SETTLEMENT AGREEMENTSettlement Agreement • August 13th, 2021
Contract Type FiledAugust 13th, 2021This Settlement Agreement (“Agreement” or “Settlement Agreement”) is made and entered into this 1_2_ day of August 2021 (“Execution Date”) by ZF TRW Automotive Holdings Corp, ZF Friedrichshafen AG (the successor in interest into which TRW KFZ Ausrüstung GmbH merged), and Lucas Automotive GmbH (now known as ZF Active Safety GmbH) (together, “TRW”) and End-Payor Plaintiff Class Representatives (“End-Payor Plaintiffs”), both individually and on behalf of a class of indirect purchasers of Hydraulic Braking Systems (“Settlement Class”), as more particularly defined in Paragraph 13 below.