2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 1 of 17 Pg ID 23189
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`Updated Settlement Notice
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`If You Bought or Leased a New Motor Vehicle, or Bought Certain
`Replacement Parts for a Motor Vehicle in the U.S. Since 1998
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`You Could Get Money from Settlements Totaling Approximately $225 Million
`
`A Federal Court authorized this Notice. This is not a solicitation from a lawyer.
`
`• Please read this Notice and the Settlement Agreements available at www.AutoPartsClass.com carefully. Your legal
`rights may be affected whether you act or don’t act. This Notice is a summary, and it is not intended to, and does not,
`include all of the specific details of each Settlement Agreement. To obtain more specific details concerning the
`Settlements, please read the Settlement Agreements.
`• Separate lawsuits claiming that Defendants in each lawsuit entered into unlawful agreements that artificially raised
`the prices of certain motor vehicle component parts have been settled with 11 defendants and their affiliates (“Settling
`Defendants”).
`• Generally, you are included if, at any time between 1998 and 2015, depending upon the component part, you: (1)
`bought or leased a new motor vehicle in the U.S. (not for resale), or (2) indirectly paid for a motor vehicle
`replacement part (not for resale). Indirectly means you bought the vehicle replacement part from someone other than
`the manufacturer of the part.
`• As more fully described in Question 7 below, the Settling Defendants have agreed to pay approximately $225 million
`to be made available to Settlement Class members who purchased or leased a new motor vehicle or purchased a
`motor vehicle replacement part in the District of Columbia and one or more of the following States: Arizona,
`Arkansas, California, Florida, Hawaii, Iowa, Kansas, Maine, Massachusetts, Michigan, Minnesota, Mississippi,
`Missouri, Montana, Nebraska, Nevada, New Hampshire, New Mexico, New York, North Carolina, North Dakota,
`Oregon, Rhode Island, South Carolina, South Dakota, Tennessee, Utah, Vermont, West Virginia, and Wisconsin.
`• The Settlements also include provisions requiring Settling Defendants’ cooperation in the ongoing litigations.
`Certain Settling Defendants have also agreed not to engage in the specified conduct that is the subject of the lawsuits
`for a period of two years from the date of entry of the final judgment.
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`EXCLUDE
`YOURSELF
`
`DO NOTHING
`NOW
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`OBJECT TO THE
`SETTLEMENTS
`GO TO THE
`HEARING
`REGISTER ON
`THE WEBSITE
`
`Your Legal Rights And Options
`You will not be included in the Settlements from which you exclude yourself.
`You will receive no benefits from those Settlements, but you will keep any
`rights you currently have to sue the Settling Defendants about the claims in the
`case(s) from which you exclude yourself.
`You will be included in the Settlements and eligible to file a claim for a
`payment (if you qualify) at a later date. You will give up your rights to sue the
`Settling Defendants about the claims in these cases.
`If you do not exclude yourself, you can write to the Court explaining why you
`disagree with the Settlements.
`Ask to speak in Court about your opinion of the Settlements.
`
`The best way to receive notice about filing a claim and updates about the
`lawsuits.
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`April 11,
`2016
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`April 11,
`2016
`May 11,
`2016
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`• These rights and options – and the deadlines to exercise them – are explained in this Notice.
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`• The Court in charge of these cases still has to decide whether to finally approve the Settlements. Payments will only
`be made (1) if the Court approves the Settlements and after any appeals are resolved, and (2) after the Court approves
`a Plan of Allocation to distribute the Settlement Funds minus expenses, any court-approved attorneys’ fees, and
`incentive awards (“Net Settlement Funds”) to Settlement Class members. A Plan of Allocation will be proposed at
`the conclusion of the cases against the Non-Settling Defendants or as ordered by the Court. The Plan will be
`described in a future Notice to be given at a later date, providing Settlement Class members with an opportunity to
`state their views regarding the Plan of Allocation.
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`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 2 of 17 Pg ID 23190
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`What This Notice Contains
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`BASIC INFORMATION .......................................................................................................................................... 4
`1. WHY IS THERE A NOTICE? ............................................................................................................................... 4
`2. WHAT ARE THESE LAWSUITS ABOUT? ............................................................................................................. 4
`3. WHO ARE THE SETTLING DEFENDANTS? ......................................................................................................... 4
`4. WHO ARE THE NON-SETTLING DEFENDANTS? ................................................................................................ 4
`5. WHAT MOTOR VEHICLE PARTS ARE INCLUDED? ............................................................................................ 5
`6. WHY ARE THESE CLASS ACTIONS? ................................................................................................................... 6
`WHO IS INCLUDED IN THE CLASSES .................................................................................................................. 6
`7. HOW DO I KNOW IF I MAY BE INCLUDED IN THE CLASSES? ............................................................................. 6
`8. WHO IS NOT INCLUDED IN THE CLASSES? ........................................................................................................ 8
`9. WHY ARE THE LAWSUITS CONTINUING IF THERE ARE SETTLEMENTS? ............................................................ 9
`THE SETTLEMENTS’ BENEFITS .......................................................................................................................... 9
`10. WHAT DO THE SETTLEMENTS PROVIDE? ....................................................................................................... 9
`HOW TO GET BENEFITS ................................................................................................................................... 10
`11. HOW MUCH MONEY CAN I GET? ................................................................................................................... 10
`12. WHEN WILL I GET A PAYMENT? ................................................................................................................... 10
`13. WHAT IS THE NON-MONETARY RELIEF? ....................................................................................................... 11
`REMAINING IN THE CLASSES ........................................................................................................................... 11
`14. WHAT HAPPENS IF I REMAIN IN THE CLASSES? ........................................................................................... 11
`EXCLUDING YOURSELF FROM THE CLASSES ................................................................................................. 11
`15. HOW DO I GET OUT OF THE CLASSES? ......................................................................................................... 11
`16. IF I DON’T EXCLUDE MYSELF, CAN I SUE FOR THE SAME THING LATER? ..................................................... 12
`17. IF I EXCLUDE MYSELF, CAN I STILL GET MONEY BENEFITS? ........................................................................ 12
`THE LAWYERS REPRESENTING YOU ............................................................................................................... 12
`18. DO I HAVE A LAWYER REPRESENTING ME? .................................................................................................. 12
`19. HOW WILL THE LAWYERS BE PAID? ............................................................................................................. 12
`OBJECTING TO THE SETTLEMENTS ................................................................................................................ 13
`20. HOW DO I OBJECT TO OR COMMENT ON THE SETTLEMENTS? ...................................................................... 13
`21. WHAT IS THE DIFFERENCE BETWEEN EXCLUDING MYSELF FROM THE CLASSES AND
`OBJECTING TO THE SETTLEMENTS? ............................................................................................................. 13
`THE FINAL FAIRNESS HEARING ....................................................................................................................... 14
`22. WHEN AND WHERE WILL THE COURT DECIDE WHETHER TO APPROVE THE SETTLEMENTS? ....................... 14
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`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 3 of 17 Pg ID 23191
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`23. DO I HAVE TO ATTEND THE HEARING? ........................................................................................................ 14
`24. MAY I SPEAK AT THE HEARING? .................................................................................................................. 14
`THE TRIALS ....................................................................................................................................................... 14
`25. WHEN AND WHERE WILL THE TRIALS AGAINST THE NON-SETTLING DEFENDANTS TAKE
`PLACE? ......................................................................................................................................................... 14
`26. WHAT ARE THE PLAINTIFFS ASKING FOR FROM THE NON-SETTLING DEFENDANTS? .................................. 14
`27. WILL I GET MONEY AFTER THE TRIALS? ...................................................................................................... 15
`GET MORE INFORMATION ............................................................................................................................... 15
`28. HOW DO I GET MORE INFORMATION? .......................................................................................................... 15
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`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 4 of 17 Pg ID 23192
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`1 . WHY IS THERE A NOTICE?
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`BASIC INFORMATION
`
`This Notice is to inform you about the partial Settlements reached in 19 of the pending cases that are
`included in this litigation, before the Court decides whether to finally approve the Settlements. This
`Notice explains the lawsuits, the Settlements, and your legal rights.
`
`The Court in charge is the United States District Court for the Eastern District of Michigan. This
`litigation is known as In re Automotive Parts Antitrust Litigation, MDL No. 2311. The people who
`sued are called the “Plaintiffs.” The companies they sued are called the “Defendants.”
`
`2 . WHAT ARE THESE LAWSUITS ABOUT?
`
`The lawsuits claim that the Defendants in each lawsuit agreed to unlawfully raise the price of certain
`motor vehicle component parts. As a result, businesses and consumers who purchased or leased new
`motor vehicles (not for resale) containing those parts or who indirectly purchased replacement parts
`(not for resale) from the Defendants may have paid more than they should have. Although the
`Settling Defendants have agreed to settle, the Settling Defendants do not agree that they engaged in
`any wrongdoing or are liable and owe any money or benefits to Plaintiffs. The Court has not yet
`decided who is right.
`
`3 . WHO ARE THE SETTLING DEFENDANTS?
`
`The Settling Defendants are:
`• Autoliv, Inc.; Autoliv ASP, Inc.; Autoliv B.V. & Co. KG; Autoliv Safety Technology, Inc.;
`and Autoliv Japan Ltd. (collectively, “Autoliv”),
`• Fujikura, Ltd. and Fujikura Automotive America LLC (together, “Fujikura”),
`• Hitachi Automotive Systems, Ltd. (“HIAMS”),
`• Kyungshin-Lear Sales and Engineering, LLC (“KL Sales”),
`• Lear Corporation (“Lear”),
`• Nippon Seiki Co., Ltd.; N.S. International, Ltd.; and New Sabina Industries, Inc.
`(collectively, “Nippon Seiki”),
`• Panasonic Corporation and Panasonic Corporation of North America (together, “Panasonic”),
`• Sumitomo Electric Industries, Ltd.; Sumitomo Wiring Systems, Ltd.; Sumitomo Electric
`Wiring Systems, Inc. (incorporating K&S Wiring Systems, Inc.); and Sumitomo Wiring
`Systems (U.S.A.) Inc. (collectively, “Sumitomo”),
`• T.RAD Co., Ltd. and T.RAD North America, Inc. (together, “T.RAD”),
`• TRW Deutschland Holding GmbH and TRW Automotive Holdings Corporation (now known
`as “ZF TRW Automotive Holdings Corp.”) (together, “TRW”), and
`• Yazaki Corporation and Yazaki North America, Incorporated (together, “Yazaki”).
`
`4 . WHO ARE THE NON- SETTLING DEFENDANTS?
`
`A list of all of the Defendants and the parts they manufactured and sold is available at
`www.AutoPartsClass.com.
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`
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`
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`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 5 of 17 Pg ID 23193
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`5 . WHAT MOTOR VEHICLE PARTS ARE INCLUDED?
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`The Settlements involve the following motor vehicle component parts:
`
`
`
`Air Flow Meters are used to measure the volume of air flowing into motor vehicle engines.
`
`Alternators are electromechanical devices that generate an electric current while motor vehicle engines
`are in operation.
`
`ATF Warmers are automatic transmission fluid warmer or cooler devices located in the engine
`compartment of a vehicle that moderate the temperature of the automatic transmission fluid.
`
`Automotive Wire Harness Systems are the electrical distribution systems used to direct and control
`electronic components, wiring, and circuit boards in motor vehicles. Automotive Wire Harness Systems
`include the following parts: automotive wire harnesses, automotive electrical wiring, lead wire
`assemblies, cable bond, automotive wiring connectors, automotive wiring terminals, electronic control
`units, fuse boxes, relay boxes, junction blocks, power distributors, high voltage wiring, and speed sensor
`wire assemblies.
`
`Electronic Throttle Bodies control the amount of air flowing into a motor vehicle’s engine.
`
`Fuel Injection Systems admit fuel or a fuel/air mixture into motor vehicle engine cylinders. Fuel
`Injection Systems can also be sold as part of a broader system, such as an engine management system, or
`as separate components. Fuel Injection Systems include one or more of the following parts: injectors;
`high pressure pumps; rail assemblies; feed lines; engine electronic control units; fuel pumps and fuel
`pump modules; manifold absolute pressure sensors; and pressure regulators, pulsation dampers, and purge
`control valves.
`
`Fuel Senders are devices located inside the fuel tank of motor vehicles that measure the amount of fuel in
`the tank.
`
`Heater Control Panels (“HCPs”) are either mechanical or electrical devices that control the temperature
`of the interior environment of a vehicle. HCPs can be either manual (referred to as low-grade) or
`automatic (referred to as high-grade) and are located in the center console, back seat, or rear cabin of an
`automobile.
`
`High Intensity Discharge (“HID”) Ballasts are electrical devices that limit the amount of electrical
`current flowing to an HID headlamp.
`
`Ignition Coils release electric energy to ignite the fuel/air mixture in cylinders.
`
`Instrument Panel Clusters are the mounted instruments and gauges housed in front of the driver of a
`motor vehicle. Instrument Panel Clusters are also known as meters.
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`Inverters convert direct current electricity to alternating current electricity.
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`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 6 of 17 Pg ID 23194
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`Motor Generators are electric motors used to power electric drive systems that can also capture and
`regenerate energy.
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`Occupant Safety Restraint Systems are comprised of the parts in an automotive vehicle that protect
`drivers and passengers from bodily harm. Occupant Safety Restraint Systems include one or more of the
`following: seat belts, air bags, steering wheels or steering systems, and safety electronic systems.
`
`Radiators are heat exchangers or other devices that help prevent automotive vehicle engines from
`overheating or otherwise regulate the temperature of the engine compartment of a vehicle and the fluids
`passing through it, including all devices physically attached to and sold as part of a radiator (as more fully
`described in the applicable Settlement Agreement).
`
`Starters are small electronic motors used in starting internal combustion engines.
`
`Steering Angle Sensors detect the angle of the vehicle’s direction and send signals to a vehicle computer,
`which in turn controls the vehicle stability during turns. Steering Angle Sensors are installed on the
`steering column of a vehicle and may be connected to part of a combination switch.
`
`Switches include one or more of the following: steering wheel switch (installed in the steering wheel),
`used to control functions within the vehicle; turn switch (installed behind the steering wheel), used to
`signal a left or right turn and control hi/lo beam selection; wiper switch (installed behind the steering
`wheel), used to activate the vehicle’s windshield wipers; combination switch, a combination of the turn
`and wiper switches as one unit, sold together as a pair; and door courtesy switch (installed in the door
`frame), which activates the light inside the vehicle when the door opens.
`
`Valve Timing Control Devices (also called Variable Timing Devices and/or Variable Timing Control
`Devices), control the timing of engine valve operation and include the Variable Timing Control actuator
`or solenoid valve. Some valve timing control devices may also contain an oil control valve.
`
`6 . WHY ARE THESE CLASS ACTIONS?
`
`In class actions, one or more people called the “class representatives” sue on behalf of themselves and
`other people with similar claims in the specific class action. All of these people together are the “Class”
`or “Class members.” In these class actions, there are a total of fifty-five class representatives. In a class
`action, one court may resolve the issues for all Class members, except for those who exclude themselves
`from the class.
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`WHO IS INCLUDED IN THE CLASSES
`
`7 . HOW DO I KNOW IF I MAY BE INCLUDED IN THE CLASSES?
`
`
`
`
`
`Generally, you may be included in one or more Settlements if, at any time from 1998 to 2015, you: (1)
`bought or leased a new motor vehicle in the U.S. (not for resale), or (2) paid to replace one or more of the
`new motor vehicle parts listed in Question 5 above (not for resale). New motor vehicles include, but are
`not limited to, automobiles, cars, light trucks, pickup trucks, crossovers, vans, mini-vans, and sport utility
`vehicles.
`
`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 7 of 17 Pg ID 23195
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`The specific definition of who is included in each Settlement Class is set forth in each Settlement
`Agreement between the Settlement Classes and the Settling Defendants. Each of those Settlement
`Agreements, and the related Complaints, are accessible on the website www.AutoPartsClass.com. Set
`forth below at pages 16 through 17 is a chart, referred to as Addendum A, identifying the pages and
`paragraph numbers of the relevant Settlement Class definitions for each Settlement Agreement and
`Complaint that will permit you to determine whether you are a member of any of the Settlement Classes.
`
`Payments to Class members will only be made: (1) if the Court approves the Settlements and after any
`appeals are resolved, and (2) in accordance with a Plan of Allocation to distribute the Settlement Funds
`minus expenses, court-approved attorneys’ fees, and incentive awards (“Net Settlement Funds”) to Class
`members. A Plan of Allocation will be proposed to the Court for approval at the conclusion of the cases
`against Non-Settling Defendants or as ordered by the Court. The Plan, as approved by the Court, will
`determine the amount, if any, that each Class member will receive. The Plan will be described in a future
`Notice, to be given at a later date, providing Class members with an opportunity to state their views
`regarding the Plan.
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`These cases are proceeding as class actions seeking monetary recovery for consumers and businesses in
`30 states and the District of Columbia, and for nationwide injunctive relief to stop the Defendants’ alleged
`illegal behavior and prevent this behavior from happening in the future (see Question 13).
`
`Purchasers or lessees of new motor vehicles or indirect purchasers of any of the replacement parts listed
`in Question 5 may be members of the Classes entitled to monetary recovery if the purchase or lease
`transaction occurred in the District of Columbia or one or more of the following states during the relevant
`time periods listed below: Arizona, Arkansas, California, Florida, Hawaii, Iowa, Kansas, Maine,
`Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New
`Hampshire, New Mexico, New York, North Carolina, North Dakota, Oregon, Rhode Island, South
`Carolina, South Dakota, Tennessee, Utah, Vermont, West Virginia, and Wisconsin. (The TRW
`Settlement does not include Arkansas or South Carolina and does not provide Settlement Funds for Class
`members in those states.) A separate Settlement Class has been preliminarily approved by the Court for
`each of the cases settled by the Settling Defendants and their affiliates. The time period covered by the
`Settlements for each of the Classes is provided below.
`
`Defendant
`Autoliv
`
`Time Period Starts Time Period Ends
`January 1, 2003
`May 30, 2014
`
`Fujikura
`
`January 1, 1999
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`August 24, 2015
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`Auto Part(s)
`Occupant Safety Restraint
`Systems
`Automotive Wire Harness
`Systems
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`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`2:13-cv-00703-MOB-MKM Doc # 60-2 Filed 01/13/16 Pg 9 of 18 Pg ID 1323
`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 8 of 17 Pg ID 23196
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`Defendant
`HIAMS
`
`Time Period Starts Time Period Ends
`January 1, 2000
`March 26, 2015
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`KL Sales
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`January 1, 2000
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`May 5, 2014
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`Lear
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`January 1, 2000
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`May 5, 2014
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`Nippon Seiki December 1, 2002
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`January 26, 2016
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`Panasonic
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`T.RAD
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`TRW
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`July 1, 1998
`January 1, 2000
`September 1, 2000
`November 1, 2002
`February 1, 2001
`January 1, 2003
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`February 25, 2015
`February 25, 2015
`February 25, 2015
`August 12, 2015
`August 12, 2015
`September 17, 2014
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`Sumitomo
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`January 1, 1999
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`September 15, 2015
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`Yazaki
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`January 1, 1999
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`September 15, 2014
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`Auto Part(s)
`Alternators, Starters, Ignition
`Coils, Motor Generators,
`Inverters, Fuel Injection
`Systems, Valve Timing
`Control Devices, Air Flow
`Meters, and Electronic Throttle
`Bodies
`Automotive Wire Harness
`Systems
`Automotive Wire Harness
`Systems
`Instrument Panel Clusters
`
`HID Ballasts
`Switches
`Steering Angle Sensors
`ATF Warmers
`Radiators
`Occupant Safety Restraint
`Systems
`Automotive Wire Harness
`Systems and Heater Control
`Panels
`Automotive Wire Harness
`Systems, Instrument Panel
`Clusters, and Fuel Senders
`
`The specific definitions of each Settlement Class are available at www.AutoPartsClass.com or can be
`obtained by calling 1-877-940-5043.
`
`8 . WHO IS NOT INCLUDED IN THE CLASSES?
`
`The Classes do not include:
`
`
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`• Any of the Defendants, their parent companies, subsidiaries, and affiliates;
`• Any co-conspirators;
`• Federal government entities and instrumentalities;
`• States and their political subdivisions, agencies, and instrumentalities; and
`• All persons who purchased their motor vehicle parts directly from the Defendants or for resale.
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`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 9 of 17 Pg ID 23197
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`9 . WHY ARE THE LAWSUITS CONTINUING IF THERE ARE SETTLEMENTS?
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`Settlements have been reached with the Settling Defendants (listed in Question 3) as specified in the
`individual Settlement Agreements. The lawsuits will continue against all of the remaining Defendants
`who have not settled (“Non-Settling Defendants”).
`
`Additional money may become available in the future as a result of a trial or future Settlements.
`Alternatively, the litigation may be resolved in favor of the Non-Settling Defendants, and no additional
`money may become available. There is no guarantee as to what will happen.
`
`Please register at the website, www.AutoPartsClass.com, to be notified about the claims process or any
`future Settlements.
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`THE SETTLEMENTS’ BENEFITS
`
`10 . WHAT DO THE SETTLEMENTS PROVIDE?
`
`
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`
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`The Settlement Funds total approximately $225 million. After deduction of attorneys’ fees, notice and
`claims administration costs, and litigation expenses, as approved by the Court, the remaining Settlement
`Funds will be available for distribution to Class members who timely file valid claims.
`
`The Settlements also include non-monetary relief (see Question 13), including cooperation, and they also
`include agreements by certain Settling Defendants not to engage in the conduct that is the subject of the
`lawsuits, as more fully described in the proposed Final Judgments located on the Settlement website
`www.AutoPartsClass.com.
`
`The Settlement Funds are allocated to the motor vehicle cases in question, as follows:
`
`Automotive Parts Case
`Air Flow Meters
`Alternators
`ATF Warmers
`Automotive Wire Harness
`Systems
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`Auto Parts Settlements and Settlement Funds
`Settling Defendant
`Amount Settled
`HIAMS
`$5,047,920
`HIAMS
`$6,216,420
`T.RAD
`$741,000
`Lear
`$3,040,000
`
`Settlement Fund
`$5,047,920
`$6,216,420
`$741,000
`$119,496,220
`
`KL Sales
`Fujikura
`Sumitomo
`Yazaki
`HIAMS
`HIAMS
`Yazaki
`Sumitomo
`
`$228,000
`$7,144,000
`$35,817,220
`$73,267,000
`$6,870,780
`$8,693,640
`$58,000
`$2,182,780
`
`$6,870,780
`$8,693,640
`$58,000
`$2,182,780
`
`Electronic Throttle Bodies
`Fuel Injection Systems
`Fuel Senders
`Heater Control Panels
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`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 10 of 17 Pg ID 23198
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`Auto Parts Settlements and Settlement Funds
`Settling Defendant
`Amount Settled
`Panasonic
`$5,510,596
`HIAMS
`$7,431,660
`Nippon Seiki
`$4,560,000
`Yazaki
`$2,675,000
`HIAMS
`$2,337,000
`HIAMS
`$2,337,000
`TRW
`$5,446,350
`Autoliv
`$19,000,000
`T.RAD
`$6,669,000
`HIAMS
`$3,832,680
`Panasonic
`$6,293,229
`Panasonic
`$5,296,175
`HIAMS
`$3,972,900
`
`Settlement Fund
`$5,510,596
`$7,431,660
`$7,235,000
`
`$2,337,000
`$2,337,000
`$24,446,350
`
`$6,669,000
`$3,832,680
`$6,293,229
`$5,296,175
`$3,972,900
`
`Automotive Parts Case
`HID Ballasts
`Ignition Coils
`Instrument Panel Clusters
`
`Inverters
`Motor Generators
`Occupant Safety Systems
`
`Radiators
`Starters
`Steering Angle Sensors
`Switches
`Valve Timing Control
`Devices
`Total
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`$224,668,350
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`Any interest earned will be added to each of the Settlement Funds. More details about the Settlements are
`set forth in the Settlement Agreements, available at www.AutoPartsClass.com.
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`11 . HOW MUCH MONEY CAN I GET?
`
`HOW TO GET BENEFITS
`
`At this time, it is unknown how much each Class member who submits a valid claim will receive.
`Payments will be based on a number of factors, including at least the number of valid claims filed by all
`Class members and the number of (1) new motor vehicles purchased or leased or (2) replacement parts
`purchased. It’s possible that any money remaining after claims are paid will be distributed to charities,
`governmental entities, or other beneficiaries approved by the Court. No matter how many claims are
`filed, no money will be returned to the Settling Defendants once the Court finally approves the
`Settlements.
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`In order to receive a payment, you will need to file a valid claim form before the claims period ends. The
`claims period has not yet begun. A Notice about the claims process will be provided at a later date as
`ordered by the Court. If you want to be kept updated about the claims process or any future settlements,
`you should register at www.AutoPartsClass.com.
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`12 . WHEN WILL I GET A PAYMENT?
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`No money will be distributed yet. The lawyers for the Plaintiffs will continue to pursue the lawsuits
`against the Non-Settling Defendants. All Settlement Funds that remain after payment of the court-ordered
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`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`2:12-md-02311-MOB-MKM Doc # 1306-2 Filed 04/29/16 Pg 11 of 17 Pg ID 23199
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`attorneys’ fees, incentive awards, costs, and expenses (see Question 10) will be distributed at the
`conclusion of the lawsuits or as ordered by the Court.
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`13 . WHAT IS THE NON- MONETARY RELIEF?
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`Some of the Settling Defendants have agreed not to engage in certain specified conduct that would violate
`the antitrust laws that are at issue in these lawsuits for a period of two years. Additionally, all of the
`Settling Defendants will cooperate with the Plaintiffs in their ongoing litigation against the Non-Settling
`Defendants.
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`REMAINING IN THE CLASSES
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`14 . WHAT HAPPENS IF I REMAIN IN THE CLASSES?
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`You will give up your right to sue the Settling Defendants on your own for the claims described in the
`Settlement Agreements unless you exclude yourself from one or more of the Classes. You also will be
`bound by any decisions by the Court relating to the Settlements.
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`In return for paying the Settlement amounts and providing the non-monetary benefits, the Settling
`Defendants (and certain related entities defined in the Settlement Agreements) will be released from
`claims relating to the alleged conduct involving the vehicle parts identified in the settlement agreements.
`The settlement agreements describe the released claims in detail, so read them carefully since those
`releases will be binding on you if the Court approves the Settlements. If you have any questions, you can
`talk to Class Counsel listed in Question 18 for free, or you can, of course, talk to your own lawyer (at
`your own expense) if you have questions about what this means. The Settlement Agreements and the
`specific releases are available at www.AutoPartsClass.com.
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`EXCLUDING YOURSELF FROM THE CLASSES
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`15 . HOW DO I GET OUT OF THE CLASSES?
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`To exclude yourself from one or more of the Classes, you must send a letter by mail stating that you want
`to be excluded from In re Automotive Parts Antitrust Litigation, MDL No. 2311, and specifying which
`Settlement Class(es) (including the specific automotive part case and the Settling Defendant(s)) you wish
`to be excluded from. Your letter must also include:
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`• Your name, address, and telephone number;
`• Documents reflecting your purchase or lease of a new motor vehicle and/or purchase of the
`applicable replacement part. Purchase or lease documentation should include: (a) the date of
`purchase or lease, (b) the make and model year of the new motor vehicle, (c) the state where the
`new motor vehicle was purchased or leased, and (d) the amount paid. Replacement part
`documentation should include: (a) the date of purchase, (b) type of replacement part purchased,
`(c) the state where the replacement part was purchased, and (d) the amount paid; and
`• Your signature.
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`You must mail your exclusion request postmarked no later than April 11, 2016, to:
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`Questions? Call 1-877-940-5043 or Visit www.AutoPartsClass.com
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`Automotive Parts Indirect Exclusions
`P.O. Box 10163
`Dublin, OH 43017-3163
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`16 . IF I DON’ T EXCLUDE MYSELF, CAN I SUE FOR THE SAME THING LATER?
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`No. Unless you exclude yourself, you give up any right to sue the Settling Defendants for the claims
`being released in this litigation.
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`17 . IF I EXCLUDE MYSELF, CAN I STILL GET MONEY BENEFITS?
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`No. If you exclude yourself from the Settlement Class in any case, you will not get any money as a result
`of the Settlement in that case. However, you may exclude yourself from some Settlements but remain in
`other Settlements. In that case, you may receive money from the Settlements