The Court directed that the Notice be sent to you because you or someone in your family or an investment account for which you serve as custodian may have purchased Perrigo common stock during the Class Period or owned Perrigo common stock as of November 12, 2015. The Court has directed us to send you the Notice because, as a potential Class Member, you have the right to understand how this class action lawsuit may generally affect your legal rights. If the Court approves the Settlement and the Plan of Allocation (or some other plan of allocation), the Claims Administrator selected by Lead Plaintiff and approved by the Court will make payments pursuant to the Settlement after any objections and appeals are resolved.

The purpose of the Notice is to inform you of the terms of the proposed Settlement, and of a hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement, the proposed Plan of Allocation, and the motion by Lead Counsel for attorneys’ fees and Litigation Expenses (the “Settlement Hearing”). See paragraphs 53-54 of the Notice for details about the Settlement Hearing, including the date and location of the hearing.

The issuance of the Notice is not an expression of any opinion by the Court concerning the merits of any claim in the Action, and the Court still has to decide whether to approve the Settlement. If the Court approves the Settlement and a plan of allocation, then payments to Authorized Claimants will be made after any appeals are resolved and after the completion of all claims processing. Please be patient, as this process can take some time to complete.

This Action is a securities class action lawsuit alleging violations of Sections 10(b), 14(e) and 20(a) of the Securities Exchange Act of 1934 and certain claims under Israeli law against Defendants. This lawsuit asserts that Defendants made material misrepresentations and omissions during the Class Period (from April 21, 2015 through May 2, 2017, inclusive), including in connection with a tender offer made to Perrigo shareholders by Mylan N.V. in the fall of 2015 (through which Mylan sought to acquire Perrigo), regarding (a) the performance and integration of Omega Pharma, N.V., which Perrigo acquired in early 2015; (b) Perrigo’s pricing strategy, noncompetitive practices, and the competitive environment for Perrigo’s generic prescription drug unit; (c) Perrigo’s organic growth rate; and (d) a royalty stream for a drug called Tysabri. 

On May 18, 2016, this Action was commenced in the United States District Court for the District of New Jersey.

By Order dated February 10, 2017, the Court entered an order appointing Perrigo Institutional Investor Group (consisting of Migdal Insurance Company Ltd., Migdal Makefet Pension and Provident Funds Ltd., Clal Insurance Company Ltd., Clal Pension and Provident Ltd., Atudot Pension Fund for Employees and Independent Workers Ltd., and Meitav DS Provident Funds and Pension Ltd.) as Lead Plaintiff and approved its selection of Pomerantz LLP and Bernstein Litowitz Berger & Grossmann LLP as Lead Counsel. 

On June 21, 2017, Lead Plaintiff filed the operative Amended Complaint. The Amended Complaint named as defendants Perrigo and former Perrigo CEO Joseph C. Papa, as well as former defendants Judy Brown, Laurie Brlas, Gary M. Cohen, Marc Coucke, Jacqualyn A. Fouse, Ellen R. Hoffing, Michael R. Jandernoa, Gerald K. Kunkle, Jr., Herman Morris, Jr., and Donal O’Connor (“Former Defendants”). 

On August 21, 2017, Defendants and Former Defendants moved to dismiss the Amended Complaint. After full briefing, on July 27, 2018, the Court entered an order granting Marc Coucke’s motion to dismiss, and granting in part and denying in part the motion to dismiss filed by the Defendants and the Former Defendants other than Coucke. As a result of that order, all of the Former Defendants other than Judy Brown were dismissed from this Action. That order also dismissed claims regarding organic growth rate and Tysabri.

Thereafter, Defendants and Former Defendant Judy Brown answered the Amended Complaint, and Lead Plaintiff, Defendants, and Former Defendant Judy Brown commenced discovery. The Parties thereafter engaged in substantial discovery efforts, which included the litigation of several disputed issues related to the scope and breadth of discovery and the efforts by the U.S. Department of Justice to stay discovery in this Action.  Substantively, the Parties’ discovery efforts included the production and review of over 3.4 million pages of documents from Defendants and non-parties to Lead Plaintiff, and 40 depositions of fact and expert witnesses. 

On November 30, 2018, Lead Plaintiff moved for class certification. On November 14, 2019, after full briefing, the Court certified the Class, appointing Lead Plaintiff to be the Class Representative and its counsel to be Class Counsel. After Defendants’ petition for interlocutory appeal was denied, on July 10, 2020, Lead Plaintiff, Defendants and Former Defendant Judy Brown stipulated, and the Court ordered, that notice should issue regarding the pendency of class action.  

Beginning in August 2020, the Class Notice was mailed to potential Class Members to notify them of, among other things: (i) the Court’s certification of the Action to proceed as a class action on behalf of the Class; and (ii) Class Members’ right to request to be excluded from the Class, the effect of remaining in the Class or requesting exclusion, and the procedure for requesting exclusion. The deadline for requesting exclusion from the Class pursuant to the Class Notice was December 3, 2020. A list of the persons and entities who requested exclusion pursuant to the Class Notice is available on the Notice tab of this website. 

On April 9, 2021, Defendants Perrigo and Papa and Former Defendant Judy Brown each moved for summary judgment and to exclude Lead Plaintiff’s experts. The Summary Judgment record was voluminous with several hundred pages of briefing and statements of fact, and thousands of pages of exhibits. After full briefing and oral argument, on August 17, 2023, the Court entered an Order and issued an Opinion granting Former Defendant Judy Brown’s motion for summary judgment, granting in part and denying in part Defendants Perrigo and Papa’s motions for summary judgment, directing further briefing and argument on the issue of corporate scienter, and reserving ruling on the motions to exclude. The Parties completed that briefing and presented further argument to the Court on the issue of corporate scienter on November 16, 2023. 

Throughout the pendency of this Action, the Parties engaged in extensive attempts to mediate this dispute, both before private mediators Hon. Daniel Weinstein (Ret.), Former Ambassador David Carden, and Jed Melnick, and before Magistrate Judge Leda D. Wettre. These efforts included four in-person mediation sessions between 2018 and 2024, and numerous Zoom sessions and phone calls. On February 29, 2024, Magistrate Judge Wettre issued a mediator’s proposal to settle this Action for $97 million. On March 6, 2024, the Parties accepted the proposal.

After additional negotiations regarding the specific terms of their agreement, the Parties entered into the Stipulation on April 4, 2024. The Stipulation sets forth the specific terms and conditions of the Settlement and can be viewed on the Important Documents tab of this website. 

By Order dated April 23, 2024, the Court preliminarily approved the Settlement, authorized notice of the Settlement to be provided to potential Class Members, and scheduled the Settlement Hearing to consider whether to grant final approval to the Settlement.

If you are a member of the Class who has not previously sought exclusion from the Class in connection with the Class Notice, you are subject to the Settlement. The Class (or “Classes”), which was certified by the Court on November 14, 2019 consists of:  

1. all persons who purchased Perrigo publicly traded common stock between April 21, 2015 and May 2, 2017, both dates inclusive (the “Class Period”), on the New York Stock Exchange or any other trading center within the United States and were damaged thereby;
    
2. all persons who purchased Perrigo’s publicly traded common stock between April 21, 2015 and May 2, 2017, both dates inclusive, on the Tel Aviv Stock Exchange and were damaged thereby; and
    
3. all persons who owned Perrigo common stock as of November 12, 2015 and held such stock through at least 8:00 a.m. on November 13, 2015 (whether or not a person tendered their shares in response to the tender offer of Mylan, N.V.).
    

Excluded from these Classes are the Defendants; Former Defendants; any current member of the Board of Directors of Perrigo; any current or former Officers of Perrigo who served during the Class Period or any former members of the Board of Directors of Perrigo who served during the Class Period; the Immediate Family Members of any Defendant, Former Defendant, or any current member of the Board of Directors of Perrigo, or former member of the Board of Directors of Period who served during the Class Period, or any current or former Officer of Perrigo who served during the Class Period; any entity that any Defendant or Former Defendant owns or controls, or owned or controlled during the Class Period; and the legal representatives, heirs, agents, affiliates, successors, or assigns of any such excluded persons and entities.  Also excluded from the Classes are the persons and entities who requested exclusion from the Classes in connection with the mailing of the Class Notice, or were previously excluded by motion and order.

PLEASE NOTE:  Receipt of the Notice does not mean that you are a Class Member or that you will be entitled to receive proceeds from the Settlement. 

If you wish to be eligible to participate in the distribution of proceeds from the Settlement, you are required to submit the Claim Form that is being distributed with the Settlement Notice and the required supporting documentation postmarked (if mailed), or online, no later than August 26, 2024.

Lead Plaintiff and Lead Counsel believe that the claims asserted against Defendants have merit. They recognize, however, the uncertainty, expense, and length of the continued proceedings inherent in the prosecution of their claims through the pre-trial motions, trial, post-trial motions, and appeals presented significant risks to achieving a result superior to the Settlement.

Among other things, Lead Plaintiff faced substantial risks in establishing liability by the Defendants. Lead Plaintiff faced risks on each main element of its claims. To start, at the time of the Settlement, the Court indicated it was likely to enter summary judgment on behalf of Defendants dismissing Lead Plaintiff’s claims concerning Perrigo’s statements about its generic drug pricing practices. Losing those claims would have substantially narrowed the scope of liability and damages. Lead Plaintiff also faced challenges in proving that Defendants’ statements were false, or that Defendants acted with scienter.

In addition, Lead Plaintiff faced substantial risks in establishing loss causation and damages. Defendants would argue, among other things, that Lead Plaintiff could not appropriately establish damages for the claims brought under Section 14(e) of the Exchange Act in connection with the tender offer by Mylan during the Class Period. Defendants have argued and would likely argue at trial that Plaintiffs could not establish that the tender offer would have gone through in the absence of the Defendants’ alleged false statements. Defendants would further argue that Lead Plaintiff and its expert could not establish a causal connection between the alleged misrepresentations and the alleged corrective disclosures.  If Defendants succeeded on these arguments, even if Lead Plaintiff had established liability for the violations of the securities laws alleged, the recoverable damages could be substantially less than the amount provided in the Settlement or even zero.

In light of these risks, the amount of the Settlement, and the immediacy of recovery to the Class, Lead Plaintiff and Lead Counsel believe that the proposed Settlement is fair, reasonable, and adequate, and in the best interests of the Class. Lead Plaintiff and Lead Counsel believe that the Settlement provides a favorable result for the Class compared to the risk that the claims in the Action would produce a smaller, or no, recovery after a contested trial and appeals, possibly years in the future.

Defendants have denied the claims asserted against them in the Action and in the Complaint and deny having engaged in any wrongdoing or violation of law of any kind whatsoever. Defendants have agreed to the Settlement solely to eliminate the burden and expense of continued litigation. Accordingly, as noted above, the Settlement may not be construed as an admission of any wrongdoing by Defendants.

If there were no Settlement and Lead Plaintiff failed to establish, either at trial or on appeal, any essential legal or factual element of their claims against Defendants, neither Lead Plaintiff nor the other Class Members would recover anything from Defendants. Among other things, Lead Plaintiff faced the very real risk that it would not be able to establish that Defendants made false or misleading statements or acted with fraudulent intent, or caused losses to the Class.  In light of these circumstances, the Class could recover substantially less than the amount provided in the Settlement, or nothing at all.

As a Class Member, you are represented by Lead Plaintiff and Lead Counsel, unless you enter an appearance through counsel of your own choice and at your own expense. You are not required to retain your own counsel, but if you choose to do so, such counsel must file a notice of appearance on your behalf and must serve copies of his or her appearance on the attorneys listed in the section entitled, “When And Where Will The Court Decide Whether To Approve The Settlement?,” below.

If you are a Class Member and you wish to object to the Settlement, the Plan of Allocation, and/or Lead Counsel’s motion for attorneys’ fees and Litigation Expenses, and if you did not previously exclude yourself from the Class in connection with Class Notice, you may present your objections by following the instructions in the section entitled, “When And Where Will The Court Decide Whether To Approve The Settlement?,” below.

If you are a Class Member you will be bound by any orders issued by the Court. If the Settlement is approved, the Court will enter a judgment (“Judgment”). The Judgment will dismiss with prejudice the claims against Defendants and will provide that, upon the Effective Date of the Settlement, Lead Plaintiff, the Class, and each of the other Class Members, on behalf of themselves, and their respective heirs, executors, administrators, predecessors, successors, and assigns, in their capacities as such, shall be deemed to have, and by operation of law and of the Judgment shall have, fully, finally, and forever compromised, settled, released, resolved, relinquished, waived, and discharged each and every Released Plaintiffs’ Claim (as defined in paragraph 33 of the Notice) against the Defendants’ Releasees (as defined in paragraph 34 of the Notice), and shall forever be barred and enjoined from prosecuting any or all of the Released Plaintiffs’ Claims against any of the Defendants’ Releasees. This Release shall not apply to any of the Excluded Plaintiffs’ Claims.  

To be eligible for a payment from the proceeds of the Settlement, you must be a member of the Class and you must timely complete and return the Claim Form with adequate supporting documentation postmarked (if mailed), or submitted online under the "File a Claim" tab no later than August 26, 2024. A Claim Form is included with the Settlement Notice, or you may obtain one from the "Claim Form" tab or this website, or you may request that a Claim Form be mailed to you by calling the Claims Administrator toll free at 1-833-674-0175, or by emailing the Claims Administrator at info@PerrigoSecuritiesLitigation.com. Please retain all records of your ownership of and transactions in Perrigo common stock, as they may be needed to document your Claim. If you previously requested exclusion from the Class in connection with Class Notice or do not submit a timely and valid Claim Form, you will not be eligible to share in the Net Settlement Fund.

At this time, it is not possible to make any determination as to how much any individual Class Member may receive from the Settlement.

Pursuant to the Settlement, Defendants have agreed to pay $97,000,000 in cash. The Settlement Amount will be deposited into an escrow account. The Settlement Amount plus any interest earned thereon is referred to as the “Settlement Fund.” If the Settlement is approved by the Court and the Effective Date occurs, the Net Settlement Fund will be distributed to Class Members who submit valid Claim Forms, in accordance with the proposed Plan of Allocation or such other plan of allocation as the Court may approve.

The Net Settlement Fund will not be distributed unless and until the Court has approved the Settlement and a Plan of Allocation and that decision is affirmed on appeal (if any) and/or the time for any petition for rehearing, appeal, or review, whether by certiorari or otherwise, has expired, the review of pending Claims has been completed, and the Court orders distribution.

Neither Defendants, the other Defendants’ Releases, nor any other person or entity who or which paid any portion of the Settlement Amount on their behalf are entitled to get back any portion of the Settlement Fund once the Court’s order or Judgment approving the Settlement becomes Final. Defendants and the other Defendants’ Releasees shall not have any liability, obligation, or responsibility for the administration of the Settlement, the disbursement of the Net Settlement Fund, or the Plan of Allocation.

Approval of the Settlement is independent from approval of a plan of allocation. Any determination with respect to a plan of allocation will not affect the Settlement, if approved.

Unless the Court otherwise orders, any Class Member who fails to submit a Claim Form postmarked (if mailed), or online, on or before August 26, 2024 shall be fully and forever barred from receiving payments pursuant to the Settlement but will in all other respects remain a Class Member and be subject to the provisions of the Stipulation, including the terms of any Judgment entered and the Releases given. This means that each Class Member releases the Released Plaintiffs’ Claims (as defined in paragraph 33 of the Notice) against the Defendants’ Releasees (as defined in paragraph 34 of the Notice) and will be enjoined and prohibited from prosecuting any of the Released Plaintiffs’ Claims against any of the Defendants’ Releasees whether or not such Class Member submits a Claim Form.

Participants in and beneficiaries of a Perrigo-sponsored employee retirement and/or benefit plan covered by ERISA (“ERISA Plan”) should NOT include any information relating to Perrigo common stock purchased/acquired or held through the ERISA Plan in any Claim Form they submit in this Action. They should include ONLY those publicly traded Perrigo common stock purchased or held outside of the Perrigo-sponsored ERISA Plan. Claims based on any ERISA Plan(s)’ purchases or ownership of Perrigo common stock may be made by the ERISA Plan(s)’ trustees.

The Court has reserved jurisdiction to allow, disallow, or adjust the Claim of any Class Member.

Each Claimant shall be deemed to have submitted to the jurisdiction of the Court with respect to his, her, or its Claim Form.

Only Class Members will be eligible to share in the distribution of the Net Settlement Fund. Persons and entities who are excluded from the Class by definition or who previously excluded themselves from the Class in connection with Class Notice will not be eligible to receive a distribution from the Net Settlement Fund and should not submit Claim Forms.

Appendix A to the Notice sets forth the Plan of Allocation for allocating the Net Settlement Fund among Authorized Claimants, as proposed by Lead Plaintiff. At the Settlement Hearing, Lead Plaintiff will request the Court approve the Plan of Allocation. The Court may modify the Plan of Allocation, or approve a different plan of allocation, without further notice to the Class.

Plaintiffs’ Counsel have not received any payment for their services in pursuing claims against the Defendants on behalf of the Class, nor have Plaintiffs’ Counsel been reimbursed for their out-of-pocket expenses. Before final approval of the Settlement, Lead Counsel will apply to the Court for an award of attorneys’ fees for all Plaintiffs’ Counsel in an amount not to exceed 20% of the Settlement Fund. At the same time, Lead Counsel also intends to apply for payment of Litigation Expenses incurred in connection with the prosecution and resolution of this Action in an amount not to exceed $4.5 million, which may include a request for reimbursement of the reasonable costs and expenses incurred by Lead Plaintiff or its members directly related to their representation of the Class. The Court will determine the amount of any award of attorneys’ fees or reimbursement of Litigation Expenses. Such sums as may be approved by the Court will be paid from the Settlement Fund. Class Members are not personally liable for any such fees or expenses.

Class Members do not need to attend the Settlement Hearing.  The Court will consider any submission made in accordance with the provisions below even if a Class Member does not attend the hearing. You can participate in the Settlement without attending the Settlement Hearing. 

Please Note: The date and time of the Settlement Hearing may change without further written notice to the Class. The Court may decide to conduct the Settlement Hearing by video or telephonic conference, or otherwise allow Class Members to appear at the hearing by phone, without further written notice to the Class. In order to determine whether the date and time of the Settlement Hearing have changed, or whether Class Members must or may participate by phone or video, it is important that you monitor the Court’s docket and this website before making any plans to attend the Settlement Hearing. Any updates regarding the Settlement Hearing, including any changes to the date or time of the hearing or updates regarding in-person or telephonic appearances at the hearing, will be posted to this website. Also, if the Court requires or allows Class Members to participate in the Settlement Hearing by telephone, the phone number for accessing the telephonic conference will be posted to this website. 

The Settlement Hearing will be held on September 5, 2024 at 10:00 a.m., before the Honorable Leda Dunn Wettre, United States Magistrate Judge, either in person in Courtroom 3C of the Martin Luther King Building & U.S. Courthouse, 50 Walnut Street, Newark, NJ 07101, or by telephone or videoconference (in the discretion of the Court). The Court reserves the right to approve the Settlement, the Plan of Allocation, Lead Counsel’s motion for an award of attorneys’ fees and Litigation Expenses, and/or any other matter related to the Settlement at or after the Settlement Hearing without further notice to the members of the Class.

Any Class Member may object to the Settlement, the Plan of Allocation, and/or Lead Counsel’s motion for attorneys’ fees and Litigation Expenses. Objections must be in writing. You must file any written objection, together with copies of all other papers and briefs supporting the objection, with the Clerk’s Office at the United States District Court for the District of New Jersey at the address set forth below as well as serve copies on Lead Counsel and Defendants’ Counsel at the addresses set forth below so that the papers are received on or before August 6, 2024.

Any objections, filings, and other submissions by the objecting Class Member:  (a) must identify the case name and docket number, Roofer’s Pension Fund v. Papa, et al., No. 1:16-cv-02805 (RMB) (LDW) (D.N.J.); (b) must state the name, address, and telephone number of the person or entity objecting and must be signed by the objector; (c) must state with specificity the grounds for the Class Member’s objection, including any legal and evidentiary support the Class Member wishes to bring to the Court’s attention and whether the objection applies only to the objector, to a specific subset of the Class, or to the entire Class; and (d) must include documents sufficient to prove membership in the Class, including (i) the number of shares of Perrigo common stock that the objecting Class Member purchased/acquired and/or sold during the Class Period (i.e., April 21, 2015 and May 2, 2017, inclusive), as well as the transaction dates, number of shares, and prices of each such purchase/acquisition and sale; and (ii) the number of shares of Perrigo common stock that objecting Class Member owned as of November 12, 2015 and still held through at least 8:00 a.m. on November 13, 2015. The objecting Class Member shall provide documentation establishing membership in the Class through copies of brokerage confirmation slips or monthly brokerage account statements, or an authorized statement from the objector’s broker containing the transactional and holding information found in a broker confirmation slip or account statement.

You may not object to the Settlement, Plan of Allocation, and/or Lead Counsel’s motion for attorneys’ fees and Litigation Expenses if you previously excluded yourself from the Class in connection with Class Notice or if you are not a member of the Class.

You may submit an objection without having to appear at the Settlement Hearing. You may not, however, appear at the Settlement Hearing to present your objection unless you first submit a written objection in accordance with the procedures described above, or the Court orders otherwise.

If you wish to be heard orally at the hearing in opposition to the approval of the Settlement, the Plan of Allocation, and/or Lead Counsel’s motion for attorneys’ fees and Litigation Expenses, and if you timely submit a written objection as described above, you must also file a notice of appearance with the Clerk’s Office and serve it on Lead Counsel and Defendants’ Counsel at the addresses set forth in paragraph 55 of the Notice so that it is received on or before August 6, 2024.  Persons who intend to object and desire to present evidence at the Settlement Hearing must include in their written objection or notice of appearance the identity of any witnesses they may call to testify and exhibits they intend to introduce into evidence at the hearing. Such persons may be heard orally at the discretion of the Court.

You are not required to hire an attorney to represent you in making written objections or in appearing at the Settlement Hearing. However, if you decide to hire an attorney, it will be at your own expense, and that attorney must file a notice of appearance with the Court and serve it on Lead Counsel and Defendants’ Counsel at the addresses set forth in paragraph 55 of the Notice so that the notice is received on or before August 6, 2024.

Unless the Court orders otherwise, any Class Member who does not object in the manner described above will be deemed to have waived any objection and shall be forever foreclosed from making any objection to the proposed Settlement, the proposed Plan of Allocation, and/or Lead Counsel’s motion for an award of attorneys’ fees and Litigation Expenses. Class Members do not need to appear at the Settlement Hearing or take any other action to indicate their approval.

IMPORTANT: If you previously provided the names and addresses of persons and entities (a) on whose behalf you purchased or otherwise acquired Perrigo common stock from April 21, 2015 through May 2, 2017, inclusive, or (b) on whose behalf you held Perrigo common stock as of the close of trading on November 12, 2015, in connection with the Class Notice, and (i) those names and addresses remain current and (ii) you have no additional names and addresses for potential Class Members to provide to the Claims Administrator, you need do nothing further at this time. The Claims Administrator will mail the Settlement Notice and the Claim Form (the “Settlement Notice Packet”) to the beneficial owners whose names and addresses were previously provided in connection with the Class Notice. If you elected to mail the Class Notice directly to beneficial owners, you were advised that you must retain the mailing records for use in connection with any further notices that may be provided in the Action. If you elected this option, the Claims Administrator will forward the same number of Settlement Notice Packets to you to send to the beneficial owners. If you require more copies of the Settlement Notice Packet than you previously requested in connection with the Class Notice mailing, please contact the Claims Administrator, JND Legal Administration, by email at PRGSecurities@JNDLA.com or toll free at 1-833-674-0175, and let them know how many additional packets you require. You must mail the Settlement Notice Packets to the beneficial owners within seven (7) calendar days of your receipt of the Settlement Notice Packets. 

If you have not already provided the names and addresses for persons and entities on whose behalf (a) you purchased Perrigo common stock from April 21, 2015 and May 2, 2017, inclusive, or (b) held Perrigo common stock as of the close of trading on November 12, 2015, in connection with the Class Notice, or if you have additional names or updated or changed information, then the Court has ordered that you must, WITHIN SEVEN (7) CALENDAR DAYS OF YOUR RECEIPT OF THE SETTLEMENT NOTICE, either: (i) send the Settlement Notice Packet to all such beneficial owners of such Perrigo common stock, or (ii) send a list of the names and addresses of such beneficial owners to the Claims Administrator at Perrigo Securities Litigation, c/o JND Legal Administration, P.O. Box 91374, Seattle, WA 98111, in which event the Claims Administrator shall promptly mail the Settlement Notice Packet to such beneficial owners. AS STATED ABOVE, IF YOU HAVE ALREADY PROVIDED THIS INFORMATION IN CONNECTION WITH CLASS NOTICE, UNLESS THAT INFORMATION HAS CHANGED (E.G., BENEFICIAL OWNER HAS CHANGED ADDRESS), IT IS UNNECESSARY TO PROVIDE SUCH INFORMATION AGAIN. 

Upon full and timely compliance with these directions, nominees who mail the Settlement Notice Packet to beneficial owners may seek reimbursement of  their reasonable out-of-pocket expenses, incurred in providing notice to beneficial owners, which expenses would not have been incurred except for the providing names and addresses up to $0.05 per name (with address and email address) provided to the Claims Administrator; up to $0.05 per Postcard Notice or Notice and Proof of Claim mailed plus postage at the rate used by the Claims Administrator;  or up to $0.05 per Notice and Claim Link sent by email, with any disputes as to the reasonableness or documentation of expenses incurred subject to review by the Court.

Copies of the Settlement Notice and the Claim Form may be obtained from the "Notice" and "Claim Form" tabs of this website respectively, by calling the Claims Administrator toll free at 1 833-674-0175, or by emailing the Claims Administrator at info@PerrigoSecuritiesLitigation.com.

The Notice contains only a summary of the terms of the Settlement. For the terms and conditions of the Settlement, please see the Stipulation available on the "Important Documents" tab of this website. More detailed information about the matters involved in this Action can be obtained by accessing the Court docket in this case, for a fee, through the Court’s Public Access to Court Electronic Records (PACER) system at https://www.njd.uscourts.gov/, or by visiting, during regular office hours, the Office of the Clerk, United States District Court for the District of New Jersey, Martin Luther King Building & U.S. Courthouse, 50 Walnut Street, Newark, NJ 07101. Additionally, copies of the Stipulation, any related orders entered by the Court and certain other filings in this Action will be posted on this website.

All inquiries concerning the Settlement Notice and the Claim Form should be directed to:

Perrigo. Securities Litigation
c/o JND Legal Administration
P.O. Box 91374
Seattle, WA 98111
1-833-674-0175
info@PerrigoSecuritiesLitigation.com
www.PerrigoSecuritiesLitigation.com

and/or

Joshua Silverman
Pomerantz LLP
10 S. LaSalle Street
Chicago, IL 60603
1-312-377-1181
jbsilverman@pomlaw.com

James A. Harrod
Bernstein Litowitz Berger & Grossmann LLP
1251 Avenue of the Americas
New York, NY 10020
1-800-380-8496
settlements@blbglaw.com

PLEASE DO NOT CALL OR WRITE THE COURT, THE CLERK’S OFFICE, PERRIGO, OR DEFENDANTS’ COUNSEL REGARDING THE NOTICE.