NOTICE OF PROPOSED CLASS ACTION SETTLEMENT

Heather Hughes-Richmond v. Waldom Electronic Corporation, case number 2023-LA-370,
pending in the Seventeenth Judicial Circuit Court of Illinois, Winnebago County.

PLEASE READ THE NOTICE CAREFULLY AS YOUR LEGAL RIGHTS
MAY BE AFFECTED. A CLASS ACTION SETTLEMENT HAS BEEN REACHED
UNDER WHICH YOU MAY BE ENTITLED TO A PAYMENT.

SUMMARY OF YOUR OPTIONS AND THE  LEGAL EFFECT OF EACH OPTION

DO NOTHING

If you are a Class Member and do nothing, you will receive a Direct Check from the Settlement after Final Approval and you will give up your rights as set forth in this Notice and the Settlement Agreement. This check must be deposited within ninety (90) days, or you will not receive any monetary relief and will give up your rights as set forth in this Notice and the Settlement Agreement.

EXCLUDE YOURSELF 

If you do not want the money from the Settlement, you may exclude yourself. If you do so, you will not receive any cash payment, but you will not release any claims you may have against Defendant and the Released Parties (as that term is defined in the Settlement Agreement) and are free to pursue whatever legal rights you may have, including pursuing your own lawsuit against Defendant at your own risk and expense. To exclude yourself from the Settlement, you must mail a signed letter to the Settlement Administrator at Hughes-Richmond v. Waldom Electronic Settlement Administrator, P.O. Box 301130, Los Angeles, CA 90030-1130 postmarked no later than August 15, 2024. The exclusion letter must state that you exclude yourself from this Settlement and must include the name and case number of this Litigation, as well as your full name, address, telephone number, signature, and a statement that you wish to be excluded.

OBJECT TO THE SETTLEMENT

If you wish to object to the Settlement, you must submit your objection in writing to the Clerk of the Circuit Court of Winnebago County, Illinois. The objection must be received by the Court no later than
August 15, 2024. You must also send a copy of your objection to the attorneys for all Parties to the lawsuit, including Class Counsel (Mark Hammervold of Hammervold Law, LLC, 155 S. Lawndale Avenue, Elmhurst, IL 60126), as well as the attorneys representing Defendant (John P. Ryan and Liam A. McGing of Hinshaw & Culbertson, LLP, 151 N. Franklin Street, Suite 2500, Chicago, IL 60606), postmarked no later than
August 15, 2024. Any objection to the proposed Settlement must include: (a) your full name and current address, (b) a statement that you believe yourself to be a member of the Settlement Class, (c) the specific grounds for the objection, (d) all documents or writings that you desire the Court to consider, (e) the name and contact information of any and all attorneys representing you in connection with the objection, (f) a statement indicating whether you intend to appear at the Final Approval Hearing, and (g) your signature. If you hire an attorney in connection with making an objection, that attorney must also file with the Court a notice of appearance by the objection deadline of August 15, 2024. If you do hire your own attorney, you will be solely responsible for payment of any fees and expenses the attorney incurs on your behalf. If you exclude yourself from the Settlement, you cannot file an objection.

You may appear at the Final Approval Hearing, which is to be at September 4, 2024 at 10:30 a.m., in person or through counsel to show cause of why the proposed Agreement should not be approved as fair, reasonable, and adequate. Attendance at the hearing is not necessary; however, persons wishing to be heard orally in opposition to the approval of the Settlement, the request for attorneys’ fees and expenses, and/or the request for a service award to the Class Representative are required to indicate in their written objection their intention to appear at the hearing on their own behalf or through counsel and to identify the names of any witnesses they intend to call to testify at the Final Approval Hearing, as well as any exhibits they intend to introduce at the Final Approval Hearing.