| Candidate Information | | Title | Settlement Class | | Target Location | US-PA-Hanover |
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SETTLEMENT AGREEMENT AND RELEASEThis Settlement Agreement and Release (the Agreement) is made and effective as of __0D B_ (the Settlement Date), by and between (a) Apple Inc., a California corporation with offices at 1 Apple Park Way, Cupertino, California 95014, (Apple); and (b) Plaintiffs Lisa Tabak, DeJhontai Banks, Matthew White, Kelly Camelo-Cenicola, Nestor Trujillo, and Christine Clemence (Plaintiffs or Named Plaintiffs or Class Representatives), individually and as representatives of the Settlement Class as defined below, (collectively, theParties) in accordance with the terms and conditions set forth below. DEFINITIONSAs used herein, the following terms have the meanings set forth below: 1. Apple Counsel shall mean Apples counsel of record in this Lawsuit. 2. Attorneys Fees and Expense Award shall mean the amount of attorneys fees and reimbursement of costs and expenses awarded to Class Counsel by the Court from the Settlement Fund.3. Class Representatives or Plaintiffs or Named Plaintiffs means Lisa Tabak, DeJohntai Banks, Matthew White, Kelly Camelo-Cenicola, Nestor Trujillo, and Christine Clemence.4. Class Payment shall mean the share of the Net Settlement Fund provided to each Settlement Class Member pursuant to the Plan of Allocation described herein. 5. Complainant shall mean Class Members who complained to Apple about a Covered Issue, but who did not pay out of pocket to Apple for a repair or replacement for that issue.6. Covered Issue(s) shall mean issues reported to Apple regarding the iPhone 7 and iPhone 7 Plus reflected in Apples records as Sound-Speaker, Sound-Microphone, Sound Receiver, Unexpected Restart / Shutdown, or Power On Device Unresponsive. 7. Effective Date shall mean the first day after which all of the following events and conditions of this Settlement Agreement have occurred or have been met: (a) the Court has entered a Final Approval Order approving the Settlement, and (b) the Court has entered judgment that has become final (Final) in that the time for appeal or writ of certiorari has expired or, if an appeal or writ of certiorari is taken and the Settlement is affirmed, the time period during which further petition for hearing, appeal, or writ of certiorari can be taken has expired. In the event of an appeal or other effort to obtain review, the Parties may agree jointly in writing to deem the Effective Date to have occurred; however, there is no obligation to agree to advance the Effective Date. Any order or proceeding relating to the application for an Attorneys Fee and Expense Award and Service Awards, the pendency of any such application, or any appeal from any such order, shall not operate to terminate or cancel this Settlement Agreement, or affect or delay the finality of any judgment approving the settlement.Case 4:19-cv-02455-JST Document 171-2 Filed 05/25/23 Page 2 of 56 CONFIDENTIAL DRAFT/SETTLEMENT COMMUNICATION - EVIDENCE CODE SECTION 1152 28. Escrow Account means an interest-bearing escrow account at Huntington National Bank that receives the Gross Settlement Amount and is administered by the Settlement Administrator.9. Final Approval Hearing means the hearing at or after which the Court will determine whether to finally approve the Settlement. The Final Approval Hearing must occur at least 35 days after the Objection and Exclusion deadline, on such date as set by the Court. 10. Final Approval Order means the final order to be submitted to the Court in connection with the Final Approval Hearing.11. Final Judgment means the judgment finally approving the Settlement and dismissing with prejudice the claims of the Settlement Class Members. 12. Full Class Notice shall mean the notice that will be posted on the Settlement website and mailed to any member of the Settlement Class who requests a hard copy, substantially in the form attached hereto as Exhibit A.13. Lawsuit shall mean the litigation first filed on May 6, 2019 styled Casillas et. al. v. Apple, Case No. 3:19-cv-02455 (N.D. Cal.), and in which First and Second Amended Complaints were filed styled as Tabak et. al. v. Apple, Case No. 3:19-cv-02455 (N.D. Cal.) and Tabak et. al. v. Apple, Case No. 4:19-cv-02455 (N.D. Cal.) respectively. 14. Net Settlement Fund means the Settlement Fund, reduced by the sum of the following amounts: (1) the costs of notice and the costs of administering the settlement, as set forth in Section F below; and (2) any Attorneys Fees and Expense Award to Class Counsel awarded by the Court, and any Service Award to the Class Representatives awarded by the Court, as set forth in Section G below, and any taxes owed by the Gross Settlement Fund (but not any taxes owed by any individual Settlement Class Counsel, Plaintiffs, or Settlement Class Members). 15. Notice shall mean the email and postcard notices to be distributed to members of the Settlement Class in connection with the Settlement, substantially in the form attached hereto as Exhibits B and C, and as set forth in Section F below, as well as the Full Class Notice substantially in the form attached hereto as Exhibit A, available on the Settlement website and in hard copy upon request.16. Notice Date shall mean the date set forth in the Preliminary Approval Order for commencing the transmission of Email and Postcard Notice. The Notice Date must occur no later than 30 days after Apple transmits the Settlement Class member list to the Settlement Administrator, or on such date as set by the Court. 17. Objection and Exclusion Deadline shall mean the date by which a Settlement Class Member must submit an Objection to this Agreement to the Court or an Opt-Out Form to the Settlement Administrator. The Objection and Exclusion Deadline shall be 105 days after the Notice Date.18. Out of Pocket Payees or OOP Payees shall mean members of the Settlement Class who paid Apple for a repair or replacement for a Covered Issue. Case 4:19-cv-02455-JST Document 171-2 Filed 05/25/23 Page 3 of 56 3SF-502161819. Plaintiffs Counsel or Class Counsel shall mean Gregory F. Coleman, Adam A. Edwards, and William A. Ladnier of Milberg Coleman Bryson Phillips Grossman, PLLC and Andrea R. Gold, Hassan A. Zavareei, and Allison W. Parr of Tycko & Zavareei LLP. 20. Preliminary Approval Order means the order preliminarily approving the settlement and providing for notice to the Settlement Class, the proposed form of which is attached hereto as Exhibit D.21. Response Deadline shall mean the date by which a Settlement Class Member must submit their payment information. The Response Deadline shall be 105 days after the Notice Date.22. Settlement or Settlement Agreement shall mean this agreement and the settlement and release described herein.23. Settlement Administrator shall mean Angeion, an independent settlement administrator, subject to the approval of the Court. 24. Service Award means the award sought by each Class Representativeand subsequently approved by the Courtin consideration for their service during the course of the Lawsuit.25. Settlement Class shall mean individual persons who are United States residents and who own or owned an Apple iPhone 7 or 7 Plus and reported to Apple in the United States Covered Issues, including but not limited to those who paid Apple out of pocket for repairs or replacements for Covered Issues as reflected in Apples records. The Settlement Class excludes Apple; any entity in which Apple has a controlling interest; Apples directors, officers, and employees; Apples legal representatives, successors, and assigns. Also excluded from the Settlement Class are all judicial officers assigned to this case as well as their staff and immediate families. The Class Period shall be September 16, 2016, to January 3, 2023. 26. Settlement Class Member means every member of the Settlement Class who does not validly and timely request exclusion from the Settlement Class. 27. Settlement Date shall mean the date that this Settlement Agreement becomes fully executed.28. Settlement Fund means a non-reversionary cash fund in the amount of$35,000,000.00 to be paid by Apple in accordance with the terms of this Settlement Agreement. RECITALSThis Agreement is made for the following purposes and with reference to the following facts:WHEREAS, a putative class action complaint was filed against Apple on May 6, 2019, in Casillas et. al. v. Apple, Case No. 3:19-cv-02455 (N.D. Cal.), asserting claims for breach of express and implied warranty, negligent misrepresentation, unjust enrichment, and violations of Case 4:19-cv-02455-JST Document 171-2 Filed 05/25/23 Page 4 of 56 CONFIDENTIAL DRAFT/SETTLEMENT COMMUNICATION - EVIDENCE CODE SECTION 1152 4the Magnuson-Moss Warranty Act, the Song-Beverly Consumer Warranty Act, and California consumer protection statutes; a First Amended Complaint was filed on July 25, 2019 adding certain named Plaintiffs and claims and removing Mr. Casillas (Tabak et. al. v. Apple, Case No. 3:19-cv-02455 (N.D. Cal.)), which Apple moved to dismiss; a Second Amended Complaint was filed on February 20, 2020 (Tabak et. al. v. Apple, Case No. 4:19-cv-02455 (N.D. Cal.)), adding Plaintiff Clemence, which Apple moved to dismiss. The Court granted-in-part and denied-in-part Apples Motion to Dismiss the Second Amended Complaint on November 25, 2020 (ECF 90); WHEREAS, Plaintiffs sought to represent a nationwide class of All persons or entities in the United States that purchased an Apple iPhone 7 or 7 Plus or, in the alternative, five state subclasses of persons or entities in California, Illinois, New York, Florida, and Tennessee that purchased an Apple iPhone 7 or 7 Plus;WHEREAS, the Parties have investigated the facts and analyzed the relevant legal issues regarding the claims and defenses asserted in this Lawsuit, including through significant motion practice and extensive fact and expert discovery;WHEREAS, no litigation class has been certified in the Lawsuit; WHEREAS, the parties conducted a mediation with Randall Wulff in November 2022 and continued to discuss settlement thereafter;WHEREAS, Plaintiffs are represented by Andrea R. Gold, Hassan A. Zavareei, and Allison W. Parr of Tycko & Zavareei LLP, and Gregory F. Coleman, Adam A. Edwards, and William A. Ladnier of Milberg Coleman Bryson Phillips Grossman, PLLC. WHEREAS, Plaintiffs Counsel currently have no other clients who claim to have experienced the alleged audio issues in iPhone 7 or 7 Plus that are the subject of the Lawsuit and who have expressed interest in filing claims related to the alleged audio issues in iPhone 7 or 7 Plus;WHEREAS, Apple disputes Plaintiffs contentions, denies any legal violation or liability, and continues to deny that Plaintiffs claims and allegations would be suitable for class action status;WHEREAS, to avoid further costs of litigation, and without admitting liability, Apple and Plaintiffs, individually and as representatives of the Settlement Class as defined below,(collectively, the Parties) now wish to settle the Lawsuit in its entirety as to the Plaintiffs, the Settlement Class Members, and Apple with respect to all claims arising out of the facts underlying the Lawsuit. The Parties intend this Agreement to bind Plaintiffs (both as the Class Representatives and individually), Apple, Class Counsel, and Settlement Class Members. NOW, THEREFORE, for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, and intending to be legally bound hereby, the Parties agree as follows:Case 4:19-cv-02455-JST Document 171-2 Filed 05/25/23 Page 5 of 56 5SF-5021618TERMSA. Confidentiality1. The Parties, Class Counsel, and Apple Counsel agree that until publication of this Settlement Agreement by submission to the Court, the terms of this Settlement Agreement and all associated documents and communications, including the negotiations leading to the execution of the Settlement Agreement and all submissions and arguments related to the mediation proceedings, shall not be disclosed by the Parties, Class Counsel, and Apple Counsel other than as necessary to finalize the Settlement and Notice. Upon publication of the Settlement Agreement by submission to the Court, the nondisclosure obligations set forth in this paragraph will no longer apply to the as-filed Settlement Agreement or the terms thereof, but such obligations will continue to apply to all other materials and information covered by this paragraph, including but not limited to any negotiations leading to the execution of this Settlement Agreement. 2. Other than to a court in any case filing, the Parties, Class Counsel, and Apple Counsel agree not to initiate publicity regarding the settlement or submit information about the settlement to Jury Verdicts. Notwithstanding the foregoing, Class Counsel may list the Lawsuit on their law firm websites and publicity materials as a representative case along with a neutral and factual description of the subject matter of the Lawsuit, including the amount of the settlement. Any comments made by Class Counsel concerning the settlement or the Lawsuit, including in response to inquiries from the press, shall be in neutral terms to communicate that the Lawsuit has been resolved between the Parties and shall not contain inflammatory language about the Parties or their perceived conduct in the Lawsuit.3. The Parties will continue to comply with the Stipulated Protective Order in this Action, including with respect to the requirements of Paragraph 13 thereof, which govern the return or destruction of any material produced, submitted, or filed under seal under the Protective Order.4. If, through the actions of any of the Parties or their counsel, this Settlement Agreement and the proposed Settlement become public before the Motion for Preliminary Approval is filed with the Court, the responsible Party or counsel shall pay liquidated damages of Twenty-Five Thousand U.S. Dollars ($25,000.00) to the non-responsible Party. B. Consideration for Settlement and Class Payments 1. Apples total financial commitment under this Agreement shall be $35,000,000.00. Within 45 days after an order granting preliminary approval of this Settlement, Apple shall transfer$35,000,000.00 into the Escrow Account established by the Settlement Administrator for the Settlement Fund. The Settlement Administrator shall agree to hold the Settlement Fund in an interest bearing account and administer the Settlement Fund, subject to the continuing jurisdiction of the Court and from the earliest possible date, as a qualified settlement fund as defined in Treasury Regulation 1.468B-1 et seq. The Settlement Administrator will thereafter manage distribution of the Settlement Fund. Any taxes owed by the Settlement Fund will be paid by the Settlement Administrator out of the Settlement Fund, and interest earned on the balance of the account will accrue to the Settlement Fund.Case 4:19-cv-02455-JST Document 171-2 Filed 05/25/23 Page 6 of 56 CONFIDENTIAL DRAFT/SETTLEMENT COMMUNICATION - EVIDENCE CODE SECTION 1152 62. The Settlement Fund shall be applied as follows: a. To pay the costs of notice and the costs of administering the Settlement, as set forth in Section F below;b. to pay any approved Attorneys Fees and Expense Award to Class Counsel and any Service Award to the Class Representatives, as set forth in Section G below;c. to distribute the Net Settlement Fund to Settlement Class Members as set forth in Section B.4 below.3. The Net Settlement Fund will be distributed according to the following Plan of Allocation. OOP Payees who provide payment information will each receive an equal payment of at least $50 and no more than $349. Complainants who provide payment information will each receive an equal payment of up to $125, but in any event no higher than 75% of the payment amount paid to OOP Payees. Depending on the number of Settlement Class Members who provide payment information, this allocation is subject to modification by agreement of the Parties without further notice to members of the Settlement Class, provided any such modification is approved by the Court. Any such modification will, to the extent practicable, maintain the ratio of payment amounts to Complainants as compared to payment amounts to OOP Payees. 4. Settlement Class Members will be required to provide their payment information by the Response Deadline as a condition of receiving payment under the Settlement. Settlement Class Members may elect to receive their payment by physical check, electronic check, Automated Clearing House (ACH, a/k/a direct deposit). For those Settlement Class Members who provide their payment information, a transfer reflecting their payment shall be transmitted to the Settlement Class Members within 60 calendar days after the Effective Date. 5. To the extent economically feasible, the Settlement Administrator shall follow up and communicate with Settlement Class Members who have not provided their payment information within 60 days of the Notice Date.6. To the extent economically feasible, the Settlement Administrator shall follow up and communicate with Settlement Class Members who have not cashed their checks or whose ACH transfer failed within 60 days of the payments being provided. 7. Following distribution of the Settlement Fund as set forth above, if ACH transfers to Settlement Class Members fail after 120 days or checks attributable to Settlement Class Members remain uncashed after 120 days after the Class Payment is distributed pursuant to Section B.4 above, the funds attributable to those individuals shall be used to pay any unanticipated additional costs of settlement administration as set forth in Section F.6 below. Under no circumstances will settlement funds revert to Apple. 8. In the event that unclaimed funds remain following the distribution of the Settlement Fund as set forth above in B.3 and B.7, the Parties agree to pay the unclaimed funds to a cy pres recipient. Subject to Court approval, the Parties propose Girls Who Code as the cy pres Case 4:19-cv-02455-JST Document 171-2 Filed 05/25/23 Page 7 of 56 7SF-5021618recipient, whose work is closely related to the issues raised by this Lawsuit and/or furthers the objectives of this Settlement Agreement.C. Obtaining Court Approval of the Agreement1. Settlement Class. Solely for the purposes of settlement and the proceedings contemplated herein, the Parties stipulate and agree that Plaintiffs will seek certification of the Settlement Class and appointment of Plaintiffs counsel as Class Counsel, which Apple will not oppose. The certification of the Settlement Class shall be binding only with respect to the Settlement set forth in the Settlement Agreement.2. Class Counsel will draft the motion requesting issuance of the Preliminary Approval Order and will provide that draft to Apple Counsel of record in the Lawsuit at least seven days before filing. The motion shall be written in a neutral manner. Apple will not oppose the motion. Apple may, however, provide feedback concerning the motion, and Class Counsel will meet and confer with Apple in good faith regarding Apples feedback. 3. Upon filing of the motion requesting issuance of the Preliminary Approval Order, Apple will provide timely notice of such motion as required by the Class Action Fairness Act, 28 U.S.C. 1711 et seq.4. In accordance with the schedule set in the Preliminary Approval Order, Class Counsel will draft the motion requesting final approval of the Settlement, the Proposed Final Approval Order and the Proposed Final Judgment, and will provide that draft to Apple Counsel at least seven days prior to filing. The motion shall be written in a neutral manner. Apple may provide feedback concerning the motion, and Class Counsel will meet and confer with Apple in good faith regarding Apples feedback.5. In the event that the Settlement Agreement is not approved, or in the event its approval is conditioned on any modifications (including modifications to the proposed form and method of notice) that are not acceptable to either Party, then (a) this Settlement Agreement shall be null and void and of no force and effect, (b) any payments of the Settlement Fund and any and all interest earned thereon less monies expended toward Settlement administration, shall be returned to Apple within 10 business days from the date the Settlement Agreement becomes null and void, and (c) any release shall be of no force or effect. In such event, the Lawsuit will revert to the status that existed before the Settlement Agreements execution date, the Parties shall each be returned to their respective procedural postures so that the Parties may take such litigation steps that they otherwise would have been able to take absent the pendency of this Settlement, and neither the Settlement Agreement nor any facts concerning its negotiation, discussion, terms or documentation shall be admissible in evidence for any purpose in this Lawsuit or in any other litigation.D. Objections1. Any Settlement Class Member who has not submitted a timely written request for exclusion and who wishes to object to the fairness, reasonableness, or adequacy of the Settlement, or to the requested attorneys fees and expenses or service awards, must comply with the following requirements.Case 4:19-cv-02455-JST Document 171-2 Filed 05/25/23 Page 8 of 56 CONFIDENTIAL DRAFT/SETTLEMENT COMMUNICATION - EVIDENCE CODE SECTION 1152 82. Procedural Requirements. Any objections from Settlement Class Members regarding the proposed Settlement Agreement must be submitted in writing to the Court. If a Settlement Class Member does not submit a timely written objection, the Settlement Class Member will not be able to participate in the Final Approval Hearing. 3. Deadline. Objections must be submitted by the Objection and Exclusion Deadline. a. If submitted through ECF, objections must be submitted on the Objection and Exclusion Deadline by 11:59 p.m. Pacific Time. b. If submitted by U.S. mail, Objections must be postmarked by the Objection and Exclusion Deadline. The date of the postmark on the envelope containing the written statement objecting to the Settlement will be the exclusive means used to determine whether an Objection and/or intention to appear has been timely submitted. In the event a postmark is illegible or unavailable, the date of mailing will be deemed to be three days prior to the date that the Court posts the objection on the electronic case docket. 4. Mandatory Content. All Objections must be in writing and must: a. Include the full name, address, telephone number, and email address of the objector and any counsel representing the objector; b. Clearly identify the case name and number: Tabak et. al. v. Apple, Case No. 4:19-cv-02455;c. Include information sufficient to verify that the objector is a Settlement Class Member;d. State whether the Objection applies only to the objector, to a specific subset of the class, or to the entire class;e. State the grounds for the Objection; andf. Be personally signed and dated by the objector. 5. Settlement Class Members who fail to submit timely written Objections in the manner specified above shall be deemed to have waived any objections and shall be foreclosed from making any objection to the Agreement and the proposed Settlement by appearing at the Final Approval Hearing, or through appeal, collateral attack, or otherwise. 6. Any objector who timely submits an Objection has the option to appear and request to be heard at the Final Approval Hearing, either in person or through the objectors counsel. Any objector wishing to appear and be heard at the Final Approval Hearing must include a Notice of Intention to Appear in the body of the objectors Objection. If an objector makes an Objection through an attorney, the objector shall be solely responsible for the objectors attorneys fees and expenses. Counsel for any objector seeking to appear at the Final Approval Hearing must enter a Notice of Appearance no later than 14 days before that hearing. Case 4:19-cv-02455-JST Document 171-2 Filed 05/25/23 Page 9 of 56 9SF-50216187. At no time shall any of the Parties or their counsel seek to solicit or otherwise encourage Class Members to submit written Objections to the Settlement or encourage an appeal from the Courts Final Approval Order.8. A Settlement Class member who objects to the Settlement may also submit payment information, which shall be processed in the same manner as all other payment information.9. The Class Representatives, Class Counsel, and/or Apple may file responses to any timely written Objections no later than seven (7) days prior to the Final Approval Hearing. E. Exclusions.1. Requests for Exclusion. The email and postcard Notices, as well as the Full Class Notice, will advise all members of the Settlement Class of their right to exclude themselves from the Settlement. This Settlement Agreement will not bind members of the Settlement Class who exclude themselves from the Settlement.2. Requesting Process. To request to be excluded from the Settlement, members of the Settlement Class must timely submit a written request for exclusion. The request for exclusion may be sent either through a portal on the Settlement Website or by U.S. mail to the Settlement Administrator, which will be responsible for receiving and processing requests for exclusion. The request for exclusion must include the Settlement Class Members name, address, and telephone number, be personally signed and dated by the Settlement Class Member; and contain a clear request that the individual would like to opt out or be excluded, by use of those or other words clearly indicating a desire not to participate in the Settlement. 3. Deadline. To be excluded from the Settlement, the request for exclusion must be postmarked or submitted through the portal by the Objection and Exclusion Deadline. 4. If a Settlement Class member submits both payment information and an exclusion request, the payment information submission shall take precedence and be considered valid and binding, and the exclusion shall be deemed to have been sent by mistake and rejected. 5. Effect of Exclusion. Any person who is a member of the Settlement Class and who validly and timely requests exclusion from the Settlement shall not be a Settlement Class Member; shall not be bound by the Agreement; shall not be eligible to apply for or receive any benefit under the terms of the Agreement; and shall not be entitled to submit an objection to the Settlement. 6. Exclusion List. No later than 14 days after the Objection and Exclusion Deadline, the Settlement Administrator will provide Class Counsel and Apple Counsel with the number of persons who have timely and validly excluded themselves from the Settlement. If the number of Settlement Class Members who elect to exclude themselves from the Settlement Class exceeds the threshold agreed to by the Parties and confidentially submitted to the Court in camera, Apple, in its sole discretion, may elect to reject this Settlement, in which case the entire Agreement shall be null and void. Alternatively, Apple may elect to waive this condition and proceed with the Settlement. Any such waiver by Apple must be unambiguous and in writing. Case 4:19-cv-02455-JST Document 171-2 Filed 05/25/23 Page 10 of 56 CONFIDENTIAL DRAFT/SETTLEMENT COMMUNICATION - EVIDENCE CODE SECTION 1152 10F. Notice and Settlement Administration1. Notice and Settlement administration will be performed by Angeion, subject to approval by the Court. The Settlement Administrator will be paid from the Settlement Fund. 2. The Settlement Administrator shall perform the duties, tasks, and responsibilities associated with providing notice and administering the Settlement, including the following: (a) preparing and disseminating notice to the Settlement Class substantially in the forms attached hereto as Exhibits A-C; (b) maintaining the Settlement Website; (C) keeping track of requests for exclusion and objections to the Settlement, including maintaining the original envelope in which they were mailed (or an electronic copy thereof); (d) deliver to Apple Counsel and Class Counsel copies of any requests for exclusion, objections, or, upon request of Apple Counsel or Class Counsel, other written or electronic communications from the Settlement Class; (e) making distributions to Settlement Class Members; (f) performing any tax reporting duties required by this Agreement and federal, state, or local law; (g) maintaining adequate records of all its activities, including the dates of transmission of the postcard notice, Full Class Notice, and email notice, returned mail, and other communications and attempted written or electronic communications with the Settlement Class; (h) confirming in writing its completion of the administration of the Settlement; and (i) such other tasks as Apple Counsel and Class Counsel mutually agree. 3. Apple will provide to the Settlement Administrator (but not to Class Counsel) the names, last known mailing addresses, and email addresses for all members of the Settlement Class for whom it has records as soon as practicable but starting no later than thirty (30) days after entry of the Preliminary Approval Order. The Settlement Administrator will administer the notice described herein and in accordance with the Preliminary Approval Order. The Settlement Administrator will keep identities and contact information of members of the Settlement Class strictly confidential, using them only for purposes of administrating this Settlement. 4. Notice will be provided via email to members of the Settlement Class for whom Apple has an email address, and via direct mail postcard |
