CLASS ACTION SETTLEMENT AGREEMENTSouth Carolina • December 14th, 2020
Jurisdiction FiledDecember 14th, 2020This Agreement is made between the Named Plaintiffs, on behalf of themselves and a proposed Settlement Class, and Plycem USA, LLC and Elementia USA, Inc. The purpose of this Agreement is to settle and compromise the Litigation and to release the Released Persons as set forth herein. The Agreement is contingent upon the Court’s certification of the Settlement Class and approval of the Settlement under Federal Rule of Civil Procedure 23. (Capitalized terms in this Agreement have specific definitions, which are provided in Section 1.)