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SUMMARY OF THE SETTLEMENT
<br />This is a partial settlement. Pursuant to the Settlement, GEO, on behalf of itself and the GEO Settling Parties, has agreed to
<br />pay (i) a total of $10,796,800 in cash; and (ii) up to $13,527,400 from a Sale, EBITDA -based payments, and/or shareholder
<br />dividends. The foregoing amounts and any accrued interest are. referred to herein as the Settlement Funds. Additionally,
<br />the GEO Settling Parties have agreed to provide certain cooperation measures in the ongoing litigation against the Non -
<br />Settling Defendants.
<br />The net amount of the Settlement Funds, after payment of any taxes, administration expenses, and Court -approved
<br />attorneys' fees, expenses and Case Contribution Awards, will be allocated to Direct Purchase Settlement Class Members,
<br />pro rata, according to a plan of distribution, approval of which will simultaneously be sought from the Court as part of
<br />the Settlement.
<br />As with any litigated case, Direct Purchaser Class Plaintiffs would face an uncertain outcome against the GEO Settling
<br />Parties if this lawsuit were to continue against them. Throughout this case, Direct Purchaser Class Plaintiffs and the GEO
<br />Settling Parties have disagreed on both liability and damages, and they do not agree on the amount that would be recov-
<br />erable even if Direct Purchaser Class Plaintiffs were to prevail at trial. Moreover, continued litigation could result in a
<br />judgment or verdict against the GEO Settling Parties in an amount less than the recovery obtained by the Settlement, or no
<br />recovery at all. The GEO Settling Parties have denied and continue to deny the claims and contentions alleged by Direct
<br />Purchaser Class Plaintiffs, that they are liable at all to the Direct Purchaser Settlement Class, or that the Direct Purchaser
<br />Settlement Class suffered any damages for which the GEO Settling Parties could be legally responsible. Nevertheless, the
<br />GEO Settling Parties have taken into account the uncertainty and risks inherent in any litigation, particularly in a complex
<br />case such as this, and have concluded that it is desirable that the lawsuit be fully and finally settled as to the GEO Settling
<br />Parties on the terms and conditions set forth in the Settlement Agreement.
<br />BASIC INFORMATION
<br />You received this Notice because it is believed that you or your company purchased Alum in the United States directly
<br />from a Defendant from January 1, 1997 through February 28, 2011, and therefore, you may be a member of the Direct
<br />Purchaser Settlement Class.
<br />The Court has directed that this Notice be sent to you because, as a potential member of the Direct Purchasdr Settlement
<br />Class, you have the right to know about the Settlement reached in this Action between the Direct Purchaser Class Plaintiffs,
<br />on behalf of the Direct Purchaser Settlement Class, and the GEO Settling Parties, and about all of your options before the
<br />Court decides whether to approve the Settlement. This Notice explains the lawsuit, the Settlement, and your legal rights.
<br />The Court in charge of this Action is the United States District Court for the District of New Jersey. The case is called In
<br />Re. Liquid Aluminum Sulfate Antitrust Litigation, Civil Action No. 16-md-2687 (JLL) (JAD). United States District Court
<br />Judge Jose L. Linares is overseeing this Action. The entities who brought this case are the plaintiffs, and the companies
<br />and individuals they sued are called defendants.
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<br />The Direct Purchaser Class Plaintiffs claim that the GEO Settling Parties participated in a conspiracy — with other Defen-
<br />dants in the Action and unnamed co-conspirators — to allocate territories and/or not to compete for each other's historical
<br />business by rigging bids, allocating customers and fixing, stabilizing, and maintaining the price of Alum sold in the United
<br />States from January 1, 1997 to at least February 28, 2011 in violation of the federal antitrust laws. The Direct Purchaser
<br />Class Plaintiffs allege that the claimed anticompetitive conduct resulted in artificially inflated prices for Alum. The GEO
<br />Settling Parties deny all of these claims and have asserted various defenses to the claims. The Court has not made any
<br />decision as to the merits of Direct Purchaser Class Plaintiffs' allegations.
<br />Please Note: The Settlement is a partial settlement of the Action. The Settlement does not release any claims of the Direct
<br />Purchaser Class Plaintiffs and the other members of the Direct Purchaser Settlement Class against any other Defendant in
<br />the Action and litigation against those Defendants is ongoing.
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