Defined Terms - kitecsettlement.com

IN RE: KITEC PLUMBING SYSTEM PRODUCTS LIABILITY LITIGATIONAND RELATED CANADIAN ACTIONSCLASS ACTION settlement AND RELEASE AGREEMENTThe Plaintiffs, who are acting as the Class Representatives on behalf of themselves and all other settlement Class Members of the settlement Classes set forth herein, and IPEX Inc. and IPEX USA LLC, on behalf of the IPEX Defendants, stipulate and agree, pursuant to the Terms and conditions set forth in this Agreement, to settle, dismiss, and compromise fully and finally the Kitec MDL Class Action and the Canadian TermsAs used in this Agreement, the notices and other documents contemplated by this Agreement, and any amendments thereto, the following Terms shall have the meanings set forth below. Terms used in the singular shall be deemed to include the plural and vice versa. 1. Agreement shall mean this Class Action settlement and Release Agreement, including the notices and other documents contemplated by this Agreement, and any amendments Canadian Actions shall mean the putative class action lawsuits pending in the following provinces under the following captions:a.

6 Formal Fairness Hearings shall be set by the Courts that make the Preliminary Approval Orders and communicated to the Settlement Class Members in the Court-approved

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