IMPORTANT: Lead Counsel Labaton Sucharow LLP is pleased to report that on September
29, 2014, the Court issued its orders approving the initial distribution of the
settlement proceeds in connection with the four settlements in the AIG Securities
Litigation – the "PwC," "Company," "Starr," and "Gen Re" Settlements. On November
18, 2014, pursuant to the Court's Orders, 90% of the PwC, Company, Starr, and Gen
Re Net Settlement Funds were distributed. The remaining funds will be distributed
at a future date to eligible claimants who cash this initial distribution. If you
received a check from this distribution, please cash it promptly as it will become
stale on the date listed.
Welcome to the AIG Securities Litigation - PwC Settlement website.
To visit the AIG Securities Litigation – Company
Settlement website please
To visit the AIG Securities Litigation – Starr
Defendants Settlement website please
To visit the AIG Securities Litigation – Gen Re
Settlement website please
The following is a summary of information presented in more detail in the Notice
of Proposed Settlement, Motion for Attorneys’ Fees and Expenses Award and
Fairness Hearing (the "Notice"), which Class Members should have received in the
mail, and which you can access by clicking on the box with that name to the left.
Since this is just a summary, you should see the full Notice for additional details.
Securities Brokers and other Nominees: Please see instructions at the end of the
Settlement Fairness Hearing
As previously announced, a $97.5 million Settlement between the Lead Plaintiff and
defendant PricewaterhouseCoopers LLP ("PwC Settlement") has been reached and preliminarily
approved. The Court held a hearing on November 30, 2010, at 3:00 p.m., at the United
States District Court for the Southern District of New York, United States Courthouse,
500 Pearl Street, New York, New York 10007. At the hearing, the Court approved the
Agreement of Compromise and Settlement in the action as fair, reasonable, adequate
and in the best interests of the Class Members. A final judgment was entered by
the Court on December 2, 2010. Please see the links to the left for downloadable
copies of certain relevant documents. The deadline for submitting claims, exclusion
requests and objections has passed.
What was this case about?
After the first alleged disclosures about the market division fraud were reported
to the public on October 14, 2004, ten class action complaints were filed against
AIG and others (but not PwC), and the cases were transferred to Judge Laura Taylor
Swain. The complaints included class periods of October 28, 1999 to October 15,
2004, and alleged Section 10(b) claims. After hearing fully-briefed motions regarding
appointment of a lead plaintiff and lead counsel to pursue the proposed class action,
Judge Swain, by order dated February 7, 2005, appointed the Ohio State Funds as
Lead Plaintiff; appointed Labaton Sucharow LLP (at the time known as Goodkind Labaton
Rudoff & Sucharow LLP) and Hahn Loeser & Parks LLP as Lead Plaintiff's counsel.
On April 19, 2005, Lead Plaintiff filed a Consolidated First Amended Complaint,
which included claims based on both the market division fraud and the accounting
fraud, alleged a class period of October 28, 1999 through March 30, 2005, named
additional defendants, including PwC; and added claims under Section 11 and 15 of
the Securities Act.
On May 16, 2005, the San Francisco Employees' Retirement System filed a separate,
purportedly new securities class action complaint against AIG and others that alleged
causes of action based solely on the accounting frauds disclosed in the spring of
2005. After reviewing motions on the appointment of Lead Plaintiff related to this
claim, the Court held a hearing on July 18, 2005 and found that the Ohio State Funds
would serve as the Lead Plaintiff for all the claims at issue.
Between November and December 2005 defendants in the Action filed motions to dismiss
the Action in its entirety, submitting hundreds of pages of briefing and affidavits.
The Court denied all of these motions, except one, in April and May 2006. After
the denial of the motions, Lead Plaintiff, the Ohio State Funds, and Lead Counsel
began to conduct formal discovery into the facts of the case. (Prior to filing its
first complaint, Lead Plaintiff's counsel had engaged in a thorough investigation
of the publicly available information about the claims, including contact with former
employees of AIG and the other defendants.) Defendants and approximately 42 non-parties
have produced approximately 45 million pages of documents, which includes more than
28 million pages produced by PwC. Counsel for Lead Plaintiff reviewed and analyzed
virtually all of the documents produced to date. In addition, Lead Plaintiff took
more than a dozen fact depositions.
As noted above, Lead Plaintiff and PwC reached an agreement to settle the claims
against PwC in the Action on terms that are summarized here. Lead Plaintiff and
PwC, through their counsel, engaged in substantial arm's-length negotiations in
an effort to resolve all claims that have been or could have been asserted in the
Action against PwC. Lead Plaintiff's counsel and PwC's counsel conducted numerous
meetings and conferences, including multiple mediation sessions before a former
federal judge who acted as an independent mediator, in which the terms of the Settlement
detailed here were negotiated.
IMPORTANT DATES & DEADLINES
File a Proof of Claim:
Postmarked no later than January 28, 2009
Request an Exclusion:
Deadline has passed
Deadline has passed
Settlement Fairness Hearing:
November 30, 2010 at 3:00 p.m.
United States District Court
Southern District of New York
The Settlement was Approved.
The Defendants denied Lead Plaintiffs' allegations and vigorously defended the Action.
Nonetheless, the Defendants concluded that further conduct of the Litigation would
be protracted and expensive and, therefore, determined that it was desirable that
the Litigation be settled.
Terms of the Settlement
In exchange for the Settlement and dismissal of the Released Claims, PwC agreed
to fund a $97.5 million (before interest) account that was divided, after deduction
of Court-awarded attorneys' fees and expenses, Lead Plaintiff expenses, Notice and
Administrative Expenses, and any applicable taxes, ("Distribution Amount") among
all Class Members who timely submitted valid Proof of Claim forms that showed a
Recognized Loss. Your share of the fund depended on several things, including: (1)
the amount of Recognized Losses of other Class Members who filed valid Proofs of
Claim; (2) how many AIG Securities you bought; (3) how much you paid for them; (4)
the type of security bought; (5) when you bought them; (6) whether or when you sold
them (and, if so, for how much you sold them).
Your Recognized Loss was calculated according to the formula shown in the Plan of
Allocation. It is unlikely that you got a payment for your entire Recognized Loss,
given the number of potential Class Members with Recognized Losses. The payment
you got was a portion of the Distribution Amount equal to your Recognized Loss divided
by the total of all Class Members' Recognized Losses and multiplied by the total
Distribution Amount. (See the Plan of Allocation in the Notice for more information.)
Further information regarding the Litigation, the Notice and your Proof of Claim
form may be obtained by contacting the Administrator or reading the through the
Notice and Proof of Claim link at the left.