Notice Plan Under the Amended Settlement Agreement. In addition to the notice components already implemented under the Original Settlement Agreement, the Notice Plan will employ eight additional methods for circulating information about the new proposed settlement under the Amended Settlement Agreement: • sending a New CAFA Notice to the appropriate Federal and State governmental officials; • continuing the operation of the formal Class Settlement Website, for posting various materials relating to the Settlement, including the Amended Settlement Agreement, a New Long-Form Settlement Notice, and instructions and forms for the Interstate Batteries Settlement Program; • purchasing internet keyword and phrase sponsorships related to the Litigation; • posting a hyperlink on Interstate Batteries’ Website that will redirect that customer to the Class Settlement Website as explained below; • distributing press releases to print media in the United States and the District of Columbia; • distributing audio news releases to radio stations in the United States and the District of Columbia; • disseminating handouts, which announce the proposed settlement and the Interstate Batteries Settlement Program, and provide the URL for the Class Settlement Website, by posting an 8½ by 11 inch handout and instruction sheet in Interstate Batteries’ electronic Memo Binder and requesting distributors to print the handout and have their route men deliver the handout to all Interstate Batteries authorized warranty dealers in distributors’ territories; and • directing New Long-Form Settlement Notice (1) to any customer who previously complained to Interstate Batteries about the pro-rata warranty; and (2) to any Settlement Class Member who filed a claim under the Interstate Batteries Settlement Program on or before April 30, 2012, and for whom Interstate Batteries has contact information. Each of the eight methods is further explained below in Sections V.C.2—V.C.9.
