LIQUID ALUMINUM SULFATE ANTITRUST LITIGATION CHEMTRADE AND KEMIRA DIRECT PURCHASER SETTLEMENT

If You Purchased Liquid Aluminum Sulfate In The United States Directly From A Defendant From January 1, 1997 Through February 28, 2011, You Could Be Affected By Proposed Class Action Settlements

• The information contained on this web page is only a summary of information presented in more detail in the Notice. Because this website is just a summary, you should review the Notice for additional details.

• Throughout the notice and this website there are capitalized terms with specific meanings. Unless otherwise defined, these terms shall have the same meaning a defined the Settlement Agreements available here.

• This lawsuit involves liquid aluminum sulfate or “Alum.” Alum is a chemical utilized by municipalities and industries for a variety of uses including, inter alia, treating drinking water, controlling algae in lakes and ponds, treating wastewater, manufacturing paper and pulp and fixing dyes to textiles. The Direct Purchaser Class Plaintiffs allege that the Kemira and Chemtrade Settling Parties (i.e., Kemira Chemicals, Inc. ("Kemira") and between Direct Purchaser Class Plaintiffs and settling defendants Chemtrade Logistics Income Fund; General Chemical Corporation; General Chemical LLC; General Chemical Performance Products, LLC; Chemtrade Chemicals Corporation; Chemtrade Chemicals US LLC; Chemtrade Solutions, LLC, and individual defendants Matthew LeBaron, Scott Wolff, Alex Avraamides, Frank Reichl, Amita Gupta, and Vincent Opalewski (together, “Chemtrade”).) participated in a conspiracy – with other Defendants in the Action and unnamed co-conspirators – to allocate territories and/or to not compete for each other’s historical business by rigging bids, allocating customers and fixing, stabilizing, and maintaining the price of Alum sold in the United States from January 1, 1997 to at least February 28, 2011 in violation of the federal antitrust laws. The Kemira and Chemtrade Settling Parties deny all of these claims and have asserted various defenses to the claims. The Court has not made any decision as to the merits of Direct Purchaser Class Plaintiffs’ claims against the Kemira and Chemtrade Settling Parties because the Parties have agreed to settle these claims.

• This Settlement pertains only to direct purchasers of Alum (i.e., those that purchased Alum in the United States directly from a Defendant). There is another lawsuit pending in the same Court that was brought on behalf of indirect purchasers, which are entities that purchased Alum from distributors or from other direct purchasers. Information about the indirect purchaser settlement can be found by visiting the website www.LiquidAluminumSulfate.com.

• The Court still has to decide whether to finally approve the Settlement. Approval of the Settlement by the Court will resolve the lawsuit against the Kemira and Chemtrade Settling Parties only. The lawsuit is continuing against the other Defendants in the Action.

• Your legal rights are affected whether you act or don’t act. The Notice includes important information about the lawsuit and the Settlement.

A SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
SUBMIT A CLAIM FORM POSTMARKED ON, OR SUBMIT A CLAIM FORM ONLINE, NO LATER THAN JUNE 13, 2019.	If you wish to make a claim against the Settlement Funds, you will need to submit a Claim Form in order to be eligible to receive a payment from the Settlement. The portion, if any, of the Settlement Funds to be allocated to you will be calculated on a pro rata basis based on your eligible purchases of Alum. Click here for more information on submitting a Claim Form.
ASK TO BE EXCLUDED BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION SO THAT IT IS POSTMARKED BY APRIL 2, 2019.	If you ask to be excluded from the Direct Purchaser Settlement Class and the Court approves the Settlement, you will not receive any money from the Settlement. This is the only option that allows you to be part of any other lawsuit against any of the Kemira and Chemtrade Settling Parties for the claims in this case. Click here for more information on excluding yourself.
OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION SO THAT IT IS RECEIVED NO LATER THAN APRIL 2, 2019.	If you do not like the Settlement, or any part of it, you may write to the Court and explain why you do not like the Settlement. You can only object to the Settlement if you are a Direct Purchaser Settlement Class Member and you do not exclude yourself. Click here for more information on objecting.
GO TO THE COURT’S FINAL FAIRNESS HEARING ON APRIL 17, 2019	If you submit a written objection, you may (but you do not have to) attend the hearing and, at the discretion of the Court, speak to the Court about your objection. Click here for more information about the Fairness Hearing.
DO NOTHING	You do not have to take any action to remain part of the Direct Purchaser Settlement Class. However, by doing nothing, you give up any rights to sue the Kemira and Chemtrade Settling Parties about the claims in this case and you will not receive a payment from the Settlement. Click here for more information.

These rights and options—and the deadlines to exercise them—are explained in the Notice. Click here to read the Notice. Click here to view answers to Frequently Asked Questions.