Valeant Securities Class Action Settlement

A settlement has been reached in the action against Valeant Pharmaceuticals International Inc., now known as Bausch Health Companies Inc. ("Valeant"). The Action alleges that Valeant, certain of its directors and officers, and its auditor PricewaterhouseCoopers LLP (“PwC”) failed to disclose Valeant’s relationship with Philidor Rx Services LLC and other specialty pharmacies in the conduct of its business in the United States.

The Superior Court of Québec appointed the class action plaintiffs, Celso Catucci and Nicole Aubin, as representative plaintiffs for the Primary Market Sub-Class and Secondary Market Sub-Class.

On November 16, 2020 the Settlement Agreement was approved by the Superior Court of Québec.

The Settlement provides for the payment by the Defendants of the total amount of $94 Million CAD to resolve those claims. The Settlement is a compromise of disputed claims, without any admission of liability by Valeant or any other defendant.

A class action is a lawsuit that is brought by one or more persons on behalf of a larger group of people whose claims share common legal and/or factual issues. Class actions provide a cost-effective way for groups of people with common interests to pursue a legal claim.

In a class action, the Plaintiff acts as “Representative Plaintiff” and sues on behalf of themselves and other people who have similar claims. This group of people is called the “Class,” and the people in the Class are called “Class Members.” One court resolves the issues for all Class Members. The lawyers who act for the representative plaintiffs are called “Class Counsel”.

In this class action, the Court has appointed Celso Catucci and Nicole Aubin to serve as representative plaintiffs for the Primary Market Sub-Class and Secondary Market Sub-Class and has appointed Siskinds LLP, Koskie Minsky LLP, Faguy & Co., Strosberg Sasso Sutts LLP, Rochon Genova LLP, Morganti Legal P.C., Siskinds Desmeules s.e.n.c.r.l. and Investigation Counsel P.C to serve as Class Counsel.

This case is Catucci and Aubin v. Valeant Pharmaceuticals International Inc. et al., Court File Number 500-06-000783-163 in the Superior Court of Québec.

You have been identified as a potential Class Member. The Notice provides Class Members with information about the Settlement and their rights to participate in the Settlement.

Pursuant to the Settlement Agreement, the Settlement Class Members are:

1. Primary Market Sub-Class: All persons and entities, wherever they may reside or may be domiciled, who, during the period February 28, 2013 to November 12, 2015, acquired Valeant’s Securities in an Offering, and held some or all of such Securities at any point in time between October 19, 2015 and November 12, 2015, excluding any claims in respect of Valeant’s Securities acquired in the United States (but not excluding any claims in respect of Valeant’s 4.5% Senior Notes due 2023 offered in March 2015); and,



2. Secondary Market Sub-Class: All persons and entities, wherever they may reside or may be domiciled who, during the period February 27, 2012 to November 12, 2015, acquired Valeant’s Securities in the secondary market and held some or all such Securities at any point in time between October 19, 2015 and November 12, 2015, excluding any claims in respect of Valeant’s Securities acquired in the United States.

   (together, the "Original Class")

Click here for the list of Excluded Persons.

Pursuant to the Settlement Agreement, the Settlement Class Members are:

(i) Primary Market: All persons and entities, wherever they may reside or may be domiciled, who, during the period February 28, 2013 to November 12, 2015, acquired Valeant’s Securities in an Offering, and held some or all of such Securities at any point in time between October 19, 2015 and November 12, 2015, excluding any claims in respect of Valeant’s Securities acquired in the United States (but not excluding any claims in respect of Valeant’s 4.5% Senior Notes due 2023 offered in March 2015); and,

(ii) Secondary Market: All persons and entities, wherever they may reside or may be domiciled who, during the period February 27, 2012 to November 12, 2015, acquired Valeant’s Securities in the secondary market and held some or all such Securities at any point in time between October 19, 2015 and November 12, 2015, excluding any claims in respect of Valeant’s Securities acquired in the United States.

“Class Period” means February 27, 2012 to November 12, 2015

The Valeant Securities included under this settlement are as follows:

1. Valeant Common Shares:

Primary Market: You are a Settlement Class Member if, during the period February 28, 2013 to November 12, 2015, you acquired Valeant's common shares pursuant to any of the following Valeant offering memoranda or prospectuses, you acquired such common shares outside of the United States, and you held some or all of such common shares at any point in time between October 19, 2015 and November 12, 2015:

1. Offering Circular dated June 27, 2013;
2. Offering Circular dated November 15, 2013; offering Memorandum dated January 15, 2015;
3. Offering Memorandum dated March 13, 2015;
4. Short Form Base Shelf Prospectus dated and filed on SEDAR on June 14, 2013;
5. Prospectus Supplement dated and filed on SEDAR on June 18, 2013;
6. Prospectus dated June 10, 2013, filed on EDGAR on June 19, 2013;
7. Prospectus Supplement dated June 18, 2013, filed on EDGAR on June 19, 2013;
8. Prospectus dated June 10, 2013, filed on EDGAR on March 18, 2015; and,
9. Prospectus Supplement dated March 17, 2015, filed on EDGAR on March 18, 2015.

Secondary Market: You are a Settlement Class Member if you acquired Valeant's common shares on any secondary market securities trading venue such as the Toronto Stock Exchange other than the United States secondary market securities trading venues such as the New York Stock Exchange, you acquired such common shares during the Class Period, and you held some or all of such common shares at any point in time between October 19, 2015 and November 12, 2015.

2. Valeant 6.75% senior notes due 2018 (2018 6.75% Notes):

Primary Market: You are a Settlement Class Member if you acquired these notes pursuant to Valeant's Offering Circular dated June 27, 2013 outside of the United States, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Secondary Market: You are a Settlement Class Member if you acquired these notes in the secondary market anywhere in the world other than in the United States, you acquired such notes during the Class Period, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Note that in a series of transactions carried out in March and August 2017, Valeant redeemed all the outstanding 6.75% senior notes due 2018. You are, nonetheless, a Settlement Class member if you meet the description provided above.

3. Valeant 7.50% senior notes due 2021 (2021 7.50% Notes):

Primary Market: You are a Settlement Class Member if you acquired these notes pursuant to Valeant's Offering Circular dated June 27, 2013 outside of the United States, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Secondary Market: You are a Settlement Class Member if you acquired these notes in the secondary market anywhere in the world other than in the United States, you acquired such notes during the Class Period, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

4. Valeant 5.625% senior notes due 2021 (2021 5.625% Notes):

Primary Market: You are a Settlement Class Member if you acquired these notes pursuant to Valeant's Offering Circular dated November 15, 2013 outside of the United States, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Secondary Market: You are a Settlement Class Member if you acquired these notes in the secondary market anywhere in the world other than in the United States, you acquired such notes during the Class Period, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

5. Valeant 5.50% senior unsecured notes due 2023 (2023 5.50% Notes):

Primary Market: You are a Settlement Class Member if you acquired these notes pursuant to Valeant's Offering Memorandum dated January 15, 2015 outside of the United States, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Secondary Market: You are a Settlement Class Member if you acquired these notes in the secondary market anywhere in the world other than in the United States, you acquired such notes during the Class Period, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

6. Valeant 5.375% senior unsecured notes due 2020 (2020 5.375% Notes):

Primary Market: You are a Settlement Class Member if you acquired these notes pursuant to Valeant's Offering Memorandum dated March 13, 2015 outside of the United States, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Secondary Market: You are a Settlement Class Member if you acquired these notes in the secondary market anywhere in the world other than in the United States, you acquired such notes during the Class Period, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

7. Valeant 5.875% senior unsecured notes due 2023 (2023 5.875% Notes):

Primary Market: You are a Settlement Class member if you acquired these notes pursuant to Valeant's Offering Memorandum dated March 13, 2015 outside of the United States, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Secondary Market: You are a Settlement Class member if you acquired these notes in the secondary market anywhere in the world other than in the United States, you acquired such notes during the Class Period, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

8. Valeant 4.50% senior unsecured notes due 2023 (2023 4.50% Notes):

Primary Market: You are a Settlement Class member if you acquired these notes pursuant to Valeant's Offering Memorandum dated March 13, 2015, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Secondary Market: You are a Settlement Class member if you acquired these notes in the secondary market anywhere in the world other than in the United States, you acquired such notes during the Class Period, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

9. Valeant 6.125% senior unsecured notes due 2025 (2025 6.125% Notes):

Primary Market: You are a Settlement Class member if you acquired these notes pursuant to Valeant's Offering Memorandum dated March 13, 2015 outside of the United States, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Secondary Market: You are a Settlement Class member if you acquired these notes in the secondary market anywhere in the world other than in the United States, you acquired such notes during the Class Period, and you held some or all of such notes at any point in time between October 19, 2015 and November 12, 2015.

Click here for the list of Excluded Persons.

An International Securities Identification Number (ISIN) is a code that uniquely identifies a specific securities issue.

Please see below information to identify Valeant securities.

The Excluded Persons are Valeant, the Individual Defendants, the Insurer Defendants, PwC, the Underwriter Defendants, members of the immediate families of the Individual Defendants, and the directors, officers, subsidiaries and affiliates of Valeant.

• Individual Defendants means J. Michael Pearson, Howard B. Schiller, Robert L. Rosiello, Robert A. Ingram, Ronald H. Farmer, Laizer D. Kornwasser, Theo Melas-Kyriazi, G. Mason Morfit, Dr. Laurence Paul, Robert N. Power, Norma A. Provencio, Lloyd M. Segal, Katherine B. Stevenson, Fred Hassan, Colleen Goggins and Jeffrey W. Ubben.


• Insurer Defendants means AIG Insurance Company of Canada, Allianz Global Risks US Insurance Company, Everest Insurance Company of Canada, Royal & Sun Alliance Insurance Company of Canada, Temple Insurance Company, XL Insurance Company, Chubb Insurance Company of Canada (formerly ACE INA Insurance), Ironshore Canada Ltd., Ironshore Ltd., Liberty Mutual Insurance Company, and Lloyd’s Underwriters Syndicate Numbers AWH 2232, QBE 1886, Consortium 9885, AML 1200, MIT 3210, SJC 2003, ANV 1861, NAV 1221, AMA 1200, HCC 4141, AWH 2232, Barbican Professional and Financial Lines Consortium 9562, Starr Financial Lines Consortium 9855 and ASP 4711, having a designated attorney (fondé de pouvoir), Sean Murphy, at 1155, Metcalfe Street, Suite 220, Montreal, Quebec, H3B 2V6.


• Underwriter Defendants means Goldman Sachs & Co., Goldman Sachs Canada Inc., Deutsche Bank Securities Inc., Barclays Capital Inc., HSBC Securities (USA) Inc., MUFG Securities Americas Inc. (formerly Mitsubishi UFJ Securities (USA) Inc.) Mitsubishi UFG Securities International plc., DBS Bank Ltd., DNB Markets Inc., RBC Capital Markets LLC, Morgan Stanley & Co. LLC, Suntrust Robinson Humphrey Inc., Citigroup Global Markets Inc., CIBC World Markets Corp., SMBC Nikko Securities America Inc., TD Securities (USA) LLC, J.P. Morgan Securities LLC, Merrill Lynch, Pierce, Fenner & Smith Incorporated and BMO Capital Markets Corp.

On November 16, 2020 the Settlement Agreement was approved by the Superior Court of Québec.

The Settlement provides for the payment by the Defendants of the total amount of $94 Million CAD to resolve those claims.

The Settlement is a compromise of disputed claims, without any admission of liability by Valeant or any other defendant.

The Settlement Amount, after payment of Administration Expenses, Class Counsel Fees, (the “Net Settlement Amount”), will be distributed to eligible Class Members in accordance with a Plan of Allocation approved by the Court.

Class Members will be eligible for compensation pursuant to the Settlement if they submit a duly completed Claim Form, including any supporting documentation, to the Claims Administrator no later than February 15, 2021 and their claim submission must satisfy the criteria set out in the Plan of Allocation.

The Plan of Allocation provides a formula pursuant to which the Net Settlement Amount will be allocated to eligible Class Members on a pro rata basis. Because the Net Settlement Amount will be distributed pro rata, it is not possible to estimate the individual recovery of any individual Class Member until all the claims have been received and reviewed.

In the event any amounts remain undistributed after the distribution of the Net Settlement Amount (whether by reason of tax refunds, un-cashed cheques or otherwise), if feasible, allocate such balance among Claimants in an equitable and economic fashion. Thereafter, any remaining funds will be distributed as follows:

1. The Regulation respecting the percentage withheld by the Fonds d'aide aux actions collectives, c. F-3.2.0.1.1, r.2 will apply to the portion of any remaining balance.


2. If the Claims Administrator determines, at its discretion, that funds that cannot be economically allocated among Claimants, the Claims Administrator shall, after payment is made to the Fonds d'aide aux actions collectives, hold the balance in the Escrow Account pending a further settlement in the proceedings or otherwise subject to further order of the Court.

A copy of the proposed Plan of Allocation and other related documentation is available by clicking here.

To be eligible for compensation, Class Members must submit a duly completed Claim Form, including any supporting documentation to the Claims Administrator by no later than February 15, 2021, and their claim must satisfy the criteria set out in the Plan of Allocation that can be found here.

You can submit your Claim Form:

1. Online – Click here to review and complete the online claim form - it’s fast, easy and secure. Your online claim form must be submitted no later than February 15, 2021.


2. By Mail or Email – Download and print the Claim Form from the Documents tab, duly complete it, and submit it to the Claims Administrator no later than February 15, 2021 as follows:
   

   Epiq Class Action Services Canada Inc.
   Attention: Valeant Securities Class Action Settlement Claims Administrator
   P.O. Box 507 STN B
   Ottawa ON K1P 5P6
   Email: info@ValeantSecuritiesSettlement.ca
   Telephone: 1-833-290-4729
   Fax: 1-866-262-0816
   

Please contact the Claims Administrator if you would like to request that a Claim Form be sent to you by mail, email or fax.

Separate Claim Forms should be submitted for each such legal entity (e.g., a claim submission from joint owners should not include separate transactions of just one (1) of the joint owners). Conversely, a single Claim Form should be submitted on behalf of one (1) legal entity including all transactions made by that entity on one (1) Claim Form, no matter how many separate accounts that entity has (e.g., an individual shareholder with multiple accounts should include all transactions made in all accounts on one (1) Claim Form).

All joint beneficial owners must sign the same Claim Form. If you acquired or were registered or beneficial security holders of Valeant securities in your name, you are the beneficial owner as well as the record owner. If, however, you acquired or were registered or beneficial security holders of Valeant securities and the securities were registered in the name of a third party, such as a nominee or brokerage firm, you are the beneficial owner of the securities, but the third party is the record owner.

Agents, executors, administrators, guardians, and trustees must complete and sign the Claim Form on behalf of persons represented by them, and they must:

1. Expressly state the capacity in which they are acting;


2. Identify the name, account number, address and telephone number of the beneficial owner of (or other person or entity on whose behalf they are acting with respect to) the Valeant securities; and


3. Furnish herewith evidence of their authority to bind the person or entity on whose behalf they are acting. (Authority to complete and sign a Claim Form cannot be established by stockbrokers demonstrating only that they have discretionary authority to trade stock in another person’s accounts.)

Should it be necessary, documentation such as a separation agreement may be submitted to show the agreement made between the joint beneficial owners (i.e: Each entitled to 50%).

Individual Claim Submissions

An Individual Claim means an Individual or Entity submitting a claim on their own behalf or on behalf of others (e.g. agents, executors, administrators, guardians, and trustees).

If you are an Individual Claimant, you must provide all of the information with respect to all of your acquisitions, holdings and records of Valeant securities whether such transactions resulted in a profit or a loss. Failure to report all transactions during the requested periods may result in the rejection of your claim.

You are required to submit genuine and sufficient documentation for all of your transaction(s) in and holdings of Valeant securities. Documentation may consist of the following:

• Copies of broker confirmation slips containing the claimant’s name;


• Broker account statements containing the claimant’s name; and


• Authorized statement from your broker containing the transactional information found in a broker confirmation slip and the claimant’s name.

The Releasees and the Claims Administrator do not independently have information about your investments in Valeant securities.

IF SUCH DOCUMENTS ARE NOT IN YOUR POSSESSION, PLEASE OBTAIN COPIES OR EQUIVALENT CONTEMPORANEOUS DOCUMENTS FROM YOUR BROKER. FAILURE TO SUPPLY THIS DOCUMENTATION COULD DELAY VERIFICATION OF YOUR CLAIM OR COULD RESULT IN REJECTION OF YOUR CLAIM. DO NOT SEND ORIGINAL DOCUMENTS.

Please keep a copy of all documents that you send to the Administrator.

Separate Claim Forms should be submitted for each such legal entity (e.g., a claim from joint owners should not include separate transactions of just one (1) of the joint owners). Conversely, a single Claim Form should be submitted on behalf of one (1) legal entity including all transactions made by that entity on one (1) Claim Form, no matter how many separate accounts that entity has (e.g., an individual shareholder with multiple accounts should include all transactions made in all accounts on one (1) Claim Form).

All joint beneficial owners must sign the same Claim Form. If you acquired or were registered or beneficial security holders of Valeant securities in your name, you are the beneficial owner as well as the record owner. If, however, you acquired or were registered or beneficial security holders of Valeant securities and the securities were registered in the name of a third party, such as a nominee or brokerage firm, you are the beneficial owner of the securities, but the third party is the record owner.

Click here to review and complete the online claim form - it’s fast, easy and secure.

Agents, executors, administrators, guardians, and trustees must complete and sign the Claim Form on behalf of persons represented by them, and they must:

1. Expressly state the capacity in which they are acting;


2. Identify the name, account number, address and telephone number of the beneficial owner of (or other person or entity on whose behalf they are acting with respect to) the Valeant securities; and


3. Furnish herewith evidence of their authority to bind the person or entity on whose behalf they are acting. (Authority to complete and sign a Claim Form cannot be established by stockbrokers demonstrating only that they have discretionary authority to trade stock in another person’s accounts.)

Should it be necessary documentation such as a separation agreement may be submitted to show the agreement made between the joint beneficial owners (i.e: Each entitled to 50%).

Any documentation provided must include the claimant's name and address and account number.

Please Note: The Claims Administrator reserves the right to request additional information or documentation.

IMPORTANT: Spreadsheets, charts, tax forms, handwritten information, and other documentation prepared by the claimant are not considered adequate supporting documentation.

Nominee Claim Submissions

A Nominee Claim means an institution submitting a claim on their own behalf or on behalf of other beneficial owners or a claim preparer submitting on behalf of beneficial owners.

If you are a Nominee, you must provide the following five (5) documents:

You must complete one (1) Claimant Identification Page, (Insert Section and page) and one (1) Certification Page, (Insert Section and page) of a single claim form, which will serve as an "umbrella" or “master” claim form for all claims in your electronic claim submission.

1. ONE (1) CLAIM FORM

• The Claimant Identification Page must contain your institution contact information. The Certification Page must be signed by an authorized signatory who is listed on your signature verification document and must state the capacity (job) of the signatory.


• If you are filing on behalf of multiple beneficial owners, please include your company’s name as well as the term "Various Beneficial Owners". The correct complete unabbreviated name of each beneficial owner (without honorifics) must be provided for each claim in your electronic claim submission.


• Please note that only one (1) claim form is required regardless of the number of submissions.

Click here to download the Claim Form.

2. ONE (1) SIGNATURE VERIFICATION DOCUMENT

• You must provide a document verifying that the individual who signs the claim form and any supplemental documents is authorized to sign on behalf of his/her company.


• Some common types of documents that fulfill this requirement include the following: (Please note that some entities may have different documents that fulfill this requirement. If you cannot submit the documents listed below, you must submit an equivalent document):
  • Copy of filer’s By-Laws, including signature page(s)
  
  
  • Copy of filer’s Corporate Resolution, including signature page(s)
  
  
  • Notarized Affidavit or signed letter on your company’s letterhead by an officer of the filing institution or company clearly granting a specific individual(s) authorization or confirming his/her authority to sign on behalf of his/her institution or company.
  
  

3. ONE (1) DATA VERIFICATION DOCUMENT

You must provide a notarized affidavit or signed letter on your firm’s letterhead which meets the following criteria:

• Confirms the number of distinct accounts and transactions in your file;


• Disclosed the source of your data (i.e. internal data retention system);


• Attests to the truth and accuracy of the transactions and holdings on your electronic file; and


• Is executed by an authorized signatory who is listed on your signature verification document, and specifies both the capacity and contact information of that signatory.

4. ONE (1) AUTHORIZATION DOCUMENT (If filing on behalf of clients or customers)

• If you are an institution or claim preparer submitting on behalf of beneficial owners other than yourself, you must provide a current document verifying that you are authorized to file and sign claims on behalf of the beneficial owners of the securities.


• Some common types of documents that fulfill this requirement include the following:
  
  • Power of Attorney
  
  
  • Service Agreement
  
  
  • Signed/dated letter on client's company letterhead specifically granting your company authority to file/sign claims on their behalf
  
  
  • Notarized affidavit or signed letter on your company's letterhead confirming your authority to submit and sign claims on behalf of your clients. It must be executed by an officer of the company who is also listed on your signature verification document and reference the capacity and contact information of the signatory.
  
  

Please note that some entities may have different documents that fulfill this requirement. If you cannot submit the documents listed below, you MUST submit an equivalent document.

5. EXCEL SPREADSHEET CONTAINING TRANSACTIONS AND HOLDINGS

You must provide the holding and transactions of your client’s eligible securities by following the required format set out in the Electronic Filing Instructions.

Click here to download the Electronic Filing Instructions.

Click here to download the Microsoft Excel Preformatted Spreadsheet for submitting your transactions.

ADDITIONAL DOCUMENTATION (IF REQUESTED) - DATA INTEGRITY AUDIT

The Administrator may request random entities, as deemed appropriate by Epiq, who submit claims electronically to provide documentation to support certain transactions and/or holdings in specific claims. This data integrity audit is designed to verify the overall integrity of a data submission. Accordingly, the documentation provided must be independent in nature and sufficient to verify the validity and accuracy of the entire data submission. Even if you provided a letter/affidavit attesting to the truth and accuracy of your data when initially submitting your claim electronically, we will require specific documentary evidence (trade confirmations, monthly statement, or equivalent), to independently verify the details of the transactions and/or holdings requested, if your claim is selected for a data integrity audit.

Agents, executors, administrators, guardians, and trustees must complete and sign the Claim Form on behalf of persons represented by them, and they must:

1. Expressly state the capacity in which they are acting;


2. Identify the name, account number, address and telephone number of the beneficial owner of (or other person or entity on whose behalf they are acting with respect to) the Valeant securities; and


3. Furnish herewith evidence of their authority to bind the person or entity on whose behalf they are acting. (Authority to complete and sign a Claim Form cannot be established by stockbrokers demonstrating only that they have discretionary authority to trade stock in another person’s accounts.)

Any documentation provided must include the claimant's name and address and account number.

Please Note: The Administrator reserve the right to request additional information or documentation.

IMPORTANT: Spreadsheets, charts, tax forms, handwritten information, and other documentation prepared by the claimant are not considered adequate supporting documentation.

Where a Claim Form contains minor omissions or errors, the Claims Administrator shall correct such omissions or errors if the information necessary to correct the error or omission is readily available to the Claims Administrator.

In order to remedy any deficiency in the completion of a Claim Form, the Claims Administrator may require and request via email or mail if an email address is not available that additional information be submitted by a Class Member who submits a Claim Form. Such Class Members shall have until the later of ninety (90) days from the date of the request from the Claims Administrator or the Claims Bar Deadline on February 15, 2021 to rectify the deficiency.

Any person who does not respond to such a request for information within this period shall be barred from receiving any payments pursuant to the Settlement.

The account number is the account # where the shares were purchased (should match the documentation that you are submitting).

Please note: if you are submitting a claim for multiple accounts but the same shareholder, you must only submit one (1) claim.

The commissions must be included in the total purchase and total sale amount.

The Plan of Allocation provides a formula pursuant to which the Net Settlement Amount will be allocated to eligible Class Members on a pro rata basis. Because the Net Settlement Amount will be distributed pro rata, it is not possible to estimate the individual recovery and payment specifics of any individual Class Member until all the claims have been received and reviewed.

A copy of the Plan of Allocation and other related documentation is available by clicking here.

The Settlement was approved by the Superior Court of Québec on November 16, 2020.

The deadline to comment on or object to the Settlement was November 9, 2020.

If you did not opt out of the Settlement by June 19, 2018, you are automatically included as a Class Member and are bound by the terms of the Settlement.

The deadline to exclude yourself from the Settlement was June 19, 2018.

If you did not opt out of the Settlement by June 19, 2018, you are automatically included as a Class Member and are bound by the terms of the Settlement.

Members of the Settlement Class are bound by the terms of the Settlement Agreement.

The Court appointed the law firms Siskinds LLP, Koskie Minsky LLP, Faguy & Co., Strosberg Sasso Sutts LLP, Rochon Genova LLP, Morganti Legal P.C., Siskinds Desmeules s.e.n.c.r.l. and Investigation Counsel P.C to represent the Class. This firms are called Class Counsel. Class Counsel is tasked with acting in the best interests of the Class as a whole. You may contact Class Counsel for information about the Settlement.

Click here for Class Counsel’s contact information.

As part of the settlement, Class Counsel fees are thirty percent (30%) of the Settlement Fund and Administration Expenses and Litigation Disbursement Amount, plus tax, repayment of disbursements to Class Counsel, levies payable to the Fonds d'aide aux actions collectives, and a Plan of Allocation to distribute the Settlement Fund to the Settlement Class.

If you do nothing, you automatically remain a Class Member (if you qualify) and you are bound by the Settlement Agreement. You will no longer have the right to bring forth other legal proceedings in relation to the matters alleged in the Action against the Defendants, or any person released by the approved Settlement at your own cost and you will get no compensation.

The Settlement was approved by the Superior Court of Québec on November 16, 2020.

The deadline to comment on or object to the Settlement was November 9, 2020.

Questions for the Claims Administrator should be directed to:

Epiq Class Action Services Canada Inc.
Attention: Valeant Securities Class Action Settlement Claims Administrator
P.O. Box 507 STN B
Ottawa ON K1P 5P6
Email: info@ValeantSecuritiesSettlement.ca
Telephone: 1-833-290-4729
Fax: 1-866-262-0816

Questions for Class Counsel should be directed to:

In English:

Siskinds LLP
Valeant Securities Class Action Settlement
Suite 302 - 100 Lombard Street
Toronto ON M5C 1M3
Email: michael.robb@siskinds.com
Telephone: +1.800.461.6166 (toll free)
Telephone: +1.519.660.7872 (outside North America)
http://www.siskinds.com/valeant/

In French:

Faguy & Co.
Valeant Securities Class Action Settlement
Suite 200 - 329 de la Commune Street West
Montreal QC H2Y 2E1
Email: classactions@faguyco.com
Telephone: +1.514.285.8100 ext. 225
http://www.faguyco.com/class-actions/