Case 2:12-md-02311-SFC-RSW ECF No. 2114-7, PageID.38369 Filed 02/17/21 Page 1 of 7
`
`
`
`
`
`EXHIBIT E
`
`

`

`Case 2:12-md-02311-SFC-RSW ECF No. 2114-7, PageID.38370 Filed 02/17/21 Page 2 of 7
`The Circuit Court of Cook County, Illinois
`County Department, Chancery Division
`If You Were an Illinois Resident Who Bought a TV or Monitor Containing a Cathode Ray
`Tube (CRT) between March 1, 1995 and November 25, 2007,
`This Lawsuit And Settlements May Affect You.
`The Circuit Court of Cook County, Illinois, 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 don’t act.
`• There is a lawsuit involving cathode ray tubes (“CRTs”) purchased indirectly from the Defendants. “Indirectly”
`means that you purchased the CRT from someone other than the company that manufactured the component CRT.
`In most cases, this means that you bought a TV or monitor containing a CRT from a retailer.
`• The lawsuit was brought by the Illinois Attorney General on behalf of the State of Illinois and as parens patriae on
`behalf of Illinois consumers (individuals and businesses) as purchasers of TVs and monitors containing a CRT for
`their own use and not for resale indirectly from the Defendants, anytime from March 1, 1995 to November 25,
`2007. Defendants deny all of the claims in the lawsuit. See Question 5 below for more details about who is eligible
`to recover money in this lawsuit.
`• This notice only relates to the Illinois consumer (individuals and businesses) claims in the lawsuit. If you are a
`governmental entity, you may not participate in this settlement.
`• Settlements totaling over $36 million have been reached with four Defendant groups (together called the
`“Settling Defendants”) and the lawsuit is continuing against two remaining Defendant groups (the “Non-Settling
`Defendants”). The Settling Defendants have also agreed to cooperate with the State in the litigation against the
`Non-Settling Defendants. The ongoing litigation is seeking damages from the Non-Settling Defendants.
`
`YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT AND SETTLEMENTS
`
`SUBMIT A CLAIM
`
`EXCLUDE YOURSELF
`
`DO NOTHING
`
`Under this option, if you submit a claim by July 12, 2018, you may
`be entitled to receive a payment. You would give up your rights
`to sue the Defendants about the claims in this case. Any claims
`filed after July 12, 2018 will be considered for payment only if
`settlement funds remain after all valid claims filed by that date
`have been paid in full.
`
`Under this option, you would not be included in the ongoing
`lawsuits or settlements. You would receive no benefits, but you
`would retain any rights you currently have to sue the Defendants
`about the claims in this case.
`
`If you do nothing, you will not receive any payment and you will
`give up your rights to sue the Defendants about the claims in this
`case.
`
`QUESTIONS? VISIT WWW.ILLINOISCRTSETTLEMENT.COM OR CALL 1-866-652-8226
`
`Page 1 of 6
`
`

`

`Case 2:12-md-02311-SFC-RSW ECF No. 2114-7, PageID.38371 Filed 02/17/21 Page 3 of 7
`What This Notice Contains
`Basic Information......................................................................................................................................................2
`1.
`What is this Notice about? ..............................................................................................................................2
`2.
`What is the lawsuit about? ..............................................................................................................................2
`3.
`What is a Cathode Ray Tube (“CRT”)? ..........................................................................................................3
`What is parens patriae authority? ..................................................................................................................3
`4.
`How do I know if I may recover damages in the Illinois Attorney General’s parens patriae lawsuit? .........3
`5.
`6.
`Who are the Defendant companies? ...............................................................................................................3
`7.
`Why are there settlements but the lawsuit is continuing? ..............................................................................4
`The Settlements’ Benefits..........................................................................................................................................4
`8.
`What do the settlements provide? ..................................................................................................................4
`9.
`How much money can I get? ..........................................................................................................................4
`10. When will I get a payment? ............................................................................................................................4
`How To Get A Payment.............................................................................................................................................4
`11.
`How can I get a payment? ..............................................................................................................................4
`12.
`Can I have someone else submit a claim on my behalf? ................................................................................5
`13.
`Can I submit an incomplete claim form by the deadline and supply further information later? ....................5
`Remaining in the Lawsuit ........................................................................................................................................5
`14.
` What am I giving up if I stay in the lawsuit? ................................................................................................5
`15.
` How do I get out of the lawsuit? ...................................................................................................................5
`16.
` If I don’t exclude myself, can I sue for the same thing later? .......................................................................5
`17.
` If I exclude myself, can I still get benefits from the lawsuit? .......................................................................6
`The Lawyers Representing You ...............................................................................................................................6
`18.
` Do I have a lawyer representing me? ............................................................................................................6
`19.
` How will the lawyers be paid? ......................................................................................................................6
`The Trial .....................................................................................................................................................................6
`20.
` When and where will the trial against the Non-Settling Defendants take place? .........................................6
`21.
` What is the Plaintiff asking for from the Non-Settling Defendants? ............................................................6
`22.
` Will I get money after the trials? ...................................................................................................................6
`Get More Information ..............................................................................................................................................6
`23.
` Where can I get more information? ...............................................................................................................6
`
`Basic Information
`
`What is this Notice about?
`1.
`This Notice is to inform you about the status and partial settlement of ongoing litigation which may affect your rights.
`You have the right to know about the lawsuit and about your legal rights and options before the Court or the jury decide
`whether the claims being made against the Defendants on your behalf are correct.
`The Court in charge is the Circuit Court of Cook County, Illinois. The case is called Illinois v. Hitachi Ltd., et al, No. 12
`CH 35266. The Illinois Attorney General is called the Plaintiff, and the companies it sued are called the Defendants (see
`Question 6 – Who are the Defendant Companies?).
`2.
`What is the lawsuit about?
`The lawsuit claims that the Defendants conspired to fix, raise, maintain or stabilize prices of CRTs resulting in
`overcharges to consumers who bought products containing CRTs. The Defendants deny Plaintiff’s allegations or that
`
`QUESTIONS? VISIT WWW.ILLINOISCRTSETTLEMENT.COM OR CALL 1-866-652-8226
`
`Page 2 of 6
`
`

`

`Case 2:12-md-02311-SFC-RSW ECF No. 2114-7, PageID.38372 Filed 02/17/21 Page 4 of 7
`indirect purchasers suffered any overcharge. The Court has not yet decided who is right.
`3.
`What is a Cathode Ray Tube (“CRT”)?
`A CRT is a piece of technology used as displays (screens) in televisions and computer monitors. Before LCD, Plasma
`and LED display technologies became popular, CRTs were the main technology used in these devices.
`This is what a CRT monitor looks like:
`This is what a CRT television looks like:
`
`What is parens patriae authority?
`4.
`The doctrine of parens patriae allows the Illinois Attorney General to bring a lawsuit under the antitrust laws on
`behalf of Illinois residents to recover damages. The Illinois Attorney General may also seek injunctive relief and civil
`penalties.
`How do I know if I may recover money in the Illinois Attorney General’s parens patriae lawsuit?
`5.
`Illinois consumers: The Illinois Attorney General is seeking monetary damages incurred by any Illinois resident
`(person or business) that purchased a CRT television or monitor between March 1, 1995 and November 25, 2007,
`while residing in Illinois and for their own use in Illinois and not for resale. Therefore, if you purchased one or more
`CRT television or monitor between March 1, 1995 and November 25, 2007 while residing in Illinois (or, if you are a
`business, while you were headquartered or incorporated in Illinois), you may recover by filing a claim.
`You may not file a claim if you are:
`• An individual who resided outside Illinois when you purchased your CRT television or monitor
`• A business that was incorporated and headquartered outside Illinois when you purchased your CRT television or
`monitor
`• An Illinois county, municipality, township or other political subdivision
`If you may not file a claim in this lawsuit because of the above criteria, you retain any right you may have to sue the
`Defendants for monetary relief.
`The Illinois Attorney General is also seeking monetary damages on behalf of the State of Illinois, including its state
`agencies. However, this notice of settlement does not relate to the settlements resolving the State of Illinois’ claims.
`Illinois state agencies are not eligible to participate in this claims process.
`6.
`Who are the Defendant companies?
`The Defendants are manufacturers and/or suppliers of CRTs.
`The Settling Defendant companies are:
`• Hitachi Ltd., and Hitachi Electronic Devices (USA) Inc. (“Hitachi”)
`• LG Electronics, Inc. (“LG”)
`• Koninklijke Philips Electronics N.V. and Philips Electronics North American Corp. (“Philips”)
`• Samsung Display Device Co., Ltd. and Samsung SDI America, Inc. (“Samsung”)
`
`QUESTIONS? VISIT WWW.ILLINOISCRTSETTLEMENT.COM OR CALL 1-866-652-8226
`
`Page 3 of 6
`
`

`

`Case 2:12-md-02311-SFC-RSW ECF No. 2114-7, PageID.38373 Filed 02/17/21 Page 5 of 7
`The Non-Settling Defendant companies are:
`• Panasonic Corporation, Panasonic Corp. of North America, and MT Picture Display, Co., Ltd. (“Panasonic”).
`• Toshiba Corporation, Toshiba America, Inc., Toshiba America Information Systems Inc., Toshiba America
`Electronic Components, Inc. (“Toshiba”)
`Why are there settlements but the lawsuit is continuing?
`7.
`Settlements have been reached with Hitachi, LG, Philips, and Samsung. The Non-Settling Defendants (Panasonic and
`Toshiba) have not agreed to settle so the lawsuit continues against them.
`Additional money may become available as a result of a trial or a future settlement. If the State later settles with the
`Non-Settling Defendants, the settlement agreement(s) will be posted on the website, www.illinoiscrtsettlement.com.
`Alternatively, the litigation may be resolved in favor of the Non-Settling Defendants, in which case no additional
`money would become available. There is no guarantee as to what will happen.
`The Settlements’ Benefits
`
`What do the settlements provide?
`8.
`The four Settling Defendants have settled the claims brought on behalf of Illinois businesses and individuals for a total
`of approximately $36 million.
`Any interest earned will be added to the Settlement Fund. The cost to administer the Settlements as well as the Illinois
`Attorney General’s fees and costs will come out of the Settlement Fund (see Question 19 - How will the lawyers be
`paid?).
`How much money can I get?
`9.
`The maximum amount you could potentially recover equals three times the actual amount the State alleges you were
`overcharged for each device containing a CRT—a total of $20 for a television and $60 for a monitor. If there is not
`enough money recovered to pay the maximum amount, your recovery will depend on the number of claims per device
`submitted by July 12, 2018 and the total recovery. We expect that such a pro rata distribution will allow for at least $20
`per claim and will increase if there are additional settlements or the Illinois Attorney General prevails at trial.
`It is possible that any money remaining after claims are paid will be distributed to charities, governmental entities, or
`other beneficiaries.
`In order to receive a payment, you will need to file a valid claim (see Question 11 – How can I get a payment?).
`The Claim Form provides additional details on how to submit a claim. Further information is available at
`www.illinoiscrtsettlement.com or by calling 1-866-652-8226.
`10. When will I get a payment?
`No money will be distributed yet. The Plaintiff will pursue the lawsuit against the Non-Settling Defendants and will
`complete the litigation before any claims are paid. Plaintiff believes that money could be paid by the Non-Settling
`Defendants through additional settlements or as a result of winning the lawsuit. All funds received in this case will be
`distributed together at the conclusion of the lawsuit or as ordered by the Court.
`How To Get A Payment
`
`How can I get a payment?
`11.
`If you meet the requirements described in Question 5 and you want to participate in the Settlements, you must complete
`and submit a Claim Form. We urge you to submit a Claim Form online at www.illinoiscrtsettlement.com. If you do not
`
`QUESTIONS? VISIT WWW.ILLINOISCRTSETTLEMENT.COM OR CALL 1-866-652-8226
`
`Page 4 of 6
`
`

`

`Case 2:12-md-02311-SFC-RSW ECF No. 2114-7, PageID.38374 Filed 02/17/21 Page 6 of 7
`file online, you can also file a paper Claim Form by mail.
`The Claim Form can be found at www.illinoiscrtsettlement.com or you can obtain a copy by calling, toll free,
`1-866-652-8226. If you choose to submit your claim online, you must do so on or before July 12, 2018. If you choose
`to submit a Claim Form by mail, it must be postmarked by July 12, 2018, and mailed to:
`CRT Illinois Claims
`c/o KCC Class Action Services
`P.O. Box 404041
`Louisville, KY 40233-4041
` Can I have someone else submit a claim on my behalf?
`12.
`We will not accept or pay claims filed by someone else on behalf or as an assignee of the person or entity who actually
`purchased the CRT television or monitor. This means that when you submit your claim, the name and address of the
`claimant must match the name and address to which the payment is to be sent. If these names and addresses do not
`match, your claim will be invalid. For individuals, the name of the person verifying the information must match that of
`the person making the claim. For corporations or other business entities, the individual verifying the information must
`be a duly authorized officer of the corporation or business entity. Verification provided by anyone else will be treated
`as an unverified claim and invalidated.
`The process of filing a claim is designed to be straightforward. If you have any questions about how to file a claim,
`you can call the claims administrator at 1-866-652-8226 for assistance.
`13.
` Can I submit an incomplete claim form by the deadline and supply further information later?
`No. In order to be a valid claim, your claim form must be complete at the time of filing. You should not leave any
`part of the claim form blank or include inaccurate information that you intend to update later. If you determine you
`have made a mistake on your claim form after submitting it, please call the claims administrator at 1-866-652-8226 to
`address the issue.
`
`Remaining in the Lawsuit
` What am I giving up if I stay in the lawsuit?
`14.
`You will give up your right to sue the Defendants on your own for the claims in this case unless you exclude yourself
`from the lawsuit. You also will be bound by all current and future settlements and directions by the Court relating to
`the lawsuit.
`In return for paying the Settlement amounts, the Settling Defendants (and certain related entities defined in the
`Settlement Agreements) will be released from all claims relating to the facts underlying this lawsuit, as more fully
`described in the Settlement Agreements. The Settlement Agreements describe the released claims in detail, so read
`them carefully since those descriptions are binding on you. If you have any questions, you can call 1-866-652-8226,
`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.illinoiscrtsettlement.com.
`Excluding Yourself from the Lawsuit
` How do I get out of the lawsuit?
`15.
`To exclude yourself from the lawsuit, you must send a letter (or request for exclusion) by mail stating that you want
`to be excluded from Illinois v. Hitachi Ltd., et al., No. 12 CH 35266. Your letter or request for exclusion must also
`include your name, your address, your telephone number and your signature. You must mail your exclusion request
`no later than March 12, 2018, to:
`
`CRT Illinois Indirect Exclusions
`c/o KCC Class Action Services
`P.O. Box 404041
`
`QUESTIONS? VISIT WWW.ILLINOISCRTSETTLEMENT.COM OR CALL 1-866-652-8226
`
`Page 5 of 6
`
`

`

`Case 2:12-md-02311-SFC-RSW ECF No. 2114-7, PageID.38375 Filed 02/17/21 Page 7 of 7
`Louisville, KY 40233-4041
` If I don’t exclude myself, can I sue for the same thing later?
`16.
`No. Unless you exclude yourself, you give up any right to sue the Defendants for the claims in this case.
`17.
` If I exclude myself, can I still get benefits from the lawsuit?
`No. If you exclude yourself, you will not get any benefit as a result of the Settlements, trial, or judgment in this case.
`The Lawyers Representing You
` Do I have a lawyer representing me?
`18.
`As noted above, the Illinois Attorney General is representing consumers as parens patriae and state agencies in Illinois
`(see Question 5). You do not have to pay the Illinois Attorney General separately. If you wish to seek the advice of your
`own lawyer, you may hire one at your own expense.
`19.
` How will the lawyers be paid?
`Under the terms of the Settlements, the parties expect that 10% of the Settlement Fund will be awarded to the Illinois
`Attorney General for fees and costs, including the cost to administer the Settlements.
`The Trial
` When and where will the trial against the Non-Settling Defendants take place?
`20.
`If the cases are not dismissed or settled, the Plaintiff will have to prove its claims against the Non-Settling Defendants.
`The trial date has not yet been scheduled.
`During the trial, a decision will be reached about whether the Plaintiff or the Non-Settling Defendants are right about the
`claims in the lawsuit. There is no guarantee that the Plaintiff will win any additional money or benefits for consumers.
`21.
` What is the Plaintiff asking for from the Non-Settling Defendants?
`The Plaintiff is asking for money for Illinois consumers and State agencies and for civil penalties.
`22.
` Will I get money after the trials?
`If you file a valid claim (see Question 11 - How can I get a payment?), you will receive a portion of the current
`settlements at a later date. If the Plaintiff obtains additional settlements or prevails at trial, you will receive a portion
`of those recoveries, in addition to what you are entitled to under the current settlements, up to the estimated actual
`recoveries discussed above (See Question 9 - How much money can I get?). If you file a valid claim, you will be
`paid once after the lawsuit is resolved against all Defendants. You will not receive two separate payments. Important
`information about the case will be posted on the website, www.illinoiscrtsettlement.com, as it becomes available.
`Get More Information
` Where can I get more information?
`23.
`The Notice summarizes the lawsuit and the Settlements. You can get more information about the lawsuit and
`Settlements at www.illinoiscrtsettlement.com, by calling 1-866-652-8226, or writing to Illinois CRT Claims, c/o
`KCC, P.O. Box 404041, Louisville, KY 40233-4041.
`
`QUESTIONS? VISIT WWW.ILLINOISCRTSETTLEMENT.COM OR CALL 1-866-652-8226
`
`Page 6 of 6
`
`