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<br />The settling defendants are GEO Specialty Chemicals, Inc., Kenneth A. Ghazey and Brian C. Steppig (collectively referred
<br />to herein as the "GEO Settling Parties").
<br />In a class action, one or more individuals or entities, called "class representatives," sue on behalf of others who have simi-
<br />lar claims. The class representatives in this case are Central Arkansas Water; City of Charlotte, North Carolina; City and
<br />County of Denver, Colorado, acting by and through its board of Water Commissioners; Flambeau River Papers, LLC; City
<br />of Greensboro, North Carolina; Mobile Area Water and Sewer System; City of Rochester, Minnesota; City of Sacramento,
<br />California; SUEZ Water Environmental Services Inc.; SUEZ Water New Jersey Inc.; SUEZ Water Princeton Meadows
<br />Inc.; SUEZ Water New York Inc.; SUEZ Water Pennsylvania Inc.; and City of Texarkana, Arkansas and City of Texarkana,
<br />Texas, d/b/a Texarkana Water Utilities (collectively referred to herein as "Direct Purchaser Class Plaintiffs"). The Direct
<br />Purchaser Class Plaintiffs and the individuals or. entities with similar claims are individually "class members," together
<br />comprising a class. One court resolves the issues for all class members, except for those who exclude themselves from the
<br />class.
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<br />The GEO Settling Parties have denied all liability and wrongdoing in this case and have asserted various defenses to the
<br />Direct Purchaser Class Plaintiffs' claims. The Court did not decide in favor of the Direct Purchaser Class Plaintiffs or the
<br />GEO Settling Parties. Instead, both sides agreed to the Settlement. That way, they avoid the cost and risk of a trial, and the
<br />Direct Purchaser Settlement Class Members affected will get compensation.
<br />This Settlement is the product of extensive negotiations between lawyers for the Direct Purchaser Class Plaintiffs and the
<br />GEO Settling Parties. The Direct Purchaser Class Plaintiffs and Interim DPP Lead Counsel think the Settlement is fair and
<br />in the best interests of all Direct Purchaser Settlement Class Members.
<br />WHO Is AFFECTED BY THE SETTLEMENT
<br />To see if you are affected by the Settlement, you first have to determine if you are a
<br />Direct Purchaser Settlement Class Member.
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<br />The Court has provisionally certified, for purposes of effectuating the Settlement only, a class consisting of. all persons
<br />or entities that purchased Alum in the United States directly from a Defendant from January 1, 1997 through
<br />February 28, 2011. Generally, you are included in the Direct Purchaser Settlement Class if you purchased Alum directly
<br />from a Defendant during this period.
<br />Excluded from the Direct Purchaser Settlement Class are (1) Defendants and their respective parents, subsidiaries, and
<br />affiliates, and (2) any Direct Purchaser Settlement Class Members who timely and validly elect to be excluded from the
<br />Direct Purchaser Settlement Class.
<br />Pon r��cy a'aY."i £ N �t� C -
<br />1A MTWAR
<br />MEN WIN
<br />If you are still not sure if you are a Direct Purchaser Settlement Class Member, you can get more information by visiting
<br />www.LiquidAluminumDirectSettlement com, or you can get free help by calling or writing Interim DPP Lead Counsel,
<br />at the phone number and address listed in Question 23 below. You may also contact the Settlement Administrator, by calling
<br />1-855-338-6128, by emailing info@LiquidAluminumDirectSettlement.com, or writing to Liquid Aluminum Sulfate
<br />Antitrust Litigation — GEO Direct Purchaser Settlement, c/o Settlement Administrator, P.O. Box 30097, Philadelphia,
<br />PA 19103.
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