The purpose of the Notice is to inform potential Settlement Class Members of the existence of this case, that it is a class action, how you (if you are a Settlement Class Member) might be affected, and how to exclude yourself from the Settlement Class if you wish to do so. The Notice also informs potential Settlement Class Members of the terms of the Settlement, and of a hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement, the Court Approved Plan of Allocation, and Lead Counsel’s application for an award of attorneys’ fees and reimbursement of Litigation Expenses (“Settlement Fairness Hearing”).

This is a securities class action against Endo and certain of its former executives. Lead Plaintiff alleges that, during the Class Period, Defendants made false and misleading statements and failed to disclose material adverse facts regarding the putative safety and abuse-deterrent properties of Reformulated Opana ER, an opioid analgesic indicated for the management of severe pain that requires daily opioid treatment.

The Settlement Class provisionally certified by the Court for purposes of effectuating the Settlement consists of: 

All persons and entities who purchased or otherwise acquired Endo common stock or ordinary shares between November 30, 2012 and June 8, 2017, inclusive, and were damaged thereby. 

Excluded from the Settlement Class are present or former executive officers and directors of Endo during the Class Period, including the Individual Defendants, the Dismissed Defendants, and members of their immediate families, any of the foregoing entities’ and individuals’ legal representatives, heirs, successors or assigns; (iii) any entity in which the foregoing entities or individuals have or had a controlling interest, or any affiliate of Endo; and (iv) any person or entity who or which purchased, sold, or otherwise acquired Endo ordinary shares on the Toronto Stock Exchange. Also excluded from the Settlement Class are any persons or entities who or which submit a request for exclusion from the Settlement Class that is accepted by the Court. 

Lead Plaintiff and Lead Counsel believe that the claims asserted against Defendants have merit; however, they also recognize the substantial risks in continuing to litigate the Action. Defendants have denied the claims asserted against them in the Action and deny having engaged in any wrongdoing or violation of law of any kind whatsoever. Defendants have agreed to the Settlement to eliminate the burden and expense of continued litigation, and the Settlement may not be construed as an admission of any wrongdoing by Defendants in this or any other action or proceeding. Additionally, Lead Plaintiff and Lead Counsel recognize the significant expense and length of continued proceedings necessary to pursue their claims against Defendants through the completion of discovery, further motion practice, trial, and appeals.

The law firm of Kessler Topaz Meltzer & Check, LLP was appointed to represent all Settlement Class Members. These lawyers are called Lead Counsel.  You will not be separately charged for the services of these lawyers. As a Settlement Class Member, you are represented by Lead Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense.

If you are a Settlement Class Member and you did not exclude yourself from the Settlement Class, you are bound by any orders issued by the Court.

Unless you timely and validly excluded yourself, you are a member of the Settlement Class, and that means you cannot sue, continue to sue, or be part of any other lawsuit against Defendants or their Related Parties about the Released Claims in this case. It also means that all of the Court’s orders will apply to you and legally bind you. If you are a Settlement Class Member, and if the Settlement is approved, you will give up all “Released Claims”, including “Unknown Claims”, against the “Released Persons.” For the definitions of the above terms see page 8 of the Notice.

If you did not receive a payment, please contact the Claims Administrator by calling 1-844-961-0316 or emailing Info@EndoSecuritiesLitigaion.com to get further information on the determination of your claim and/or status of the payment.

If you wish to request a reissuance of your payment, the request must be done in writing.  Reissue requests cannot be taken over the phone. A written request for a reissue can be sent to Info@EndoSecuritiesLitigaion.com or by mail at SEB Investment Management AB v. Endo International plc, et al. Settlement, c/o JND Legal Administration P.O. Box 91311, Seattle, WA 98111. If you have any questions, please contact the Claims Administrator at 1-844-961-0316 or by sending an email on the “Contact Us” page.

The Notice contains only a summary of the terms of the Settlement. For the terms and conditions of the Settlement, please see the Stipulation available at www.EndoSecuritiesLitigationSettlement.com. More detailed information about the matters involved in this Action can be obtained by accessing the Court docket in this case, for a fee, through the Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.paed.uscourts.gov, or by visiting, during regular office hours, the Office of the Clerk, United States District Court for the Eastern District of Pennsylvania, James A. Byrne U.S. Courthouse, 601 Market Street, Philadelphia, PA 19106. Additionally, copies of any related orders entered by the Court and certain other filings in this Action will be posted on the website for the Settlement, www.EndoSecuritiesLitigationSettlement.com.