponds,
<br />treating wastewater, manufacturing paper and pulp and fixing dyes to textiles. The Direct Purchaser Class Plaintiffs
<br />allege that the GEO Settling Parties participated in a conspiracy — with other Defendants in the Action and unnamed
<br />co-conspirators — to allocate territories and/or to not compete for each other's historical business by rigging bids,
<br />allocating customers and fixing, stabilizing, and maintaining the price of Alum sold in the United States from
<br />January 1, 1997 to at least February 28, 2011 in violation of the federal antitrust laws. The GEO Settling Parties
<br />deny all of these claims and have asserted various defenses to the claims. The Court has not made any decision as
<br />tothe merits of Direct Purchaser Class Plaintiffs' claims against the GEO Settling Parties because the Parties have
<br />agreed to settle these claims.
<br />' Direct Purchaser Class Plaintiffs are Central Arkansas Water; City of Charlotte, North Carolina; City and County of Denver, Colorado, acting by and
<br />through its board of Water Commissioners; Flambeau River Papers, LLC; City of Greensboro, North Carolina; Mobile Area Water and Sewer System; City
<br />of Rochester, Minnesota; City of Sacramento, California; SUEZ Water Environmental Services Inc.; SUEZ Water New Jersey Inc.; SUEZ Water Princeton
<br />Meadows Inc.; SUEZ Water New York Inc.; SUEZ Water Pennsylvania Inc.; and City of Texarkana, Arkansas and City of Texarkana, Texas, d/b/a Texarkana
<br />Water Utilities.
<br />z The full terms of the Settlement are set forth in Settlement Agreement Between Direct Purchaser Class Plaintiffs and Defendants GEO Specialty
<br />Chemicals, Inc., Kenneth A. Ghazey and Brian C. Steppig dated June 1, 2018 (the "Settlement Agreement'), a copy of which can be viewed on the
<br />Settlement website, www.LiduiidAluminumDirectSettlement.com. All capitalized terms used herein and not otherwise defined herein have the meanings set
<br />forth in the Settlement Agreement. In the event of any conflicts between the terms of this Notice and the Settlement Agreement, the Settlement Agreement
<br />shall control.
<br />Defendants are General Chemical Corporation, General Chemical Performance Products, LLC, General Chemical LLC, GenTek Inc., Chemtrade
<br />Logistics Income Fund, Chemtrade Logistics Inc., Chemtrade Chemicals Corporation, Chemtrade Chemicals US, LLC, Chemtrade. Solutions, LLC, C&S
<br />Chemicals, Inc., GEO Specialty Chemicals, Inc., USALCO, LLC, Kemira Chemicals, Inc., Southern Ionics, Inc., American Securities LLC, Frank A.
<br />Reichl, Brian C. Steppig, Vincent J. Opalewski, Alex Avraamides, Amita Gupta, Kenneth A. Ghazey, Milton Sundbeck, Matthew LeBaron and Scott Wolff.
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