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Animation Workers Antitrust Litigation c/o Kurtzman Carson Consultants ("KCC") P.O. Box 40007 College Station, TX 77842-4007 AWU Animation Workers Antitrust Litigation «Barcode»c/o Kurtzman Carson Consultants ("KCC") PostalP.O. Box Service: 40007 Please do not mark barcode College Station, TX 77842-4007 Animation Workers Antitrust Litigation Claim#: AWU-«Claim8» - «CkDig»c/o Kurtzman Carson Consultants (“KCC”) «First1» «Last1» P.O. Box 40007 ID:<<Claim8>> AWU«Addr2» Access Code: <<PIN>> College Station, TX 77842-4007 «Addr1» «Barcode»«City», «St» «Zip» Postal Service: Please do not mark barcode UNITED STATES DISTRICT COURT Claim#: AWU-«Claim8» - «CkDig»FOR THE NORTHERN DISTRICT OF CALIFORNIA «First1» «Last1» ID:<<Claim8>> NOTICE OF PENDENCY OF CLASS ACTION LAWSUIT, «Addr2» PROPOSED SETTLEMENTS, Access Code: <<PIN>> «Addr1» «City», «St» «Zip» FAIRNESS HEARING, AND RIGHT TO APPEAR IMPORTANT INFORMATION – READ CAREFULLY AND DO NOT DISCARD UNITED STATES DISTRICT COURT If you were an employee who held anFOR animation THE NORTHERN or visual effects DISTRICT job title OF at CALIFORNIA Blue Sky Studios, Inc., DreamWorks Animation SKG, Inc., Two Pic MC LLC (f/k/a Image Movers Digital LLC), Lucasfilm, Ltd., LLC, Pixar, Sony Pictures Animation Inc., Sony Pictures Imageworks Inc., orNOTICE The Walt OF Disney PENDENCY Company OF during CLASS the ACTION time periods LAWSUIT set forth, below, an ongoing class action lawsuit may affect your rights, and you could getPROPOSED money from SETTLEMENT settlements withS, two of the multiple defendants in the lawsuit. A court FAIRNESSauthorized this HEARING, Notice. This AND is not RIGHT a solicitation TO APPEAR from a lawyer. This Notice describesIMPORTANT the ongoing lawsuit INFORMATIO and how youN – can READ continue CAREFULLY in that lawsuit AND or D Oexclude NOT DISCARDyourself from that lawsuit. This NoticeIf you alsowere describes an employee settlement who helds with an twoanimation of the defendantsor visual effects and how job titleyou mayat Blue be Skyeligible Studios, to get Inc., money DreamWorks from those Animationsettlements SKG, Inc., Two Pic MC LLC (f/k/a Imageor excludeMovers yourselfDigital LLC), from oneLucasfilm, or both Ltd., of them. LLC, Pixar, Sony Pictures Animation Inc., Sony Pictures Imageworks Inc., or The Walt Disney CompanyBACKGROUND during the time periods set forth below, an ongoing class action lawsuit may affect your rights, and you could get money from settlements with two of the multiple defendants in the lawsuit. The class action lawsuit In re Animation Workers Antitrust Litigation, 14-cv-04062-LHK, claims that Blue Sky Studios, Inc. (“Blue Sky”), DreamWorksA court Animation authorized SKG,this Notice. Inc. ("DreamWorks This is not a solicitation Animation") from, Twoa lawyer. Pic MC LLC (f/k/a ImageMovers This NoticeDigital describes LLC), theLucasfilm, ongoing Ltd.,lawsuit LLC, and Pixar,how you Sony can Pictures continue Animation in that lawsuit Inc. andor exclude Sony Pictures yourself Imageworks from that lawsuit. Inc. (“Sony This Notice alsoPictures”), describes and settlement The Walts withDisney two Company of the defendants (collectively, and howthe “Defendants”) you may be eligible violated to getfederal money and from state th antitrustose settlement laws bys conspiring to suppress compensationor exclude by agreeing yourself not fromto solicit one oreach both other’s of them. employees and by coordinating compensation policies. Defendants deny that they violated any antitrust law or engaged in any wrongdoing. BACKGROUND The Honorable Lucy H. Koh of the United States District Court for the Northern District of California entered an order preliminarilyThe class action approving lawsuit settlementsIn re Animation with Workerstwo of the Antitrust defendants Litigation in the, lawsuit14-cv-04062- Blue- LSkyHK, and claims Sony that Pictures Blue -Sky and Studios, certifying Inc. a Settlement(“Blue Sky”), Class DreamWorks of visual effects Animation and animation SKG, Inc. emp ("DreamWorksloyees who worked Animation") at any Defendant, Two Pic for MC defined LLC periods (f/k/a betweenImageMovers 2001 andDigital 2010 LLC),. Lucasfilm, Ltd., LLC, Pixar, Sony Pictures Animation Inc. and Sony Pictures Imageworks Inc. (“Sony Pictures”), and The Walt Disney Company (collectively, the “Defendants”) violated federal and state antitrust laws by Blueconspiring Sky has to settledsuppress for compensation $5,950,000, and by Sonyagreeing Pictur notes tohas solicit settled each for $13,000,000other’s employees. The remaining and by coordinating defendants (DreamWorkscompensation Animationpolicies. Defenda, Two ntsPic denyMC thatLLC they (f/k/a violated ImageMovers any antitrust Digital law or LLC), engaged Lucasfilm, in any wrongdoing. Ltd., LLC, Pixar, and The Walt Disney Company) have not settled (collectively the “Non-Settling Defendants”). However, if you were an employee for any of the DefendantsThe Honorable listed Lucy above H. andKoh held of thean Unitedanimation States or visualDistrict effects Court job for title the duringNorthern the Districttime period of California listed below, entered you anmay order be entitledpreliminarily to compensation. approving settlements A list of job with titles two is ofattached the defendants in the List in of the Job lawsuit Titles- byBlue Defendant. Sky and Sony Pictures- and certifying a Settlement Class of visual effects and animation employees who worked at any Defendant for defined periods between 2001 Ifand you 2010 are. a Settlement Class Member, you have a right to participate in both Settlements. JudgeBlue Sky Koh has has settled also enteredfor $5,950,000, an order and certifying Sony Pictur a Litigationes has settled Class for of $13,000,000visual effects. Theand remaininganimation defendantsemployees (DreamWorksin the lawsuit whoAnimation worked, Twoat any Pic Defendant MC LLC for (f/k/adefined ImageMovers periods between Digital 2004 LLC), and 2010 Lucasfilm,. This class Ltd., of LLC, employees Pixar, will and continue The Walt the lawsuitDisney againstCompany the) haveNon- Snotettling settled Defendants. (collectively It is the smaller “Non -thanSettling the settlementDefendants c”).lass However, because it if excludes you were employees an employee who for worked any of for the a DefendantDefendants between listed above 2001 and 2003held anbut animation did not work or visualfor a Defendant effects job during title duringthe defined the time periods period between listed 2004 below, and you 2010 may. be Thisentitled is notto compensation. a lawsuit against A list you. of jobYour titles participation is attached inin thisthe Listlawsuit of Job or Tiacceptancetles by Defendant. of money from the Settlements will not affectIf you yourare a employmentSettlement Class status Member, or compensation you have in a rightany way. to participate in both Settlements. Judge Koh has also entered an order certifying a Litigation Class of visual effects and animation employees in the lawsuit who worked at any Defendant for defined periods between1 2004 and 2010. This class of employees will continue the lawsuit against the Non-Settling Defendants. It is smaller than the settlement class because it excludes employees who worked for a Defendant between 2001 and 2003 but did not work for a Defendant during the defined periods between 2004 and 2010. This is not a lawsuit against you. Your participation in this lawsuit or acceptance of money from the Settlements will not affect your employment status or compensation in any way. 1 The purpose of this Notice is to advise you of your rights with respect to the ongoing lawsuit and the two settlements. Please read it carefully. This Notice explains your legal rights and options – and the deadlines to exercise them. Your legal rights will be affected whether you act or don’t act, and you have choices to make now. This Notice is divided into sections that apply to Settlement Class Members or Litigation Class Members or both. Please read all of the Notice carefully, determine whether you are a member of both classes or just the Settlement Class, and then decide whether or not to exercise your rights and options. Summary of Notice for Settlement Class Members You are a Settlement Class Member and are included in the two settlements with Sony Pictures and Blue Sky if you fall within the following definition: All animation and visual effects employees employed by one or more of the Defendants in the United States who held any of the job titles listed in the attached List of Job Titles by Defendant during the following time periods: Pixar (2001-2010), Lucasfilm Ltd., LLC (2001-2010), DreamWorks Animation (2003-2010), The Walt Disney Company (2004-2010), Sony Pictures Animation or Sony Pictures Imageworks (2004-2010), Blue Sky (2005-2010) and Two Pic MC LLC f/k/a ImageMovers Digital LLC (2007-2010). Excluded from the Class are senior executives, members of the board of directors, and persons employed to perform office operation or administrative tasks. You must have been an employee and held one or more of the job titles listed on the attached List of Job Titles by Defendant during the time periods above. You may not know what your job title was. If you have any questions about this, please contact phone number 855-730-8617 or visit the following website: www.animationlawsuit.com. The Court in charge of this case still has to approve the two Settlements. Payment will be made if the Court approves one or both Settlements and orders that the Settlement Funds be distributed. Please be patient. SUMMARY OF YOUR LEGAL RIGHTS AS A SETTLEMENT CLASS MEMBER AND OPTIONS WITH RESPECT TO THE SETTLING DEFENDANTS DO NOTHING You will receive a payment from the Settlements if you are a Settlement Class Member. You will receive money from the Settlements when the funds are distributed and will waive any rights to pursue a lawsuit of your own against Blue Sky or Sony Pictures. You will retain your claims against the other Defendants. EXCLUDE YOURSELF Get no payment from the Settlements. This is the only way you can file FROM ONE OR BOTH OF your own lawsuit or ever be part of any other lawsuit about the claims in this THE SETTLEMENTS case against Blue Sky or Sony Pictures.
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