In re: Dial Complete Marketing and
Sales Litigation

United States District Court
for District of New Hampshire

MDL Docket No. 11-md-2263-SM


15. How do I tell the Court that I disagree with the Settlement?

Any Class Member who does not timely and properly opt out of the Settlement may object to the fairness, reasonableness, or adequacy of the proposed Settlement under Federal Rule of Civil Procedure 23. Each Class Member who wishes to object to any term of this Agreement must do so, in writing, by filing a written objection with the Clerk of the Court and mailing it to Settlement Class Counsel, counsel for Dial, and the Settlement Notice and Claims Administrator.

The written objection must include: (a) copies of any materials that the objector intends to submit to the Court or present at the Fairness Hearing; (b) be personally signed by the Class Member and, if represented, by his or her counsel; (c) include information or documents sufficient to show that the objector is a Class Member; and (d) clearly state in detail (i) the legal and factual ground(s) for the objection, (ii) the Class Member’s name, mailing address, email address, and telephone number, (iii) if represented by counsel, such counsel’s name, email address, mailing address, and telephone number, (iv) any request to present argument to the Court at the Fairness Hearing; (v) previous objections that the Class Member has filed in class action settlements in the past five years and the results of those objections (including any settlements that were reached concerning his or her objection); and (vi) previous objections that the objecting Class Member’s class counsel has filed either in a representative capacity or on their own behalf in the past five years (including any settlements that were reached concerning those objections).

Your objection, along with any supporting material you wish to submit, must be filed with the Court, with a copy delivered to Settlement Class Counsel, Defendant’s Counsel and the Settlement Notice & Claims Administrator no later than March 13, 2019 at the following addresses:

Clerk of the Court


United States District Court
for the District of New Hampshire
55 Pleasant Street Room 110
Concord, NH 03301

Settlement Class Counsel


Lucy J. Karl
Shaheen & Gordon, P.A.
P.O. Box 2703
107 Storrs Street
Concord, NH 03301

Counsel for Dial


Patrick Haney
Kirkland & Ellis LLP
655 Fifteenth Street NW
Washington DC 20005

Settlement Notice & Claims Administrator


Class Action Objections
ATTN: Soap Settlement
PO BOX 58220
1500 John F Kennedy Blvd
Suite C31
Philadelphia, PA 19102


Class Members have the option to appear at the Fairness Hearing, either in person or through personal counsel hired at the Class Member’s expense, to object to the fairness, reasonableness, or adequacy of the Settlement, the award of attorneys’ fees and costs, or the proposed incentive awards to the Class Representatives. However, Class Members (with or without their attorneys) intending to make an appearance at the Fairness Hearing must so inform the Parties and the Court on or before March 13, 2019 by providing a “Notice of Intention to Appear” to the parties listed above.




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