Class Counsel will ask the Court to approve a payment for legal fees equal to 33% of the Qualified Settlement Fund, as well as payment of the litigation expenses Class Counsel incurred to prosecute the Case. The attorneys’ fees would pay Class Counsel for investigating the facts, litigating the Case for years, and negotiating the Class Settlement, all of which Class Counsel did without any guarantee of a single dollar of compensation. Any award of attorneys’ fees and expenses will be paid out of the Qualified Settlement Fund. Defendants have agreed not to oppose a Court award of attorneys’ fees and expenses.