Common use of Notice Plan and Claim Form Clause in Contracts

Notice Plan and Claim Form. a. The Parties agree to provide the best Notice that is practicable under the circumstances, including individual notice to Persons in the Settlement Class who may be identified through reasonable efforts. b. The Parties shall provide the Settlement Administrator with the Class List. The Settlement Administrator shall use the Class List to take all steps reasonably necessary, including reverse phone look-ups of the phone numbers using a historical lookup approach, to identify the owners of the numbers in the Class List together with such Persons’ last known mailing addresses. After identifying mailing addresses through this process, the Settlement Administrator shall, by using the National Change of Address (“NCOA”) database maintained by the United States Postal Service (“Postal Service”), obtain updated mailing addresses, if available. c. Within thirty (30) days following entry of the Preliminary Approval Order, the Settlement Administrator shall send the Short Form/Postcard Notice to each Class Member via first class mail for those Class Members for whom a mailing address has been obtained. Neither the Parties nor the Settlement Class Administrator shall have any obligation to mail the Short Form/Postcard Notice to any Settlement Class Member for whom no mailing address could be located. To the extent deemed necessary by the Settlement Administrator, the last known address of Persons in the Settlement Class will be subject to confirmation or updating as follows: (a) the Settlement Administrator may conduct a reasonable search to locate an updated address for any Person in the Settlement Class whose Short Form/Postcard Notice is returned as undeliverable; (b) the Settlement Administrator shall update addresses based on any forwarding information received from the United States Post Office; and (c) the Settlement Administrator shall update addresses based on information it receives and through any requests received from Persons in the Settlement Class. d. If any Short Form/Postcard Notice sent under this Section is returned by the Postal Service as undeliverable, the Settlement Administrator shall re-mail the Short Form/Postcard Notice once to the forwarding address, if any, provided by the Postal Service on the face of the returned mail. Other than as set forth in this paragraph, neither the Parties nor the Settlement Administrator shall have any other obligation to re-mail the Short Form/Postcard Notice. e. The Settlement Administrator shall have discretion to format the Short Form/Postcard Notice and Claim Form in a reasonable manner to minimize mailing or administrative costs. Before the Short Form/Postcard Notices are mailed, Class Counsel and Counsel for Defendant shall first be provided with a proof copy of all forms of Notice (including what the items will look like in their final form), and shall have the right to inspect the same for compliance with the Settlement Agreement and with any orders by the Court. f. No later than thirty (30) days following the entry of the Preliminary Approval Order, the Settlement Administrator shall cause the Long Form Notice, a downloadable Claim Form that may be printed and mailed to the Settlement Administrator, an electronic version of the Claim Form that may be completed and submitted electronically, this Settlement Agreement, the Complaint, the Preliminary Approval Order, and any other relevant documents to be made available on a dedicated Settlement Website, the website name/URL for which is to be agreed upon by the Parties, to be administered by the Settlement Administrator. When available, the Settlement Administrator shall make available on the Settlement Website Class Counsel’s application for a Fee Award and any motion seeking approval of any Incentive Award as well as the Final Approval Order. Any other content proposed to be included or displayed on the Settlement Website shall be approved in advance by Class Counsel and Defendant’s Counsel. Such approvals shall not be unreasonably withheld. g. Within thirty (30) days after entry of the Preliminary Approval Order, the Settlement Administrator shall set up a toll-free telephone number that will provide automated information about the Settlement, the Settlement Class Members’ rights, important deadlines, and instructions as to how Settlement Class Members may make claims. That telephone number shall be maintained until the Claims Deadline. After that time, and through the date the Final Approval Order is entered, a recording will advise any caller to the toll free telephone number that the Claims Deadline has passed and that details regarding the Settlement may be reviewed on the Settlement Website. x. Xxxxxx and the Settlement Administrator shall be responsible for timely compliance with any notice required by the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1715. Xxxxxx shall provide proof of such compliance by filing a confirmation declaration with the Court at least fourteen (14) days prior to the Final Approval Hearing. i. Claim Forms shall be returned or submitted to the Settlement Administrator via U.S. Mail or via submission through the Settlement Website, by the Claims Deadline or be forever barred.

Notice Plan and Claim Form. a. The Parties agree to will provide Notice using the best Notice that is practicable under the circumstances, including individual notice to Persons most recent mailing address in the MCM’s records for each Settlement Class who may be identified through reasonable effortsMember. b. The Parties shall provide the Settlement Administrator with the Class List. The Settlement Administrator shall use the Class List to take all steps reasonably necessary, including reverse phone look-ups of the phone numbers using a historical lookup approach, to identify the owners of the numbers in the Class List together with such Persons’ last known mailing addresses. After identifying mailing addresses through this process, the Settlement Administrator shall, by using the National Change of Address (“NCOA”) database maintained by the United States Postal Service (“Postal Service”), obtain updated mailing addresses, if available. c. Within thirty (30) days following entry of the Preliminary Approval Order, the Settlement Administrator shall send the Short Form/Postcard Notice to each Class Member via first class mail for those Class Members for whom a mailing address has been obtained. Neither the Parties nor the Settlement Class Administrator shall have any obligation to mail the Short Form/Postcard Notice to any Settlement Class Member for whom no mailing address could be locatedmail. To the extent deemed necessary by the Settlement Administrator, the last known address of Persons in the Settlement Class will be subject to confirmation or updating as follows: (a) the Settlement Administrator may conduct a reasonable search to locate an updated address for any Person in the Settlement Class whose Short Form/Postcard Notice is returned as undeliverableClass; (b) the Settlement Administrator shall update addresses based on any forwarding information received from the United States Post Office; and (c) the Settlement Administrator shall update addresses based on information it receives and through any requests received from Persons in the Settlement Class. d. If any Short Form/Postcard Notice sent under this Section is returned by the Postal Service as undeliverable, the Settlement Administrator shall re-mail the Short Form/Postcard Notice once to the forwarding address, if any, provided by the Postal Service on the face of the returned mail. Other than as set forth in this paragraph, neither the Parties nor the Settlement Administrator shall have any other obligation to re-mail the Short Form/Postcard Notice. e. The Settlement Administrator shall have discretion to format the Short Form/Postcard Notice and Claim Form in a reasonable manner to minimize mailing or administrative costs. Before the Short Form/Postcard Notices or any other communication to Settlement Class Members are mailed, Class Counsel and Counsel for Defendant shall first be provided with a proof copy of all forms of Notice (including what the items will look like in their final form), and shall have the right to inspect the same for compliance with the Settlement Agreement and with any orders by the Court. f. The Settlement Administrator shall have discretion, with the consent and at the direction of Class Counsel and Counsel for MCM, to send any reminder notices to Settlement Class Members during the notice period. Before any reminder notice is mailed, Class Counsel and Counsel for Defendant shall first be provided with a proof copy of all forms (including what the items will look like in their final form), and shall have the right to inspect the same for compliance with the Settlement Agreement and with any orders by the Court. g. No later than thirty (30) days following the entry of the Preliminary Approval Order, the Settlement Administrator shall cause the Long Form Notice, a downloadable Claim Form that may be printed and mailed to the Settlement Administrator, an electronic version of the Claim Form that may be completed and submitted electronically, this Settlement Agreement, the Complaint, the Preliminary Approval Order, and any other relevant documents to be made available on a dedicated Settlement Website, the website name/URL for which is to be agreed upon by the Parties, to be administered by the Settlement Administrator. When available, the Settlement Administrator shall make available on the Settlement Website Class Counsel’s application for a Fee Award and any motion seeking approval of any Incentive Award as well as the Final Approval Order. Any other content proposed to be included or displayed on the Settlement Website shall be approved in advance by Class Counsel and Defendant’s Counsel. Such approvals shall not be unreasonably withheld. g. h. Within thirty (30) days after entry of the Preliminary Approval Order, the Settlement Administrator shall set up a toll-free telephone number that will provide automated information about the Settlement, the Settlement Class Members’ rights, rights and important deadlines, and instructions as to how Settlement Class Members may make claims. That telephone number shall be maintained until the Claims Deadline. After that time, and through the date the Final Approval Order is entered, a recording will advise any caller to the toll toll-free telephone number that the Claims Deadline has passed and that details regarding the Settlement may be reviewed on the Settlement Website. x. Xxxxxx and the Settlement Administrator shall be responsible for timely compliance with any notice required by the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1715. Xxxxxx shall provide proof of such compliance by filing a confirmation declaration with the Court at least fourteen (14) days prior to the Final Approval Hearing. i. Claim Forms shall be returned or submitted to the Settlement Administrator via U.S. Mail or via submission through the Settlement Website, by the Claims Deadline or be forever barred.

Notice Plan and Claim Form. a. The Parties agree to will provide Notice using the best Notice that is practicable under the circumstances, including individual notice to Persons most recent mailing address in the Target’s records for each Settlement Class who may be identified through reasonable effortsMember. b. The Parties shall provide the Settlement Administrator with the Class List. The Settlement Administrator shall use the Class List to take all steps reasonably necessary, including reverse phone look-ups of the phone numbers using a historical lookup approach, to identify the owners of the numbers in the Class List together with such Persons’ last known mailing addresses. After identifying mailing addresses through this process, the Settlement Administrator shall, by using the National Change of Address (“NCOA”) database maintained by the United States Postal Service (“Postal Service”), obtain updated mailing addresses, if available. c. Within thirty (30) days following entry of the Preliminary Approval Order, the Settlement Administrator shall send the Short Form/Postcard Notice to each Class Member via first class mail for those Class Members for whom a mailing address has been obtained. Neither the Parties nor the Settlement Class Administrator shall have any obligation to mail the Short Form/Postcard Notice to any Settlement Class Member for whom no mailing address could be locatedmail. To the extent deemed necessary by the Settlement Administrator, the last known address of Persons in the Settlement Class will be subject to confirmation or updating as follows: (a) the Settlement Administrator may conduct a reasonable search to locate an updated address for any Person in the Settlement Class whose Short Form/Postcard Notice is returned as undeliverable; (b) the Settlement Administrator shall update addresses based on any forwarding information received from the United States Post Office; and (c) the Settlement Administrator shall update addresses based on information it receives and through any requests received from Persons in the Settlement Class. d. If any Short Form/Postcard Notice sent under this Section is returned by the Postal Service as undeliverable, the Settlement Administrator shall re-mail the Short Form/Postcard Notice once to the forwarding address, if any, provided by the Postal Service on the face of the returned mail. Other than as set forth in this paragraph, neither the Parties nor the Settlement Administrator shall have any other obligation to re-mail the Short Form/Postcard Notice. e. The Settlement Administrator shall have discretion to format the Short Form/Postcard Notice and Claim Form in a reasonable manner to minimize mailing or administrative costs. Before the Short Form/Postcard Notices are mailed, Class Counsel and Counsel for Defendant shall first be provided with a proof copy of all forms of Notice (including what the items will look like in their final form), and shall have the right to inspect the same for compliance with the Settlement Agreement and with any orders by the Court. f. No later than thirty (30) days following the entry of the Preliminary Approval Order, the Settlement Administrator shall cause the Long Form Notice, a downloadable Claim Form that may be printed and mailed to the Settlement Administrator, an electronic version of the Claim Form that may be completed and submitted electronically, this Settlement Agreement, the Complaint, the Preliminary Approval Order, and any other relevant documents to be made available on a dedicated Settlement Website, the website name/URL for which is to be agreed upon by the Parties, to be administered by the Settlement Administrator. When available, the Settlement Administrator shall make available on the Settlement Website Class Counsel’s application for a Fee Award and any motion seeking approval of any Incentive Award as well as the Final Approval Order. Any other content proposed to be included or displayed on the Settlement Website shall be approved in advance by Class Counsel and Defendant’s Counsel. Such approvals shall not be unreasonably withheld. g. Within thirty (30) days after entry of the Preliminary Approval Order, the Settlement Administrator shall set up a toll-free telephone number that will provide automated information about the Settlement, the Settlement Class Members’ rights, important deadlines, and instructions as to how Settlement Class Members may make claimsrequest and obtain hard-copy Settlement documents. That telephone number shall be maintained until the Claims Deadline. After that time, and through the date the Final Approval Order is entered, a recording will advise any caller to the toll free telephone number that the Claims Deadline has passed and that details regarding the Settlement may be reviewed on the Settlement Website. x. Xxxxxx and the Settlement Administrator h. Target shall be responsible for timely compliance with any notice required by the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1715. Xxxxxx Target shall provide proof of such compliance by filing a confirmation declaration with the Court at least fourteen (14) days prior to the Final Approval Hearing. i. Claim Forms shall be returned or submitted to the Settlement Administrator via U.S. Mail or via submission through the Settlement Website, by the Claims Deadline or be forever barred.

Notice Plan and Claim Form. a. The Parties agree to provide the best Notice notice that is practicable under the circumstances, including individual notice to Persons in the Settlement Class who may be identified through reasonable efforts. b. The Parties shall Eurtonshall, within fourteen (14) days of entry of the Preliminary Approval Order, provide the Settlement Administrator and Class Counsel with the Class List. The Settlement Administrator shall use the Class List to take all steps reasonably necessary, including reverse phone look-ups of the phone numbers using a historical lookup approach, to identify the owners of the numbers in the Class List together with such Persons’ last known mailing addresses. After identifying mailing addresses through this process, the Settlement Administrator shall, by using the National Change of Address (“NCOA”) database maintained by the United States Postal Service (“Postal Service”), obtain updated mailing addresses, if available. c. Within thirty (30) days following entry of the Preliminary Approval Order, the Settlement Administrator shall send the Short Form/Postcard Form Notice to each Class Member via first class mail for those Class Members for whom a mailing address has been obtained. Neither the Parties nor the Settlement Class Administrator shall have any obligation to mail the Short Form/Postcard Form Notice to any Settlement Class Member for whom no mailing address could be locatedlocated after a diligent search. To If and to the extent deemed necessary by the Settlement Administrator, the last known address of Persons in the Settlement Class will be subject to confirmation or updating as follows: (a) the Settlement Administrator may conduct a reasonable search to locate an updated address for any Person in the Settlement Class whose Short Form/Postcard Form Notice is returned as undeliverable; (b) the Settlement Administrator shall update addresses based on any forwarding information received from the United States Post Office; and (c) the Settlement Administrator shall update addresses based on information it receives and through any requests received from Persons in the Settlement Class. d. If any Short Form/Postcard Form Notice sent under this Section is returned by the Postal Service as undeliverable, the Settlement Administrator shall re-mail the Short Form/Postcard Form Notice once to the forwarding address, if any, provided by the Postal Service on the face of the returned mail. Otherwise, the Settlement Administrator shall attempt to send notice via email. Other than as set forth in this paragraph, neither the Parties nor the Settlement Administrator shall have any other obligation to re-mail the Short Form/Postcard Form Notice. e. The Settlement Administrator shall have discretion to format the Short Form/Postcard Form Notice and Claim Form in a reasonable manner to minimize mailing or administrative costs. Before the Short Form/Postcard Form Notices are mailed, Class Counsel and Counsel for Defendant shall first be provided with a proof copy of any and all forms of Notice notices (including what the items will look like in their final form), and shall have the right to inspect the same for compliance with the Settlement Agreement and with any orders by the Court. f. The Settlement Administrator shall also create and implement a targeted programmatic digital media campaign for publication Internet Notice, as needed to accomplish sufficient reach to comport with due process. A proposed form of such Internet Notice is attached hereto as Exhibit 2. g. No later than thirty twenty-one (3021) days following the entry of the Preliminary Approval Order, the Settlement Administrator shall cause the Long Form Notice, a downloadable Claim Form that may be printed and mailed to the Settlement Administrator, an electronic version of the Claim Form that may be completed and submitted electronically, this Settlement AgreementAgreement and Exhibits, the Complaint, the Preliminary Approval Order, and any other relevant documents to be made available on a dedicated Settlement Website, the website name/URL for which is to be agreed upon by the Parties, to be administered by the Settlement Administrator. When available, the Settlement Administrator shall make available on the Settlement Website Class Counsel’s application for a Fee Award and any motion seeking approval of any Incentive Award as well as the Final Approval Order. Any other content proposed to be included or displayed on the Settlement Website shall be approved in advance by Class Counsel and Defendant’s Counsel. Such approvals shall not be unreasonably withheld. g. Within thirty (30) days after entry of the Preliminary Approval Order, the Settlement Administrator shall set up a toll-free telephone number that will provide automated information about the Settlement, the Settlement Class Members’ rights, important deadlines, and instructions as to how Settlement Class Members may make claims. That telephone number shall be maintained until the Claims Deadline. After that time, and through the date the Final Approval Order is entered, a recording will advise any caller to the toll free telephone number that the Claims Deadline has passed and that details regarding the Settlement may be reviewed on the Settlement Website. x. Xxxxxx and the Settlement Administrator shall be responsible for timely compliance with any notice required by the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1715. Xxxxxx Eurton shall provide proof of such compliance by filing a confirmation declaration with the Court at least fourteen (14) days prior to the Final Approval Hearing. i. Claim Forms shall be returned or submitted to the Settlement Administrator via U.S. Mail or via submission through the Settlement Website, by the Claims Deadline or be forever barred.

Notice Plan and Claim Form. a. The Parties agree to will provide Notice using the best Notice that is practicable under the circumstances, including individual notice to Persons most recent mailing address in Cenlar’s records for each Settlement Class Member as updated by reasonable methods by the Settlement Class who may be identified through reasonable effortsAdministrator. b. The Parties shall provide the Settlement Administrator with the Class List. The Settlement Administrator shall use the Class List to take all steps reasonably necessary, including reverse phone look-ups of the phone numbers using a historical lookup approach, to identify the owners of the numbers in the Class List together with such Persons’ last known mailing addresses. After identifying mailing addresses through this process, the Settlement Administrator shall, by using the National Change of Address (“NCOA”) database maintained by the United States Postal Service (“Postal Service”), obtain updated mailing addresses, if available. c. Within thirty (30) days following entry of the Preliminary Approval Order, the Settlement Administrator shall send the Short Form/Postcard Notice to each Class Member via first class mail for those Class Members for whom a mailing address has been obtained. Neither the Parties nor the Settlement Class Administrator shall have any obligation to mail the Short Form/Postcard Notice to any Settlement Class Member for whom no mailing address could be locatedmail. To the extent deemed necessary by the Settlement Administrator, the last known address of Persons in the Settlement Class will be subject to confirmation or updating as follows: : (a) the Settlement Administrator may conduct a reasonable search to locate an updated address for any Person in the Settlement Class whose Short Form/Postcard Notice is returned as undeliverable; ; (b) the Settlement Administrator shall update addresses based on any forwarding information received from the United States Post Office; and (c) the Settlement Administrator shall update addresses based on information it receives and through any requests received from Persons in the Settlement Class. d. If any Short Form/Postcard Notice sent under this Section is returned by the Postal Service as undeliverable, the Settlement Administrator shall re-mail the Short Form/Postcard Notice once to the forwarding address, if any, provided by the Postal Service on the face of the returned mail. Other than as set forth in this paragraph, neither the Parties nor the Settlement Administrator shall have any other obligation to re-mail the Short Form/Postcard Notice. e. The Settlement Administrator shall have discretion to format the Short Form/Postcard Notice and Claim Form in a reasonable manner to minimize mailing or administrative costs. Before the Short Form/Postcard Notices are mailed, Class Counsel and Counsel for Defendant shall first be provided with a proof copy of all forms of Notice (including what the items will look like in their final form), and shall have the right to inspect the same for compliance with the Settlement Agreement and with any orders by the Court. f. No later than thirty (30) days following the entry of the Preliminary Approval Order, the Settlement Administrator shall cause the Long Form Notice, a downloadable Claim Form that may be printed and mailed to the Settlement Administrator, an electronic version of the Claim Form that may be completed and submitted electronically, this Settlement Agreement, the Complaint, the Preliminary Approval Order, and any other relevant documents to be made available on a dedicated Settlement Website, the website name/URL for which is to be agreed upon by the Parties, to be administered by the Settlement Administrator. When available, the Settlement Administrator shall make available on the Settlement Website Class Counsel’s application for a Fee Award and any motion seeking approval of any Incentive Award as well as the Final Approval Order. Any other content proposed to be included or displayed on the Settlement Website shall be approved in advance by Class Counsel and Defendant’s Counsel. Such approvals shall not be unreasonably withheld. g. Within thirty (30) days after entry of the Preliminary Approval Order, the Settlement Administrator shall set up a toll-free telephone number that will provide automated information about the Settlement, the Settlement Class Members’ rights, important deadlines, and instructions as to how Settlement Class Members may make claimsrequest and obtain hard-copy Settlement documents. That telephone number shall be maintained until the Claims Deadline. After that time, and through the date the Final Approval Order is entered, a recording will advise any caller to the toll free telephone number that the Claims Deadline has passed and that details regarding the Settlement may be reviewed on the Settlement Website. x. Xxxxxx and the Settlement Administrator h. Cenlar shall be responsible for timely compliance with any notice required by the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1715, costs of which will be the responsibility of Cenlar separate from the Settlement Fund. Xxxxxx Cenlar shall provide proof of such compliance by filing a confirmation declaration with the Court at least fourteen (14) days prior to the Final Approval Hearing. i. Claim Forms shall be returned or submitted to the Settlement Administrator via U.S. Mail or via submission through the Settlement Website, by the Claims Deadline or be forever barred.

Notice Plan and Claim Form. a. 63. The Parties agree to will provide Notice using the best Notice that is practicable under the circumstances, including individual notice to Persons most recent mailing address in the Settlement RGS’ records for each Class who may be identified through reasonable effortsMember. b. The Parties 64. RGS shall provide the Settlement Administrator with the Class ListList within five (5) days of entry of the Preliminary Approval Order. The Settlement Administrator shall use the Class List to take all steps reasonably necessary, including reverse phone look-ups of the phone numbers using a historical lookup approach, to identify the owners of the numbers in the Class List together with such Persons’ last known mailing addresses. After identifying mailing addresses through this process, the Settlement Administrator shall, by using the National Change of Address (“NCOA”) database maintained by the United States Postal Service (“Postal Service”), obtain updated mailing addresses, if available. c. 65. Within thirty (3015) days following entry of the Preliminary Approval Order, the Settlement Administrator shall send the Short Form/Postcard Notice to each Class Member via first class mail for those Class Members for whom a mailing address has been obtained. Neither the Parties nor the Settlement Class Administrator shall have any obligation to mail the Short Form/Postcard Notice to any Settlement Class Member for whom no mailing address could be locatedmail. To the extent deemed necessary by the Settlement Administrator, the last known address of Persons in the Settlement Class will be subject to confirmation or updating as follows: (a) the Settlement Administrator may conduct a reasonable search to locate an updated address for any Person in the Settlement Class whose Short Form/Postcard Notice is returned as undeliverable; (b) the Settlement Administrator shall update addresses based on any forwarding information received from the United States Post Office; and (c) the Settlement Administrator shall update addresses based on information it receives and through any requests received from Persons in the Settlement Class. d. 66. If any Short Form/Postcard Notice sent under this Section is returned by the Postal Service as undeliverable, the Settlement Administrator shall re-mail the Short Form/Postcard Notice once to the forwarding address, if any, provided by the Postal Service on the face of the returned mail. Other than as set forth in this paragraph, neither the Parties nor the Settlement Administrator shall have any other obligation to re-mail the Short Form/Postcard Notice. e. 67. The Settlement Administrator shall have discretion to format the Short Form/Postcard Notice and Claim Form in a reasonable manner to minimize mailing or administrative costs. Before the Short Form/Postcard Notices are mailed, Class Counsel and Counsel for Defendant shall first be provided with a proof copy of all forms of Notice (including what the items will look like in their final form), and shall have the right to inspect the same for compliance with the Settlement Agreement and with any orders by the Court. f. 68. No later than thirty fifteen (3015) days following the entry of the Preliminary Approval Order, the Settlement Administrator shall cause the Long Form Notice, a downloadable Claim Form that may be printed and mailed to the Settlement Administrator, an electronic version of the Claim Form that may be completed and submitted electronically, this Settlement Agreement, the Complaint, the Preliminary Approval Order, and any other relevant documents to be made available on a dedicated Settlement Website, the website name/URL for which is to be agreed upon by the Parties, to be administered by the Settlement Administrator. When available, the Settlement Administrator shall make available on the Settlement Website Class Counsel’s application for a Fee Award and any motion seeking approval of any Incentive Award as well as the Final Approval Order. Any other content proposed to be included or displayed on the Settlement Website shall be approved in advance by Class Counsel and Defendant’s Counsel. Such approvals shall not be unreasonably withheld. g. 69. Within thirty fifteen (3015) days after entry of the Preliminary Approval Order, the Settlement Administrator shall set up a toll-free telephone number that will provide automated information about the Settlement, the Settlement Class Members’ rights, important deadlines, and instructions as to how Settlement Class Members may make claimsrequest and obtain hard-copy Settlement documents. That telephone number shall be maintained until the Claims and Objection Deadline. After that time, and through the date the Final Approval Order is entered, a recording will advise any caller to the toll free telephone number that the Claims Deadline has passed and that details regarding the Settlement may be reviewed on the Settlement Website. x. Xxxxxx and the Settlement Administrator shall be responsible for timely compliance with any notice required by the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 171570. Xxxxxx shall provide proof of such compliance by filing a confirmation declaration with the Court at least fourteen (14) days prior to the Final Approval Hearing. i. Claim Forms shall be returned or submitted to the Settlement Administrator via U.S. Mail or via submission through the Settlement Website, by the Claims Deadline or be forever barred.

Notice Plan and Claim Form. a. The Parties agree to will provide Notice using the best Notice that is practicable under the circumstances, including individual notice to Persons most recent mailing address in Citizens’ records for each Settlement Class Member as updated by reasonable methods by the Settlement Class who may be identified through reasonable effortsAdministrator. b. The Parties shall provide the Settlement Administrator with the Class Lista class list. The Settlement Administrator shall use the Class List to take all steps reasonably necessary, including reverse phone look-ups of the phone numbers using a historical lookup approach, to identify the owners of the numbers in the Class List together with such Persons’ last known mailing addresses. After identifying mailing addresses through this process, the Settlement Administrator shall, by using the National Change of Address (“NCOA”) database maintained by the United States Postal Service (“Postal Service”), obtain updated mailing addresses, if available. c. Within thirty (30) days following entry of the Preliminary Approval Order, the Settlement Administrator shall send the Short Form/Postcard Notice to each Class Member via first class mail for those Class Members for whom a mailing address has been obtained. Neither the Parties nor the Settlement Class Administrator shall have any obligation to mail the Short Form/Postcard Notice to any Settlement Class Member for whom no mailing address could be locatedmail. To the extent deemed necessary by the Settlement Administrator, the last known address of Persons in the Settlement Class will be subject to confirmation or updating as follows: : (a) the Settlement Administrator may conduct a reasonable search to locate an updated address for any Person in the Settlement Class whose Short Form/Postcard Notice is returned as undeliverableClass; (b) the Settlement Administrator shall update addresses based on any forwarding information received from the United States Post Office; and (c) the Settlement Administrator shall update addresses based on information it receives and through any requests received from Persons in the Settlement Class. d. If any Short Form/Postcard Notice sent under this Section is returned by the Postal Service as undeliverable, the Settlement Administrator shall re-mail the Short Form/Postcard Notice once to the forwarding address, if any, provided by the Postal Service on the face of the returned mail. Other than as set forth in this paragraph, neither the Parties nor the Settlement Administrator shall have any other obligation to re-mail the Short Form/Postcard Notice. e. The Settlement Administrator shall have discretion to format the Short Form/Postcard Notice and Claim Form in a reasonable manner to minimize mailing or administrative costs. Before the Short Form/Postcard Notices are mailed, Class Counsel and Counsel for Defendant shall first be provided with a proof copy of all forms of Notice (including what the items will look like in their final form), and shall have the right to inspect the same for compliance with the Settlement Agreement and with any orders by the Court. f. No later than thirty (30) days following the entry of the Preliminary Approval Order, the Settlement Administrator shall cause the Long Form Notice, a downloadable Claim Form that may be printed and mailed to the Settlement Administrator, an electronic version of the Claim Form that may be completed and submitted electronically, this Settlement Agreement, the Complaint, the Preliminary Approval Order, and any other relevant documents to be made available on a dedicated Settlement Website, the website name/URL for which is to be agreed upon by the Parties, to be administered by the Settlement Administrator. When available, the Settlement Administrator shall make available on the Settlement Website Class Counsel’s application for a Fee Award and any motion seeking approval of any Incentive Award as well as the Final Approval Order. Any other content proposed to be included or displayed on the Settlement Website shall be approved in advance by Class Counsel and Defendant’s Counsel. Such approvals shall not be unreasonably withheld. g. Within thirty (30) days after entry of the Preliminary Approval Order, the Settlement Administrator shall set up a toll-free telephone number that will provide automated information about the Settlement, the Settlement Class Members’ rights, important deadlines, and instructions as to how Settlement Class Members may make claimsrequest and obtain hard-copy Settlement documents. That telephone number shall be maintained until the Claims Deadline. After that time, and through the date the Final Approval Order is entered, a recording will advise any caller to the toll free telephone number that the Claims Deadline has passed and that details regarding the Settlement may be reviewed on the Settlement Website. x. Xxxxxx and the Settlement Administrator shall be responsible for timely compliance with any notice required by the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1715. Xxxxxx shall provide proof of such compliance by filing a confirmation declaration with the Court at least fourteen (14) days prior to the Final Approval Hearing. i. h. Claim Forms shall be returned or submitted to the Settlement Administrator via U.S. Mail or via submission through the Settlement Website, by the Claims Deadline or be forever barred.