Statement of Plaintiffs’ Recovery. Subject to Court approval, the Settlement will result in the creation of a cash settlement fund in the principal amount of $486,000,000, plus any interest that may accrue thereon (the “Settlement Fund”). A portion of the Settlement Fund will be used to pay for, among other things, the expense of class notice and administration of the Settlement, taxes and tax-related expenses, Court-awarded attorneys’ fees and expenses to Plaintiffs’ Counsel and Court-awarded reimbursement of costs and expenses to Plaintiffs. The balance of the Settlement Fund will be available for distribution to Class Members who submit valid and timely Claim Forms, according to a Court-approved plan of allocation. The plan of allocation being proposed by Plaintiffs and Lead Counsel (the “Plan of Allocation”) is set forth in Appendix A hereto. Based on Plaintiffs’ damages expert’s estimate of the number of shares of Pfizer common stock purchased during the Class Period that may have been affected by the conduct at issue in the Action, and assuming that all Class Members elect to participate in the Settlement, the estimated average recovery (before deduction of any Court-approved fees, expenses and costs (as described herein) is $0.13 per affected share of Pfizer common stock. You should note, however, that the foregoing average recovery per share is only an estimate. Your recovery from the Settlement will depend on a number of things, such as the number of shares of Pfizer common stock you purchased or otherwise acquired during the period between and including October 31, 2000 and December 16, 2004, and the timing of your purchases, acquisitions and any sales, at what prices such shares were purchased, acquired or sold, and the total number of valid Claim Forms submitted.
Statement of Plaintiffs’ Recovery. Pursuant to the proposed Settlement with the remaining Defendants in the Action, Lead Plaintiffs, on behalf of the proposed Settlement Class, have agreed to settle all claims related to the purchase or acquisition of Colonial Securities during the Class Period that were or could have been asserted against Defendants and Tolled Defendants, in exchange for a payment of $7,900,000 in cash (the “Settlement Amount”), which will be deposited into an interest-bearing escrow account (the “Settlement Fund”). Based on Lead Plaintiffs’ estimate of the number of Colonial Securities that may have been damaged during the Class Period and assuming that all those securities participate in the Settlement, Lead Counsel estimates that the average recovery would be approximately $0.02 per allegedly damaged share of common stock and $0.14 per allegedly damaged note, before the deduction of Court-approved attorneys’ fees and expenses, Taxes, and Notice and Administration Expenses. Settlement Class Members should note, however, that this is only an estimate based on the overall number of potentially damaged securities purchased by the Settlement Class. Some Settlement Class Members may recover more or less than this estimated amount depending on, among other factors, when their security was purchased, the type of security purchased, and the prices at which the security was purchased or sold. The Net Settlement Fund (the Settlement Fund less Taxes, Notice and Administration Expenses, and attorneys’ fees and litigation expenses awarded) will be distributed in accordance with a plan of allocation (the “Plan of Allocation”) approved by the Court that will determine how the Net Settlement Fund shall be allocated to the members of the Settlement Class. The proposed Plan of Allocation is included in this Notice (see page below).
Statement of Plaintiffs’ Recovery. Pursuant to this proposed Settlement, a Settlement Fund consisting of $265 million in cash, plus any accrued interest, has been established. Based on Plaintiffs’ consulting expert’s estimate of the number of shares of common stock entitled to participate in the Settlement, and assuming that all such shares entitled to participate do so, Plaintiffs’ consulting expert estimates that the average recovery per allegedly damaged share of Xxxxxx common stock would be approximately $3.34 per share, before deduction of Court-approved expenses, such as attorneys’ fees and expenses and administrative costs.2 A Settlement Class Member’s actual recovery will be a portion of the Net Settlement Fund, determined by comparing his, her, or its “Recognized Loss” to the total Recognized Losses of all Settlement Class Members who submit acceptable Proofs of Claim. An individual Settlement Class Member’s actual recovery will depend on, for example: (i) the total number of claims submitted; (ii) when the Settlement Class Member purchased or acquired the common stock of Xxxxxx during the Class Period; (iii) the purchase price paid; and (iv) whether the Xxxxxx common stock was held at the end of the Class Period or sold (and, if sold, when they were sold and the amount received). See the Plan of Allocation beginning on page [ ] for information on your Recognized Loss.
Statement of Plaintiffs’ Recovery. Pursuant to this proposed Settlement, a Settlement Fund consisting of $62 million in cash, plus any accrued interest, has been established. Based on Lead Plaintiffs’ estimate of the number of shares entitled to participate in the Settlement, and assuming that all such shares entitled to participate do so, Lead Plaintiffs estimate that the average recovery per damaged share would be approximately: (i) $0.62 per damaged share if you purchased shares of RMH; (ii) $0.58 per damaged share if you purchased shares of RSF; (iii) $0.63 per damaged share if you purchased shares of RMA; or (iv) $0.86 per damaged share if you purchased shares of RHY. 2 Each of these estimates is calculated before deduction of Court-approved expenses, such as attorneys’ fees and expenses and administrative costs. A Class Member’s actual recovery will be a portion of the Net Settlement Fund, determined by comparing his, her, or its “Recognized Claim” to the total Recognized Claims of all Class Members who submit acceptable Proofs of Claim. An individual Class Member’s actual recovery will depend on, for example: (1) the total number of claims submitted; (2) when the Class Member purchased or acquired shares; (3) the purchase price paid; (4) which Closed- End Fund was purchased or acquired; and (5) whether the shares were held at the end of the Class Period (defined below) or sold during the Class Period (and, if sold, when they were sold 2 An allegedly damaged share might have been traded more than once during the Class Period, and the indicated average recovery would be the estimated average for each share that allegedly incurred damages. and the amount received). See the Plan of Allocation beginning on page [ ] for information on your Recognized Claim.
Statement of Plaintiffs’ Recovery. Pursuant to this proposed Settlement, a Settlement Fund consisting of $97.5 million in cash, plus any accrued interest, has been established. Based on Class Representative’s estimate of the number of common shares entitled to participate in the Settlement, and assuming that all such investors entitled to participate do so, Class Representative estimates that the average recovery per allegedly damaged share would be approximately $0.49 per allegedly damaged share (before deduction of any court-awarded fees and expenses, such as attorneys’ fees and expenses and administrative costs) and approximately $0.38 per allegedly damaged share (after deduction of the attorneys’ fees and litigation expenses discussed below).2 A Settlement Class Member’s actual recovery will be a portion of the Net Settlement Fund, determined by comparing his, her, or its “Recognized Loss” to the total Recognized Losses of all Settlement Class Members who submit acceptable Proofs of Claim. An individual Settlement Class Member’s actual recovery will depend on, for example: (1) the total number of claims submitted;
