In re Polyurethane Foam
Antitrust Litigation
www.flexiblepolyurethanefoamsettlement.com

FFP, FXI, Future Foam, Hickory Springs, Mohawk, and Woodbridge Direct Purchaser Settlements, and Certification Frequently Asked Questions

The legal notice is to inform you of the Settlements that have been reached. The Class Action lawsuit is known as In re Polyurethane Foam Antitrust Litigation, Case No. 10-md-2196. United States District Judge Jack Zouhary is overseeing this Class Action in the United States District Court for the Northern District of Ohio. You were sent Notice because you have been identified as a customer of one of the Defendants in the lawsuit.

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The Defendants in this case are certain manufacturers of Flexible Polyurethane Foam. Plaintiffs allege that the Defendants conspired to fix, raise, stabilize, or maintain the prices and allocate territories or customers of Flexible Polyurethane Foam. Plaintiffs allege that this conspiracy caused direct purchasers to pay more for Flexible Polyurethane Foam than they would have otherwise paid. Defendants deny Plaintiffs’ conspiracy allegations, that they did anything wrong, and/or that direct purchasers paid more for Flexible Polyurethane Foam than they should have. The Court has not decided who is right

As used herein, “Flexible Polyurethane Foam” includes “slabstock” flexible polyurethane foam (also known as “block” foam), fabricated or converted foam products made from “slabstock” flexible polyurethane foam, and carpet underlay (also known as “carpet cushion,” “carpet pad” or “carpet padding”) manufactured from polyurethane foam. The term Flexible Polyurethane Foam does not include “molded” foam (also known as “engineered” foam) or “rigid” foam (also known as “technical” foam). Flexible Polyurethane Foam is widely used for cushioning and insulation in a wide variety of goods. These include but are not limited to: furniture, mattresses, packaging, flooring, and motor vehicles.

In the late summer and fall of 2010, lawsuits were filed in several federal courts generally claiming a conspiracy to fix prices and allocate territories or customers for Flexible Polyurethane Foam. On December 1, 2010, the Judicial Panel on Multidistrict Litigation transferred those cases for coordinated pre-trial proceedings to the Honorable Jack Zouhary, United States District Judge in the United States District Court for the Northern District of Ohio. On February 28, 2011, Plaintiffs filed their first consolidated complaint claiming a conspiracy to fix Flexible Polyurethane Foam prices and allocate territories or customers that injured direct purchasers of Flexible Polyurethane Foam. Thereafter, by its Class Certification Memorandum Opinion and Order dated April 9, 2014, and its Order dated April 16, 2014, the Court certified the Certification Class, defined as follows:

All persons or entities that purchased flexible polyurethane foam (but excluding molded foam) directly from Defendants and/or their co-conspirators from January 1, 1999 to July 31, 2010 for purchase from or delivery into the United States. Excluded from the Class are governmental entities, Defendants, their co-conspirators, and their officers, employees, agents, representatives, parents, subsidiaries and affiliates.

The deadline for Class Members to exclude themselves from the Certification Class was January 26, 2015.

Defendants Vitafoam Inc. and Vitafoam Products Canada Limited (the “Vitafoam Defendants”); Domfoam International Inc. and Valle Foam Industries (1995) Inc. (the “Domfoam Defendants”); Leggett & Platt, Incorporated (“Leggett & Platt”), and Carpenter Co., E. R. Carpenter, L.P., and Carpenter Holdings, Inc. (collectively, “Carpenter”), previously settled with Plaintiffs. You may have previously received notification of those Settlements. The deadline to file a claim in the Vitafoam Settlement was April 30, 2013. The deadline to file a claim in the Leggett & Platt and Carpenter Settlements was January 26, 2015. If you filed a valid and timely Claim Form in the Vitafoam, Leggett & Platt, and/or Carpenter Settlements, you need not submit a new Claim Form in the Settlements with FFP, FXI, Future Foam, Hickory Springs, Mohawk, or Woodbridge for those same purchases as your claim will automatically be included unless you opt out. Please note that if you previously submitted a Claim Form for purchases of molded foam, these claims are not included in the Settlements and therefore will not be reimbursed.

Plaintiffs (also known as “Class Representatives” or “Representative Plaintiffs”) represent both themselves (the named plaintiffs) and the entire Certification Class of direct purchasers of Flexible Polyurethane Foam in the United States. Plaintiffs brought this lawsuit as a class action because they believe, among other things, that a class action is superior to filing individual cases. They also believe that the claims of each member of the Class present and share common questions of law and fact. By certifying the Certification Class, the Court agreed with the Class Representatives that a class action is superior to filing individual cases. Because the Certification Class has been certified, one court resolves the issues for all Class Members, except for those who excluded themselves from the Certification Class.

Plaintiffs claim that Defendants’ actions violated the Sherman Antitrust Act, a federal statute that prohibits any agreement that unreasonably restrains competition. The alleged agreement was to fix the price of Flexible Polyurethane Foam and allocate territories or customers in the United States from the year 1999 to July 31, 2010. Plaintiffs allege that Defendants and unnamed co-conspirators fixed the price of Flexible Polyurethane Foam through various methods that were all part of a wide-ranging conspiracy. These alleged methods included, but were not limited to, agreements to increase prices by announcing price increases of the same or similar percentages or amounts and at the same or similar time, and to enforce compliance with the conspiracy after each round of price increases by policing each conspirator’s price increase activities. Plaintiffs allege that by collectively agreeing to fix the price increase announcements of Flexible Polyurethane Foam, the Defendants caused prices to be higher than they otherwise would have been. Defendants have vigorously disputed these allegations and have admitted no wrongdoing.

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Plaintiffs are represented by “Class Representatives,” who sue on behalf of those who have similar claims. In this case, the Class Representatives are Ace Foam, Inc.; Adams Foam Rubber Co.; Cambridge of California, Inc.; Foam Factory Inc.; GCW t/a Floors USA; J&S Packaging, Inc.; and VFP Acquisitions, Inc. d/b/a Vanguard Foam & Packaging. All of these persons or entities along with those similarly situated are the “Class” or “Class Members.” The Class Representatives who sued – and all the Class Members like them – are called Plaintiffs.

The companies Plaintiffs sued are called Defendants. All Defendants in this litigation have now settled. Defendants include the Vitafoam Defendants, the Domfoam Defendants, Leggett & Platt, Carpenter, FFP, FXI, Future Foam, Hickory Springs, Mohawk, and Woodbridge. As used herein, the alleged “Co-conspirators” are the following entities that were included as Defendants in Plaintiffs’ consolidated amended complaint, but have since been voluntarily dismissed from the litigation: Ohio Decorative Products, Inc.; Inoac International Co., Ltd.; Inoac USA Inc.; Inoac Corporation; Crest Foam Industries Inc; Louis Carson; and David Carson.

The Court previously stayed in favor of arbitration all claims against Mohawk from customers that directly purchased Flexible Polyurethane Foam (including carpet cushion or carpet underlay) from Mohawk or one of its subsidiaries during the Class Period and had an arbitration agreement with Mohawk or one of its subsidiaries for those purchases. (See Court Order dated August 12, 2014, Docket No. 1311). As part of the Mohawk Settlement, Mohawk has agreed to withdraw its arbitration demand. As a result, despite that order, Plaintiffs’ settlement agreement with Mohawk covers and resolves the claims for those customers who have arbitration agreements with Mohawk or its subsidiaries. Accordingly, Class Members with arbitration agreements with Mohawk or its subsidiaries will be able to recover in the Mohawk Settlement just the same as Class Members who do not have arbitration agreements with Mohawk or its subsidiaries.

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The Certification Class, the FFP Settlement Class, FXI Settlement Class, Future Foam Settlement Class, Hickory Springs Settlement Class, Mohawk Settlement Class, and Woodbridge Settlement Class are defined as follows:

All persons or entities that purchased flexible polyurethane foam (but excluding molded foam) directly from Defendants and/or their co-conspirators from January 1, 1999 to July 31, 2010 for purchase from or delivery into the United States.

If you fall within this definition, you are a member of all of these Classes unless you are excluded as explained below.

Excluded from the Certification Class are governmental entities, Defendants, their alleged co-conspirators, and their officers, employees, agents, representatives, parents, subsidiaries, and affiliates. Also excluded from the Certification Class are those who timely and validly opted out of the Certification Class on or before January 26, 2015, those who were deemed by the Court to have validly opted out of the Certification Class despite an untimely exclusion request (Dkt. 1540), and those who validly and timely elected to exclude themselves from the Certification Class by September 15, 2015.

Excluded from the FFP Settlement Class, FXI Settlement Class, Future Foam Settlement Class, Hickory Springs Settlement Class, Mohawk Settlement Class, and Woodbridge Settlement Class are those who are governmental entities, Defendants, their alleged co-conspirators, and their officers, employees, agents, representatives, parents, subsidiaries, and affiliates. Also excluded from these Settlement Classes are those who timely and validly opted out of the Certification Class on or before January 26, 2015, and those who were deemed by the Court to have validly opted out of the Certification Class despite an untimely exclusion request (Dkt. 1540). In addition, excluded from the six Settlement Classes are those who validly and timely elected to exclude themselves from the Settlement Classes by September 15, 2015.

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No. Nothing in the Notice, or the Court’s order granting class certification of the Certification Class, expresses any opinion by the Court as to the merits of the claims or defenses asserted by any party in the litigation. Instead, the Court has ordered issuance of this Notice to provide the Certification Class and Settlement Classes with important information so you may make an informed decision regarding your legal rights in connection with this litigation.

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The FFP Settlement is among Plaintiffs, the Certification Class, the FFP Settlement Class, and FFP only. In accordance with the terms of the FFP Settlement, Plaintiffs, the Certification Class, and the FFP Settlement Class will release FFP from all claims known and unknown, asserted or un-asserted, arising out of or relating to claims made or which could have been made on the same or similar facts in this case. In exchange, FFP has agreed: (i) to pay $16,000,000 to a fund to compensate FFP Settlement Class Members; and (ii) to provide cooperation with Plaintiffs and the Certification Class in the form of providing witnesses for the purpose of authenticating and/or admitting documents at trial. (FFP has the right to terminate the FFP Settlement if a certain percentage of Class Members exclude themselves from the FFP Settlement Agreement.)

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The FXI Settlement is among Plaintiffs, the Certification Class, the FXI Settlement Class, and FXI only. In accordance with the terms of the FXI Settlement Agreement, Plaintiffs, the Certification Class, and the FXI Settlement Class will release FXI from all claims known and unknown, asserted or un-asserted, arising out of or relating to claims made or which could have been made on the same or similar facts in this case. In exchange, FXI has agreed: (i) to pay $60,000,000 to a fund to compensate FXI Settlement Class Members; and (ii) to provide cooperation with Plaintiffs and the Certification Class in the form of providing witnesses for the purpose of authenticating and/or admitting documents at trial. (FXI has the right to terminate the FXI Settlement if a certain percentage of Class Members exclude themselves from the FXI Settlement Agreement.)

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The Future Foam Settlement is among Plaintiffs, the Certification Class, the Future Foam Settlement Class, and Future Foam only. In accordance with the terms of the Future Foam Settlement Agreement, Plaintiffs, the Certification Class, and the Future Foam Settlement Class will release Future Foam from all claims known and unknown, asserted or un-asserted, arising out of or relating to claims made or which could have been made on the same or similar facts in this case. In exchange, Future Foam has agreed: (i) to pay $32,000,000 to a fund to compensate Future Foam Settlement Class Members, with $25,000,000 already paid to the fund and $7,000,000 to be paid on or before March 20, 2016; and (ii) to provide cooperation with Plaintiffs and the Certification Class in the form of providing witnesses for the purpose of authenticating and/or admitting documents at trial. (Future Foam has the right to terminate the Future Foam Settlement if a certain percentage of Class Members exclude themselves from the Future Foam Settlement Agreement.)

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The Hickory Springs Settlement is among Plaintiffs, the Certification Class, the Hickory Springs Settlement Class, and Hickory Springs only. In accordance with the terms of the Hickory Springs Settlement Agreement, Plaintiffs, the Certification Class, and the Hickory Springs Settlement Class will release Hickory Springs from all claims known and unknown, asserted or un-asserted, arising out of or relating to claims made or which could have been made on the same or similar facts in this case. In exchange, Hickory Springs has agreed: (i) to pay $19,500,000 to a fund to compensate Hickory Springs Settlement Class Members, with $3,000,000 already paid to the fund; $2,500,000 to be paid within 10 days of Final Approval of the Settlement Agreement; $7,000,000 to be paid to the fund on or before January 31, 2016; and $7,000,000 to be paid to the fund on or before January 31, 2017; and (ii) to provide cooperation with Plaintiffs and the Certification Class in the form of providing witnesses for the purpose of authenticating and/or admitting documents at trial. (Hickory Springs has the right to terminate the Hickory Springs Settlement if a certain percentage of Class Members exclude themselves from the Hickory Springs Settlement Agreement.)

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The Mohawk Settlement is among Plaintiffs, the Certification Class, the Mohawk Settlement Class, and Mohawk only. In accordance with the terms of the Mohawk Settlement, Plaintiffs, Certification Class Members, and Mohawk Settlement Class Members will release Mohawk from all claims known and unknown, asserted or un-asserted, arising out of or relating to claims made or which could have been made on the same or similar facts in this case. In exchange, Mohawk has agreed: (i) to pay $98,000,000 to a fund to compensate Mohawk Settlement Class Members; (ii) to provide cooperation with Plaintiffs and the Certification Class in the form of providing a business records custodian for the purpose of authenticating and/or admitting documents at trial; and (iii) to withdraw its arbitration demand (explained in greater detail below). (Mohawk has the right to terminate the Mohawk Settlement if a certain percentage of Mohawk Settlement Class Members exclude themselves from the Mohawk Settlement Agreement.) At Mohawk’s request, the Court previously stayed in favor of arbitration all claims against Mohawk from customers that directly purchased Flexible Polyurethane Foam (including carpet cushion or carpet underlay) from Mohawk or its subsidiaries and had an arbitration agreement with Mohawk or its subsidiaries for those purchases. (See Court Order dated August 12, 2014, Docket No. 1311). As part of the Mohawk Settlement, Mohawk has agreed to withdraw its arbitration demand. As a result, despite that order, the Mohawk Settlement covers and resolves arbitrable claims in addition to the non-arbitrable claims.

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The Woodbridge Settlement is among Plaintiffs, the Certification Class, the Woodbridge Settlement Class, and Woodbridge only. In accordance with the terms of the Woodbridge Settlement, Plaintiffs will release Woodbridge from all claims known and unknown, asserted or un-asserted, arising out of or relating to claims made or which could have been made on the same or similar facts in this case. In exchange, Woodbridge has agreed: (i) to pay $50,000,000 to a fund to compensate Woodbridge Settlement Class Members, with $9,000,000 already paid to the fund; $9,000,000 to be paid to the fund on or before November 15, 2015; $14,000,000 to be paid to the fund on or before November 15, 2016; and $18,000,000 to be paid to the fund on or before November 15, 2017; and (ii) to provide cooperation with Plaintiffs and the Certification Class in the form of providing witnesses for the purpose of authenticating and/or admitting documents at trial. (Woodbridge has the right to terminate the Woodbridge Settlement if a certain percentage of Class Members exclude themselves from the Woodbridge Settlement Agreement.)

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The Court has approved a plan called a “Plan of Allocation” explaining how the Settlement Funds will be distributed. It explains that Settlement Funds will be distributed among the members of the Settlement Classes on a pro rata basis among those who timely and properly submit a valid Claim Form. A copy of the “Plan of Allocation” can be found on the Court Documents Page.

The amounts to be paid by all the Settling Parties was reduced by attorneys’ fees and reimbursement of litigation expenses, as approved by the Court. This includes administration of the Settlements. The Final Approval Order outlining attorneys' fees and costs and incentive award payments to the Representative Plaintiffs can be found on the Court Documents page.

Settlement Funds were also reduced by incentive awards awarded by the Court to the Representative Plaintiffs and administrative costs. Checks were mailed to eligible Class Members on June 17, 2016.

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If you filed a valid and timely Claim Form in the Vitafoam, Carpenter, and/or Leggett & Platt Settlements, you did not need to submit a new Claim Form in the FFP, FXI, Future Foam, Hickory Springs, Mohawk, and Woodbridge Settlements for those same purchases. If you wished to amend your claim to update your Flexible Polyurethane Foam purchase amount, you could have submitted an amended Claim Form. If you did not previously submit a Settlement Claim Form, you must have filed a Claim Form by September 15, 2015 to receive payment from the Settlements.

The Claim Form was mailed to known members of the Certification Class and the proposed Settlement Classes.

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You do not need to request exclusion from the Settlement Classes or Certification Class if you previously requested exclusion from the Certification Class by the January 26, 2015 deadline, and/or were deemed by the Court to have validly opted out of the Direct Purchaser Class despite an untimely exclusion request (Dkt. 1540). If you previously excluded yourself from the Certification Class, you are automatically excluded from all six Settlements and all six Settlement Classes.

If you are a member of the Settlement Classes and you did not wish to participate in all or some of the six Settlements described above, you may have requested exclusion from all or some of the Settlements. If you want to bring your own lawsuit against any of the Defendants, you must have requested exclusion from the applicable Settlement(s) and the Certification Class.

If you qualify as a member of all of the Settlement Classes, and the Court includes you in these Classes, you will be excluded from pursuing any of the Released Claims against FFP, FXI, Future Foam, Hickory Springs, Mohawk, and Woodbridge in any other litigation. If you continue as a member of only some of the Settlement Classes, and you have opted out of the Certification Class, you will be excluded from pursuing any of the Released Claims against the Defendants from whose Settlements you have not excluded yourself.

Your request for exclusion must have been sent by first-class mail postmarked by September 15, 2015 to the appropriate address below:

In re Polyurethane Foam Antitrust Litigation
c/o GCG
P.O. Box 9907
Dublin, OH 43017-5807

If by pre-paid delivery service to be hand-delivered by September 15, 2015:

In re Polyurethane Foam Antitrust Litigation
c/o GCG
1531 Utah Avenue South, Suite 600
Seattle, WA 98134

Your written request should have specified the Class(es) from which you wished to be excluded. You should not have requested exclusion from any of the Settlements in which you wished to participate. All exclusion requests must have included your name, address, telephone number, and signature.

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The Certification Class and Settlement Classes are represented by the following attorneys:
William A. Isaacson
BOIES, SCHILLER & FLEXNER LLP
5301 Wisconsin Avenue, NW
Washington, DC 20015

Stephen R. Neuwirth
QUINN EMANUEL URQUHART & SULLIVAN, LLP
51 Madison Avenue, 22nd Floor
New York, NY 10010

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The attorneys and their law firms that have represented Plaintiffs in this case, are referred to as Class Counsel. The attorneys’ fees for which Class Counsel was granted is to compensate for their time, and the risk they assumed, in prosecuting the litigation on a wholly contingent fee basis. The Court awarded 20% of the total cash amount paid by FFP, FXI, Future Foam, Hickory Springs, Mohawk, and Woodbridge pursuant to the Settlements, as well as the costs and expenses incurred.

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If you qualified as a member of the Settlement Classes as addressed in the Notice and you wished to participate in the Settlements, but you objected to or otherwise wanted to comment on any term of the Settlements (including the request for attorneys’ fees), you must have filed your objection or comments with the Court in writing. In order for the Court to have considered your objection, your objection must have been sent by first-class mail postmarked by, or pre-paid delivery service to be hand-delivered by, September 15, 2015 to each of the following:



The Court:
United States District Court
James M. Ashley and Thomas W. L. Ashley U.S. Courthouse
1716 Spielbusch Avenue
Toledo, OH 43604

Counsel for FFP:
Larry A. Mackey
Barnes & Thornburg LLP
11 South Meridian Street
Indianapolis, IN 46204

Counsel for FXI:
Michael H. Steinberg, Esq.
Adam S. Paris, Esq.
Sullivan & Cromwell LLP
1888 Century Park East, Suite 2100
Los Angeles, CA 90067

Counsel for Future Foam:
Edward G. Warin
Kutak Rock LLP
1650 Farnam Street
The Omaha Building
Omaha, NE 68102-2186

Counsel for Hickory Springs:
Matthew P. McGuire
Alston & Bird LLP
4721 Emperor Blvd., Suite 400
Durham, NC 27703

Counsel for Mohawk:
Randall Allen
Alston & Bird LLP
1201 West Peachtree Street, NW
Atlanta, GA 30309

Counsel for Woodbridge:
Daniel G. Swanson, Esq.
Gibson, Dunn & Crutcher LLP
333 South Grand Avenue
Los Angeles, CA 90071-3197

Your objection must have set forth your qualifications to be included in the Settlement Class(es) to which you object. The written objection also should have stated the precise reason or reasons for the objection and should also have included any legal support you wished to bring to the Court’s attention and any evidence you wished to introduce in support of the objection. You could have, but were not required to, file the objection through an attorney. You are responsible for any costs incurred in objecting through an attorney. If you are a member of any of the Settlement Classes, you had the right to voice your objection at the Fairness Hearing. In order to do so, you must have followed all instructions stated above for objecting in writing. You may have then objected in person and/or through an attorney. You were responsible for any costs incurred in objecting through an attorney. You did not need to attend the Fairness Hearing in order for the Court to consider your objection.

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The Court held a “Fairness Hearing” on October 9, 2015 at 10:00 a.m., at the following address:

United States District Court
James M. Ashley and Thomas W. L. Ashley U.S. Courthouse
1716 Spielbusch Avenue
Toledo, OH 43604



The purpose of the Fairness Hearing was to determine whether the Settlements are fair, reasonable, and adequate, whether the Court should approve the Settlement Classes, and whether the Court should enter judgment granting final approval of the Settlements. You did not need to attend this hearing. You or your own lawyer may have attended the hearing at your own expense.

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If you did nothing, and you fall within the definition of the Settlement Classes, you will remain a member of the Settlement Classes. As a member of the Settlement Classes, you will be represented by the law firms listed above in the answer to FAQ No. 15. You will not be charged a fee for the services of such counsel and any other Class Counsel. Rather, counsel will be paid, if at all, from some portion of whatever money they may ultimately recover for you and other members of the Settlement Classes. If you want to be represented by your own lawyer, you may hire one at your own expense.

However, you must have submitted a timely Settlement Claim Form (see answer to FAQ No. 13, above) in order to be considered for any monetary benefit from the Settlement Funds.

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The Court has granted Final Approval of the Settlements, meaning the Settlement Terms, as approved by the Court, are binding as to all members of the six Settlement Classes. By remaining part of these Settlement Classes you gave up any claims against FFP, FXI, Future Foam, Hickory Springs, Mohawk, and Woodbridge relating to all claims known and unknown, asserted or un-asserted, arising out of or relating to claims made or which could have been made on the same or similar facts in this case.

Upon final certification of the Settlement Classes, all claims in the Class Action against FFP, FXI, Future Foam, Hickory Springs, Mohawk, and Woodbridge shall be solely those of the Settlement Class.

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For more detailed information concerning matters relating to the Settlements, you may wish to review: the Long-Form Settlement Agreement Between the Direct Purchaser Class and Defendant FFP Holdings, LLC dated May 4, 2015; the Long-Form Settlement Agreement Between the Direct Purchaser Class and Defendant Foamex Innovations, Inc. dated March 27, 2015; the Amendment to Long-Form Settlement Agreement Between the Direct Purchaser Class and Defendant Foamex Innovations, Inc. dated May 8, 2015; the Long-Form Settlement Agreement Between the Direct Purchaser Class and Defendant Future Foam, Inc. dated May 11, 2015; the Long-Form Settlement Agreement Between the Direct Purchaser Class and Defendant Hickory Springs Manufacturing Company dated May 8, 2015; the Long-Form Settlement Agreement Between the Direct Purchaser Class and Defendant Mohawk Industries, Inc. dated May 8, 2015; the Long-Form Settlement Agreement Between the Direct Purchaser Class and Defendants Woodbridge Foam Corporation, Woodbridge Sales & Engineering, Inc., and Woodbridge Foam Fabricating, Inc. dated May 4, 2015; and the Court’s Order entered May 20, 2015. These documents are available on this Settlement Website, in the Court Documents section. These documents and other more detailed information concerning the matters discussed in this Notice may be obtained from the pleadings, orders, transcripts of hearings and other proceedings, and other documents filed in these actions, all of which may be inspected free of charge during regular business hours at the Office of the Clerk of the Court, located at the following address:

United States District Court
James M. Ashley and Thomas W. L. Ashley U.S. Courthouse
1716 Spielbusch Avenue
Toledo, OH 43604

You may also obtain more information by calling the toll-free helpline at 1 (888) 331-9196, or contact the Notice Administrator at:

In re Polyurethane Foam Antitrust Litigation
c/o GCG
P.O. Box 9907
Dublin, OH 43017-5807

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