AIG SECURITIES LITIGATION-PwC SETTLEMENT
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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 click here.

To visit the AIG Securities Litigation – Starr Defendants Settlement website please click here.

To visit the AIG Securities Litigation – Gen Re Settlement website please click here.

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 Notice.

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
File Objection:   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

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.

IMPORTANT: THIS SITE IS NOT OPERATED BY AIG or PwC. THIS SETTLEMENT IS SUPERVISED BY LEAD PLAINTIFF'S COUNSEL. THE ADMINISTRATOR HANDLES ALL ASPECTS OF CLAIM PROCESSING. THIS IS THE AUTHORIZED WEBSITE FOR THIS SETTLEMENT; INFORMATION CAN ALSO BE FOUND ON LEAD PLAINTIFF'S COUNSEL'S WEBSITE WWW.LABATON.COM. PLEASE DO NOT RELY UPON OTHER SITES THAT SET OUT DIFFERENT AND UNAUTHORIZED INFORMATION.
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