Frequently Asked Questions

A federal court directed that this Notice be provided to you because you have a right to know about this class action Settlement and about all of your rights and options. The Court also authorized and required the manner by which you received this Notice, and specifically required notice to be provided by email or text message, where available, or U.S. mail in certain limited circumstances. This Notice explains the Lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for them, and how to get them.

The Court presiding over this case is the United States District Court for the District of New Jersey (“the Court”). The Court is overseeing the class actions in the Lawsuit as part of a Multi-District Litigation (“MDL”) called In re: Valsartan, Losartan, and Irbesartan Products Liability Litigation, Case No. 1:19-md-02875-RBK-SAK. The people and entities that filed the Lawsuit are called the “Plaintiffs” and the companies they sued are called the “Defendants.” The settled part of the Lawsuit relates only to the Aurobindo Defendants’ sale of irbesartan between January 1, 2016 and the present, and does not involve Losartan or Valsartan.

The Settlement addresses claims that the Aurobindo Defendants violated state laws by manufacturing, distributing, selling and/or dispensing irbesartan or ICDs that were contaminated with probable human carcinogens in the form of NDEA. Aurobindo Defendants deny all allegations of fault, wrongdoing, or liability made in the Lawsuit, have denied that the amounts of NDEA in the Irbesartan and ICDs at issue were or could be carcinogenic, and have asserted various legal and factual defenses.

In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals are known as “Class Representatives” or “Plaintiffs.” Together, the people included in the class action are called a “class” or “class members.” One court resolves a class action lawsuit for all class members, except for those who opt out of the class and litigation. The Plaintiffs and the Defendants are the Parties (the “Parties”) in the Litigation.

In this Settlement, which resolves one part of the overall Lawsuit, the Class Representatives are Jacqueline Harris (“Consumer Plaintiff”) and MSP Recovery Claims, Series LLC (“MSPRC”) (“TPP Plaintiff”). In this Settlement, the Aurobindo Defendants are Aurobindo Pharma Ltd., Aurobindo Pharma USA, Inc., and Aurolife Pharma LLC (defined herein to include their predecessors, successors, subsidiaries and affiliates and each of their past, present and future direct or indirect parent companies, subsidiaries, divisions and affiliates, joint ventures, and each of their present and former officers, directors, employees, stockholders, partners, owners, and insurers).

You are a member of the consumer Settlement Class if you are an individual in the United States and its territories and possessions who, from January 1, 2016 to the present, paid any amount of money for retail purchases of irbesartan finished drug formulations manufactured using Aurobindo irbesartan API that was manufactured using Aurobindo’s IC Route of Synthesis (“IC ROS Irbesartan”).

Yes. Excluded from the Settlement Class are: (a) Any judge or magistrate presiding over this action, and the members of their families; (b) The Aurobindo Defendants and affiliated entities and their officers and directors; (c) The Aurobindo Defendants’ counsel of record, assigns and successors; (d) All federal and state governmental entities except for cities, towns, municipalities, or counties with self-funded prescription drug plans; (e) Pharmacy Benefit Managers (“PBMs”); (f) Plaintiffs’ counsel of record, assigns, and successors; (g) Any personal injury plaintiff or claimant in the MDL; and, (h) All persons or entities who properly execute and file a timely request for exclusion from any Court-approved class.

If you need help in determining your eligibility, you can visit here and answer a few simple questions. You can also call 1-866-875-9644 or email info@SartanMedicationSettlement.com for more information.

In consideration of the full and complete Release of all Released Claims against the Released Parties, and the dismissal of the Action with prejudice, the Aurobindo Defendants agree to pay $2,000,000.

The net Aurobindo Economic Loss Class Settlement fund (“the Fund”), after deduction of Attorneys’ Fees and Expenses, Class Notice and administration expenses, and Service Awards, shall be administered and allocated between the consumers and Third-Party Payors in a method to be determined by their respective Class Counsel subject to review by the Hon. Joel Schneider U.S.M.J (ret.). The allocation method will be set forth in Plaintiffs’ Motion for Preliminary Approval and filed with the Court prior to the hearing.

Consumer members of the Settlement Class shall submit Claim Forms documenting their purchases of Aurobindo IC ROS Irbesartan as provided in the Settlement Agreement and approved by the Court. The Settlement Notice Administrator will review the Claim Forms and any supporting documentation with particular attention to the possibility of fraudulent or mistaken claims.

Documentation should be submitted to support your claim, if possible. Your claim will be reviewed by the Settlement Notice Administrator to determine if sufficient information is provided to accept your claim or if additional documentation, such as proof of purchase from your pharmacy, is required. You may, if you so choose, provide documentation with your claim submission to prevent any possible delays in approving your claim.

If you are an eligible Settlement Class Member, you must submit a Claim Form to receive a Settlement payment. You can submit your Claim online here or download a paper Claim Form and submit it by mail. You may be required to submit supporting documentation. Your Claim Form must be submitted online or postmarked by June 2, 2026.

The Court will consider the fairness of the Settlement at the Final Approval Hearing scheduled for June 30, 2026. If the Court grants Final Approval, following the effective date described in the Settlement Agreement and any timeline defined in the Court’s Final Approval Order, the Settlement Notice Administrator will distribute payments. Please be patient, as this process can take some time.

If you do nothing, you will remain a part of the Class and Settlement. You will receive no payment under the Settlement and you will give up your rights to sue the Aurobindo Defendants for economic losses related to Aurobindo Irbesartan. Submitting a Claim Form is the only way to receive a payment from this Settlement.

Yes, you can choose to opt-out, or exclude yourself, from the Settlement. Choosing this option means you will not be bound by any future determination made in the Settlement; however, you will also not be eligible for a payment from this Settlement. This is the only option that allows you to pursue your own claims against one or more Aurobindo Defendants for claimed economic losses related to the Aurobindo Irbesartan.

If you want to keep your right, if any, to separately sue the Aurobindo Defendants for the claims that are addressed by the Settlement, you must take steps to exclude yourself from the Class and Lawsuit. This is called “opting out”. The deadline for requesting exclusion from the Class and Lawsuit is June 2, 2026.

To exclude yourself, you must submit a written request for exclusion that includes the following information:

• Your full name, current address, and telephone number; and
• A statement specifically and unambiguously indicating your desire to be excluded from the Settlement Class and election to be excluded from any judgment entered pursuant to the settlement.

You will also be requested to provide information as to the identification of the at-issue irbesartan you purchased, if available, however this is not a requirement for exclusion.

A printable exclusion request form is available here. Your request for exclusion must be mailed to the address below so it is postmarked or received no later than June 2, 2026.

Sartan Medication Settlement Administrator
ATTN: Exclusion Request
PO Box 3376
Baton Rouge, LA 70821

You may also email a scanned copy of your signed exclusion request form to info@SartanMedicationSettlement.com. You must download, print, complete, and sign the PDF exclusion form found here to qualify for email submission of your exclusion request. You must include your documentation of purchase or declaration regarding your inability to provide documentation with your exclusion form submission.

By electing to be excluded: (1) you will not share in any recovery that might be obtained by the Class upon Final Approval of the Settlement; (2) you will not be bound by any decision related to the Settlement that is either favorable to the Class or favorable to the Aurobindo Defendants; and (3) you may present any claims you have against the Aurobindo Defendants related to Irbesartan through your own lawsuit.

Requests for exclusions shall be permitted on an individual basis only. Any purported “class-wide” opt-outs will be construed as being submitted only on behalf of the person who actually submitted the exclusion.

No. If you stay in the Settlement Class (i.e., do nothing or do not exclude yourself), you give up any right to separately sue or pursue claims against any of the Aurobindo Defendants for the claims released in this Settlement.

Yes, if you do not like any part of the Settlement, you may write to the Court and explain your objection. You cannot submit both an exclusion request and objection. You must remain a part of the Class to object. The Court will consider your objection at the Final Approval Hearing. If the Court grants Final Approval over your objection, you will give up your rights to sue the Aurobindo Defendants about the issues in this Settlement. If you also wish to receive payment from the Settlement, you must submit a Claim Form.

The deadline for objecting to the Settlement is June 2, 2026.

Any Settlement Class Member who intends to object to the fairness of the Settlement Agreement must, file any objection via the Court’s electronic filing system, and if not filed via the Court’s electronic system, must mail, postmarked by the date specified in the Preliminary Approval Order, the objection to the Court and also serve by first-class mail copies of the objection upon:

Clerk of the Court
United States District Court
District of New Jersey
Mitchell H. Cohen Building
& U.S. Courthouse
4th & Cooper Streets
Camden, New Jersey 08101

Your objection must include:

• Your full name, current address, and telephone number;
• the identification of the Aurobindo Irbesartan purchased by you, the objector, including the NDC code(s), the date(s) of purchase, and the documentation supporting your purchase(s);
• a written statement that you have reviewed the Settlement Class definition and represent in good faith that you are a Settlement Class Member;
• a written statement of all grounds for the objection accompanied by any legal support for such objection sufficient to enable the parties to understand and respond to those specific objections;
• copies of any papers, briefs, or other documents upon which the objection is based and which are pertinent to the objection; and
• a list of all other objections submitted by you, the objector, and/or your counsel, to any class action settlements submitted in any state or federal court in the United States in the previous five (5) years, including the full case name with jurisdiction in which it was filed and the docket number. If you or your counsel has not objected to any other class action settlement in the United States in the previous five (5) years, you shall affirmatively so state in the objection

Objections shall be permitted on an individual basis only. Any purported “class-wide” objections will be construed as being submitted only on behalf of the person who actually submitted the objection.

No. To object, you must stay in the Settlement Class (i.e., do not exclude yourself) and therefore you give up any right to separately sue any of the Aurobindo Defendants for the claims released in this Settlement.

Yes, but only if you also submit a Claim Form as described in Question 8 above.

Yes, if you do not exclude yourself by opting out. The Court has appointed the following law firms to represent the Settlement Class.

Consumer Economic Loss Class Counsel

• John R. Davis, Slack Davis Sanger, LLP
• Ruben Honik, Honik Law
• Conlee Whiteley, Kanner & Whiteley, LLC

You will not be charged directly for their services. Plaintiffs will apply to the Court for an award of reasonable attorneys’ fees up to, but not to exceed, one-third of the total amount of the settlement fund, plus reasonable costs and expenses attributable to the Aurobindo Irbesartan economic loss litigation. Each party shall have the right of appeal to the extent the award is inconsistent with this Agreement. Attorneys’ Fees and Expenses shall be in addition to any Representative Plaintiffs’ Service Awards that may be awarded by the Court from the settlement fund.

If you do not exclude yourself, you do not need to hire your own lawyer because Class Counsel works for you. If you want to be represented by your own lawyer, you may hire one at your own expense and have them appear on your behalf in the Lawsuit.

The Court will hold the Final Approval Hearing at 10:00 am on Tuesday, June 30, 2026, at Courtroom 3D of the United States District Court for the District of New Jersey. The purpose of the hearing is for the Court to determine whether the Settlement is fair, reasonable, adequate, and in the best interests of the Settlement Class. At the hearing, the Court will hear any objections and arguments concerning the fairness of the proposed Settlement, including those related to the amount requested by Class Counsel for attorneys’ fees and expenses and the requested service awards for the Class Representatives.

Note: The date and time of the Final Approval Hearing are subject to change by Court Order. Any changes will be posted here.

No. Class Counsel will answer any questions the Court may have. You are welcome to come at your own expense. If you send an objection, you don’t have to come to Court to talk about it. As long as your written objection was filed or mailed on time and meets the other criteria described in Question 15 and detailed in the Settlement Agreement, the Court will consider it. You may also pay a lawyer to attend, but you don’t have to.

Subject to the approval of the Court, any objecting Settlement Class Member may appear, in person or by counsel, at the Final Fairness Hearing to explain why the proposed settlement should not be approved as fair, reasonable, and adequate, or to object to any petitions for Attorneys’ Fees, Expenses or Service Awards.

If you intend to appear at the Final Fairness Hearing, you must file with the Clerk of the Court and serve upon all counsel designated in Question 15 above a notice of intention to appear at the Fairness Hearing by the objection deadline as specified in the Preliminary Approval Order. The notice of intention to appear must include copies of any papers, exhibits, or other evidence, and the identity of witnesses, that you or your counsel intends to present to the Court in connection with the Final Fairness Hearing.

For more information about the Settlement, including assistance in determining whether you qualify as a Class Member, please visit here. You may contact the Settlement Notice Administrator by email at info@SartanMedicationSettlement.com, by phone at 1-866-875-9644 or by mail at:

Sartan Medication Settlement Administrator
P.O. Box 3376
Baton Rouge, LA 70821

PLEASE DO NOT WRITE OR CALL THE COURT OR THE CLERK’S OFFICE FOR INFORMATION.

A federal court directed that this Notice be provided to you because you have a right to know about this class action Settlement and about all of your rights and options. The Court also authorized and required the manner by which you received this Notice, and specifically required notice to be provided by email or text message, where available, or U.S. mail in certain limited circumstances. This Notice explains the Lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for them, and how to get them.

The Court presiding over this case is the United States District Court for the District of New Jersey (“the Court”). The Court is overseeing the class actions in the Lawsuit as part of a Multi-District Litigation (“MDL”) called In re: Valsartan, Losartan, and Irbesartan Products Liability Litigation, Case No. 1:19-md- 02875. The people and entities that filed the Lawsuit are called the “Plaintiffs” and the companies they sued are called the “Defendants.” The settled part of the Lawsuit relates only to the Hetero Defendants’ sale of Valsartan between May 1, 2018 and July 31, 2018, and does not involve Losartan or Irbesartan.

The Settlement addresses claims that the Hetero Defendants violated state laws by manufacturing, distributing, selling and/or dispensing Valsartan or VCDs that were contaminated with probable human carcinogens in the form of NDMA. Hetero Defendants deny all allegations of fault, wrongdoing, or liability made in the Lawsuit, have denied that the amounts of NDMA in the Valsartan and VCDs at issue were or could be carcinogenic, and have asserted various legal and factual defenses.

In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals are known as “Class Representatives” or “Plaintiffs.” Together, the people included in the class action are called a “class” or “class members.” One court resolves a class action lawsuit for all class members, except for those who opt out of the class and litigation. The Plaintiffs and the Defendants are the Parties (the “Parties”) in the Litigation.

In this Settlement, which resolves one part of the overall Lawsuit, the Class Representatives are Leland Gildner, Veronica Longwell, Peter O’Brien, Mark Hays, and James Childs (“Consumer Plaintiffs”) and MSP Recovery Claims, Series LLC (“MSPRC”) and Maine Automobile Dealers Insurance Trust (“MADA”) (“TPP Plaintiffs”). In this Settlement, the Hetero Defendants are Hetero Drugs, Ltd., Hetero Labs Ltd., Hetero USA, Inc., and Camber Pharmaceuticals, Inc. (defined herein to include their predecessors, successors, subsidiaries and affiliates and each of their past, present and future direct or indirect parent companies, subsidiaries, divisions and affiliates, joint ventures, and each of their present and former officers, directors, employees, stockholders, partners, owners, and insurers).

You are a member of the Consumer Settlement Class if you are an individual in the United States and its territories and possessions who paid any amount of money for retail purchases of Valsartan finished drug formulations utilizing Hetero Process III Valsartan active pharmaceutical ingredient (“API”) which was sold between May 1, 2018 to July 31, 2018.

Yes. Excluded from the Settlement Class are: (a) Hetero Defendants and affiliated entities and their employees, officers, directors, and agents; (b) Hetero Defendants’ assigns, and successors; (c) All federal and state governmental entities except for cities, towns, municipalities, or counties with self-funded prescription drug plans; (d) Pharmacy Benefit Managers (“PBMs”); (e) Any judge or magistrate presiding over this action, and members of their families; (f) Plaintiffs’ counsel of record; (g) Any personal injury plaintiff or claimant; and, (h) All persons who properly execute and file a timely request for exclusion from any Court-approved class.

If you need help in determining your eligibility, you can visit here and answer a few simple questions. You can also call 1-866-875-9644 or email  info@SartanMedicationSettlement.com for more information.

In consideration of the full and complete Release of all Released Claims against the Hetero Defendants, and the dismissal of the settled part of the Lawsuit with prejudice, the Hetero Defendants agree to provide the following consideration to the Settlement Class: Hetero Defendants will pay $11,365,489.80. The Hetero Defendants will also be responsible for all costs of settlement notice and administration.

The net Hetero Economic Loss Class Settlement fund (“the Fund”) available for distribution to the Settlement Class, after deduction of any attorneys’ fees, litigation expenses, and class representative service awards that may be ordered by the Court, shall be first allocated between consumers up to a maximum of 40% and remaining (expected 60%) to third-party payors (described in a separate notice); allocation to individual class members as follows:

• For Consumers: Each Class Member will receive payment from the funds based on the number of pills purchased, as indicated in their Claim Form and supporting documents, with payments calculated in increments of 30 pills. If a Class Member purchased quantities in increments other than 30 pills, such as 90 pill increments, the quantity will be converted into equivalent 30 pill
  increments for payment calculation purposes.
• Each valid Consumer member of the class shall generally receive from the Fund a distribution of no more than $40 for each 30-day supply purchased and no more than a total of $120 per
  Consumer. However, a Consumer member of the class who can sufficiently document, through receipts or pharmacy records, a claim in excess of $40 for a 30-day supply paid in full by that Consumer, may receive a payment in excess of $40 for that 30-day supply without regard to the
  $40 or $120 caps.
• Total payments to Consumers will be capped at 40% of the net Hetero Economic Loss Class Settlement fund. If the amount of payments to consumers would exceed this cap, the total
  consumer award shall be reduced on a pro rata basis based on the days’ supply purchased by each consumer so that it will not exceed 40% of the Fund.
• After payment of the consumer claims as provided above, the remainder of the Fund shall be distributed to each valid TPP member of the class (including assignees) on a pro rata basis according to the total amount of each TPP’s qualifying and documented payments.

Consumer members of the Settlement Class shall submit claim forms documenting their purchases of Hetero Process III Valsartan as provided in the Settlement Agreement and approved by the Court. The Claims administrator will review the claim forms and any supporting documentation with particular attention to the possibility of fraudulent or mistaken claims.

Documentation should be submitted to support your claim, if possible. Your claim will be reviewed by the Settlement Administrator to determine if sufficient information is provided to accept your claim or if additional documentation, such as proof of purchase from your pharmacy, is required. You may, if you so choose, provide documentation with your claim submission to prevent any possible delays in approving your claim.

If you are an eligible Class Member, you must submit a Claim Form to receive a Settlement payment. You can submit your Claim online here or download a paper Claim Form and submit it by mail. You may be required to submit supporting documentation. Your Claim Form must be submitted online or postmarked by June 2, 2026.

The Court will consider the fairness of the Settlement at the Final Approval Hearing scheduled for June 30, 2026. If the Court grants Final Approval, following the effective date described in the Settlement Agreement and any timeline defined in the Court’s Final Approval Order, the Settlement Administrator will distribute payments. Please be patient, as this process can take some time.

If you do nothing, you will remain a part of the Class and Settlement. You will receive no payment under the Settlement and you will give up your rights to sue the Hetero Defendants for economic losses related to the Hetero Defendants’ Valsartan. Submitting a Claim Form is the only way to receive a payment from this Settlement.

Yes, you can choose to opt-out, or exclude yourself, from the Settlement. Choosing this option means you will not be bound by any future determination made in the Settlement; however, you will also not be eligible for a payment from this Settlement. This is the only option that allows you to pursue your own claims against one or more Hetero Defendants for claimed economic losses related to the Hetero Defendants’ Valsartan.

If you want to keep your right, if any, to separately sue the Hetero Defendants for the claims that are addressed by the Settlement, you must take steps to exclude yourself from the Class and Lawsuit. This is called “opting out”. The deadline for requesting exclusion from the Class and Lawsuit is June 2, 2026.

To exclude yourself, you must submit a written request for exclusion that includes the following information:

• Your full name, current address, and telephone number; and
• A statement specifically and unambiguously indicating your desire to be excluded from the Settlement Class and election to be excluded from any judgment entered pursuant to the
  settlement. You will also be requested to provide information as to the identification of the at-issue valsartan you purchased, if available, however this is not a requirement for exclusion.

A printable exclusion request form is available on here. Your request for exclusion must be mailed to the address below so it is postmarked or received no later than June 2, 2026.

Hetero Settlement Administrator
ATTN: Exclusion Request
PO Box 3376
Baton Rouge, LA 70821

You may also email a scanned copy of your signed exclusion request form to info@SartanMedicationSettlement.com. You must download, print, complete, and sign the PDF exclusion form found here to qualify for email submission of your exclusion request.

By electing to be excluded: (1) you will not share in any recovery that might be obtained by the Class upon Final Approval of the Settlement; (2) you will not be bound by any decision related to the Settlement that is either favorable to the Class or favorable to the Hetero Defendants; and (3) you may present any claims you have against the Hetero Defendants related to Valsartan through your own lawsuit.

Requests for exclusions shall be permitted on an individual basis only. Any purported “class-wide” optouts will be construed as being submitted only on behalf of the person who actually submitted the exclusion.

No. If you stay in the Settlement Class (i.e., do nothing or do not exclude yourself), you give up any right to separately sue or pursue claims against any of the Hetero Defendants for the claims released in this Settlement.

Yes, if you do not like any part of the Settlement, you may write to the Court and explain your objection. You cannot submit both an exclusion request and objection. You must remain a part of the Class to object. The Court will consider your objection at the Final Approval Hearing. If the Court grants Final Approval over your objection, you will give up your rights to sue the Hetero Defendants about the issues in this Settlement. If you also wish to receive payment from the Settlement, you must submit a Claim Form.

The deadline for objecting to the Settlement is June 2, 2026. Any Settlement Class Member who intends to object to the fairness of the Settlement Agreement must, file any objection via the Court’s electronic filing system, and if not filed via the Court’s electronic system, must mail, postmarked by the date specified in the Preliminary Approval Order, the objection to the Court and also serve by first-class mail copies of the objection upon:

Clerk of the Court
United States District Court
District of New Jersey
Mitchell H. Cohen Building
& U.S. Courthouse
4th & Cooper Streets
Camden, New Jersey 08101

Your objection must include:

• Your full name, current address, and telephone number;
• the identification of the at issue Valsartan purchased by you, the objector, including the NDC code(s), the date(s) of purchase, and the documentation supporting your purchase(s);
• a written statement that you have reviewed the Settlement Class definition and represent in good faith that you are a Settlement Class Member;
• a written statement of all grounds for the objection accompanied by any legal support for such objection sufficient to enable the parties to understand and respond to those specific objections;
• copies of any papers, briefs, or other documents upon which the objection is based and which are pertinent to the objection; and
• a list of all other objections submitted by you, the objector, and/or your counsel, to any class action settlements submitted in any state or federal court in the United States in the previous five (5) years, including the full case name with jurisdiction in which it was filed and the docket number. If you or your counsel has not objected to any other class action settlement in the United States in the previous five (5) years, you shall affirmatively so state in the objection

Objections shall be permitted on an individual basis only. Any purported “class-wide” objections will be construed as being submitted only on behalf of the person who actually submitted the objection.

No. To object, you must stay in the Settlement Class (i.e., do not exclude yourself) and therefore you give up any right to separately sue any of the Hetero Defendants for the claims released in this Settlement.

Yes, but only if you also submit a Claim Form as described in Question 8 above.

Yes, if you do not exclude yourself by opting out. The Court has appointed the following law firms to represent the Settlement Class.

Consumer Economic Loss Class Counsel

• John R. Davis, Slack Davis Sanger, LLP
• Ruben Honik, Honik Law
• Conlee Whiteley, Kanner & Whiteley, LLC

You will not be charged directly for their services. Plaintiffs will apply to the Court for an award of reasonable attorneys’ fees up to, but not to exceed, one-third of the total amount of the settlement fund, plus reasonable costs and expenses related to the Hetero Valsartan economic loss litigation. Attorneys’ Fees and Expenses shall be in addition to any Representative Plaintiffs’ Service Awards that may be awarded by the Court from the settlement fund.

If you do not exclude yourself, you do not need to hire your own lawyer because Class Counsel works for you. If you want to be represented by your own lawyer, you may hire one at your own expense and have them appear on your behalf in the Lawsuit.

The Court will hold the Final Approval Hearing at 10:00 am on June 30, 2026 in Courtroom 3D of the United States District Court for the District of New Jersey, Camden Division, Mitchell H. Cohen Building & U.S. Courthouse, 4th & Cooper Streets, Camden, NJ 08101. The purpose of the hearing is for the Court to determine whether the Settlement is fair, reasonable, adequate, and in the best interests of the Settlement Class. At the hearing, the Court will hear any objections and arguments concerning the fairness of the proposed Settlement, including those related to the amount requested by Class Counsel for attorneys’ fees and expenses and the requested service awards for the Class Representatives.

Note: The date and time of the Final Approval Hearing are subject to change by Court Order. Any changes will be posted here.

No. Class Counsel will answer any questions the Court may have. You are welcome to come at your own expense. If you send an objection, you don’t have to come to Court to talk about it. As long as your written objection was filed or mailed on time and meets the other criteria described in Question 15 and detailed in the Settlement Agreement, the Court will consider it. You may also pay a lawyer to attend, but you don’t have to.

Subject to the approval of the Court, any objecting Settlement Class Member may appear, in person or by counsel, at the Final Fairness Hearing to explain why the proposed settlement should not be approved as fair, reasonable, and adequate, or to object to any petitions for Attorneys’ Fees, Expenses or Service Awards.

If you intend to appear at the Final Fairness Hearing, you must file with the Clerk of the Court and serve upon all counsel designated in Question 15 above a notice of intention to appear at the Fairness Hearing by the objection deadline as specified in the Preliminary Approval Order. The notice of intention to appear must include copies of any papers, exhibits, or other evidence, and the identity of witnesses, that you or your counsel intends to present to the Court in connection with the Final Fairness Hearing.

For more information about the Settlement, including assistance in determining whether you qualify as a Class Member, please visit here. You may contact the Settlement Administrator by email at info@SartanMedicationSettlement.com, by phone at 1-866-875-9644 or by mail at:

Hetero Settlement Administrator
PO Box 3376
Baton Rouge, LA 70821

Please do not write or call the Court or the Clerk’s Office for information.

A federal court directed that this Notice be provided to you because you have a right to know about this class action Settlement and about all of your rights and options. The Court also authorized and required the manner by which you received this Notice, and specifically required notice to be provided by email or text message, where available, or U.S. mail in certain limited circumstances. This Notice explains the Lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for them, and how to get them.

The Court presiding over this case is the United States District Court for the District of New Jersey (“the Court”). The Court is overseeing the class actions in the Lawsuit as part of a Multi-District Litigation (“MDL”) called In re: Valsartan, Losartan, and Irbesartan Products Liability Litigation, Case No. 1:19-md- 02875-RBK-SAK. The people and entities that filed the Lawsuit are called the “Plaintiffs” and the companies they sued are called the “Defendants.” The settled part of the Lawsuit relates only to Vivimed’s sale of Losartan Impacted NDCs, and does not involve Irbesartan or Valsartan.

The Settlement addresses claims that Vivimed violated state laws by manufacturing, distributing, selling and/or dispensing Losartan or LCDs that were contaminated with probable human carcinogens in the form of NMBA. Vivimed Defendants deny all allegations of fault, wrongdoing, or liability made in the Lawsuit, have denied that the amounts of NMBA in the Losartan and LCDs at issue were or could be carcinogenic, and have asserted various legal and factual defenses.

In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals are known as “Class Representatives” or “Plaintiffs.” Together, the people included in the class action are called a “class” or “class members.” One court resolves a class action lawsuit for all class members, except for those who opt out of the class and litigation. The Plaintiffs and the Defendants are the Parties (the “Parties”) in the Litigation.

In this Settlement, which resolves one part of the overall Lawsuit, the Class Representatives are Jacqueline Harris (“Consumer Plaintiff”) and MSP Recovery Claims, Series LLC (“MSPRC”) (“TPP Plaintiff”). In this Settlement, Vivimed are Vivimed Pharma Ltd., Vivimed Pharma USA, Inc., and Aurolife Pharma LLC (defined herein to include their predecessors, successors, subsidiaries and affiliates and each of their past, present and future direct or indirect parent companies, subsidiaries, divisions and affiliates, joint ventures, and each of their present and former officers, directors, employees, stockholders, partners, owners, and insurers).

You are a member of the consumer Settlement Class if you are an individual in the United States and its territories and possessions who paid any amount of money for retail purchases of Vivimed Losartan finished drug formulations sold under the following impacted National Drug Codes (“NDCs”): 23155-644- 09; 23155-644-10; 23155-645-03; 23155-645-09; 23155-645-10; 23155-646-03; 23155-646-09; and 23155-646-10 (“Impacted NDCs”).

Yes. Excluded from the Settlement Class are: (a) Vivimed and affiliated entities and their employees, officers, directors, and agents; (b) Vivimed’s assigns, and successors; (c) all federal and state governmental entities except for cities, towns, municipalities, or counties with self-funded prescription drug plans; (d) Pharmacy Benefit Managers (“PBMs”); (e) any judge or magistrate presiding over this action, and members of their families; (f) Plaintiffs’ counsel of record; (g) any personal injury plaintiff or claimant; and, (h) all persons who properly execute and file a timely request for exclusion from any Court-approved class.

If you need help in determining your eligibility, you can visit here and answer a few simple questions. You can also call 1-866-875-9644 or email info@SartanMedicationSettlement.com for more information.

In consideration of the full and complete Release of all Released Claims against Vivimed and the Released Parties, and the dismissal of the Action with prejudice, Vivimed agrees to pay $1,899,000.00. All costs of settlement notice and administration shall be paid from the settlement fund.

The net fund (“the Fund”), after deduction of Attorneys’ Fees and Expenses, Class Notice and administration expenses, and Service Awards, shall be administered and allocated between the consumers and Third-Party Payors in a method to be determined by their respective Class Counsel subject to review by the Hon. Joel Schneider U.S.M.J (ret.). The allocation method will be set forth in Plaintiffs’ Motion for Preliminary Approval and filed with the Court prior to the hearing.

Consumer members of the Settlement Class shall submit Claim Forms documenting their purchases of Vivimed Losartan Impacted NDCs as provided in the Settlement Agreement and approved by the Court. The Settlement Notice Administrator will review the Claim Forms and any supporting documentation with particular attention to the possibility of fraudulent or mistaken claims.

Documentation should be submitted to support your claim, if possible. Your claim will be reviewed by the Settlement Notice Administrator to determine if sufficient information is provided to accept your claim or if additional documentation, such as proof of purchase from your pharmacy, is required. You may, if you so choose, provide documentation with your claim submission to prevent any possible delays in approving your claim.

If you are an eligible Settlement Class Member, you must submit a Claim Form to receive a Settlement payment. You can submit your Claim online here or download a paper Claim Form and submit it by mail. You may be required to submit supporting documentation. Your Claim Form must be submitted online or postmarked by [CLAIMS DEADLINE].

The Court will consider the fairness of the Settlement at the Final Approval Hearing scheduled for Month Day, Year. If the Court grants Final Approval, following the effective date described in the Settlement Agreement and any timeline defined in the Court’s Final Approval Order, the Settlement Notice Administrator will distribute payments. Please be patient, as this process can take some time.

If you do nothing, you will remain a part of the Class and Settlement. You will receive no payment under the Settlement and you will give up your rights to sue Vivimed for economic losses related to Vivimed’s Losartan. Submitting a Claim Form is the only way to receive a payment from this Settlement.

Yes, you can choose to opt-out, or exclude yourself, from the Settlement. Choosing this option means you will not be bound by any future determination made in the Settlement; however, you will also not be eligible for a payment from this Settlement. This is the only option that allows you to pursue your own claims against Vivimed for claimed economic losses related to Vivimed’s Losartan.

If you want to keep your right, if any, to separately sue Vivimed for the claims that are addressed by the Settlement, you must take steps to exclude yourself from the Class and Lawsuit. This is called “opting out”. The deadline for requesting exclusion from the Class and Lawsuit is [EXCLUSION DEADLINE].

To exclude yourself, you must submit a written request for exclusion that includes the following information:

• Your full name, current address, and telephone number, and qualification to participate in the settlement, and;
• A statement specifically and unambiguously indicating your desire to be excluded from the Settlement Class and election to be excluded from any judgment entered pursuant to the
  Settlement.

You will also be requested to provide information as to the identification of the at-issue losartan you purchased, if available, however this is not a requirement for exclusion.

A printable exclusion request form is available here. Your request for exclusion must be mailed to the address below so it is postmarked or received no later than [EXCLUSION DEADLINE].

Vivimed Settlement Notice Administrator
ATTN: Exclusion Request
PO Box 3376
Baton Rouge, LA 70821

You may also email a scanned copy of your signed exclusion request form to info@SartanMedicationSettlement.com. You must download, print, complete, and sign the PDF exclusion form found here to qualify for email submission of your exclusion request. You must include your documentation of purchase or declaration regarding your inability to provide documentation with your exclusion form submission.

By electing to be excluded: (1) you will not share in any recovery that might be obtained by the Class upon Final Approval of the Settlement; (2) you will not be bound by any decision related to the Settlement that is either favorable to the Class or favorable to Vivimed; and (3) you may present any claims you have against Vivimed related to Losartan through your own lawsuit.

Requests for exclusions shall be permitted on an individual basis only. Any purported “class-wide” optouts will be construed as being submitted only on behalf of the person who actually submitted the exclusion.

No. If you stay in the Settlement Class (i.e., do nothing or do not exclude yourself), you give up any right to separately sue or pursue claims against any of Vivimed for the claims released in this Settlement.

Yes, if you do not like any part of the Settlement, you may write to the Court and explain your objection. You cannot submit both an exclusion request and objection. You must remain a part of the Class to object. The Court will consider your objection at the Final Approval Hearing. If the Court grants Final Approval over your objection, you will give up your rights to sue Vivimed about the issues in this Settlement. If you also wish to receive payment from the Settlement, you must submit a Claim Form.

The deadline for objecting to the Settlement is [OBJECTION DEADLINE].

Any Settlement Class Member who intends to object to the fairness of the Settlement Agreement must, file any objection via the Court’s electronic filing system, and if not filed via the Court’s electronic system, must mail, postmarked by the date specified in the Preliminary Approval Order, the objection to the Court and also serve by first-class mail copies of the objection upon:

Clerk of the Court
United States District Court
District of New Jersey
Mitchell H. Cohen Building
& U.S. Courthouse
4th & Cooper Streets
Camden, New Jersey 08101

Your objection must include:

• Your full name, current address, and telephone number;
• the identification of the at issue Vivimed Losartan purchased by you, the objector, including the amount of Vivimed Losartan the objector claims to have purchased, the date(s) of purchase, and documentation necessary to establish these elements if required by the Settlement Notice Administrator;
• a written statement that you have reviewed the Settlement Class definition and represents in good faith that you are a Settlement Class Member;
• a written statement of all grounds for the objection accompanied by any legal support for such objection sufficient to enable the parties to understand and respond to those specific objections; copies of any papers, briefs, or other documents upon which the objection is based and which are pertinent to the objection; and
• a list of all other objections submitted by you, the objector, and/or your counsel, to any class action settlements submitted in any state or federal court in the United States in the previous five (5) years, including the full case name with jurisdiction in which it was filed and the docket number. If you or your counsel has not objected to any other class action settlement in the United States in the previous five (5) years, you shall affirmatively so state in the objection

Objections shall be permitted on an individual basis only. Any purported “class-wide” objections will be construed as being submitted only on behalf of the person who actually submitted the objection.

No. To object, you must stay in the Settlement Class (i.e., do not exclude yourself) and therefore you give up any right to separately sue any of Vivimed for the claims released in this Settlement.

Yes, but only if you also submit a Claim Form as described in Question 8 above.

Yes, if you do not exclude yourself by opting out. The Court has appointed the following law firms to represent the Settlement Class.

Consumer Economic Loss Class Counsel

• John R. Davis, Slack Davis Sanger, LLP
• Ruben Honik, Honik Law
• Conlee Whiteley, Kanner & Whiteley, LLC

You will not be charged directly for their services. Plaintiffs will apply to the Court for an award of reasonable attorneys’ fees up to, but not to exceed, one-third of the total amount of the Settlement Fund, plus reasonable costs and expenses related to the Vivimed Losartan economic loss litigation. Attorneys’ Fees and Expenses shall be in addition to any Representative Plaintiffs’ Service Awards that may be awarded by the Court from the Settlement Fund.

If you do not exclude yourself, you do not need to hire your own lawyer because Class Counsel works for you. If you want to be represented by your own lawyer, you may hire one at your own expense and have them appear on your behalf in the Lawsuit.

The Court will hold the Final Approval Hearing at TIME on Day, Month Date, Year at Courthouse. The purpose of the hearing is for the Court to determine whether the Settlement is fair, reasonable, adequate, and in the best interests of the Settlement Class. At the hearing, the Court will hear any objections and arguments concerning the fairness of the proposed Settlement, including those related to the amount requested by Class Counsel for attorneys’ fees and expenses and the requested service awards for the Class Representatives.

Note: The date and time of the Final Approval Hearing are subject to change by Court Order. Any changes will be posted here.

No. Class Counsel will answer any questions the Court may have. You are welcome to come at your own expense. If you send an objection, you don’t have to come to Court to talk about it. As long as your written objection was filed or mailed on time and meets the other criteria described in Question 15 and detailed in the Settlement Agreement, the Court will consider it. You may also pay a lawyer to attend, but you don’t have to.

Subject to the approval of the Court, any objecting Settlement Class Member may appear, in person or by counsel, at the Final Fairness Hearing to explain why the proposed settlement should not be approved as fair, reasonable, and adequate, or to object to any petitions for Attorneys’ Fees, Expenses or Service Awards.

If you intend to appear at the Final Fairness Hearing, you must file with the Clerk of the Court and serve upon all counsel designated in Question 15 above a notice of intention to appear at the Fairness Hearing by the objection deadline as specified in the Preliminary Approval Order. The notice of intention to appear must include copies of any papers, exhibits, or other evidence, and the identity of witnesses, that you or your counsel intends to present to the Court in connection with the Final Fairness Hearing.

For more information about the Settlement, including assistance in determining whether you qualify as a Class Member, please visit here. You may contact the Settlement Notice Administrator by email at info@SartanMedicationSettlement.com, by phone at 1-866-875-9644 or by mail at:

Vivimed Settlement Notice Administrator
P.O. Box 3376
Baton Rouge, LA 70821

PLEASE DO NOT WRITE OR CALL THE COURT OR THE CLERK’S OFFICE FOR INFORMATION.