Common Contracts

EXHIBIT A

Settlement Agreement • May 30th, 2018 • New York

• Contract Type
  Settlement Agreement
• Filed
  May 30th, 2018
• Jurisdiction
  New York

This Settlement Agreement (“Agreement”) is made and entered into as of this 26th day of May, 2018, by and among (i) Plaintiffs, as defined in Section I.GG below (collectively, “Plaintiffs”), on behalf of themselves and the Settlement Class, as defined below; (ii) Defendants Samsung Electronics America, Inc. (“SEA”) and Samsung Electronics Co., Ltd. (“SEC”) (together, “Defendants”); and (iii) Defendants Best Buy Co., Inc., The Home Depot, Inc., Home Depot U.S.A., Inc., Lowe’s Companies, Inc., Lowe’s Home Centers, LLC, and Sears Holdings Corporation (collectively, “Retailer Defendants”) to settle, fully and finally, all of the claims that have been brought in this class-action lawsuit on behalf of Plaintiffs and the Settlement Class against Defendants and Retailer Defendants relating to certain washing machines described below. Plaintiffs, Defendants, and Retailer Defendants are collectively referred to herein as the “Parties.”