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HOUSEHOLD INTERNATIONAL SECURITIES CLASS ACTION VERDICT FUND

On May 7, 2009, a jury verdict in the case of Lawrence E. Jaffe Pension Plan v. Household International, Inc. et al., Lead Case No. 02-C-5893 (the “Litigation”), pending in the United States District Court for the Northern District of Illinois, Eastern Division, was returned in favor of the plaintiff Class and against defendants Household International, Inc., William Aldinger, David Schoenholz and Gary Gilmer. As a result of the jury verdict, Class Members who purchased or otherwise acquired Household International common stock during the period beginning March 23, 2001 through October 11, 2002 (the “Damages Period”) may be entitled to a recovery, subject to approval in a claims proceeding and the outcome of any appeals. Pursuant to the Jury Verdict, there will be no recovery for any purchases of Household International common stock made before March 23, 2001.

The Jury Verdict may result in payment to Class Members who (i) purchased Household International common stock during the Damages Period; (ii) filed a timely and valid Proof of Claim form; and (iii) suffered a Recognized Loss, which is calculated based on the inflation per share on each trading day set forth in the Jury Verdict and the Court-approved formula for calculating damages. Class Members whose claims are approved may be entitled to receive 100% of their Recognized Loss less their proportionate share of any attorneys’ fees and expenses which may be awarded by the Court.

THE DEADLINE TO FILE A PROOF OF CLAIM IN THIS MATTER WAS MAY 24, 2011. ANY AND ALL CLAIMS RECEIVED AFTER MAY 24, 2011 ARE LATE AND MAY BE BARRED FROM PARTICIPATION IN ANY DISTRIBUTION

This website is intended to provide certain background information regarding the Jury Verdict and subsequent proceedings.

SUMMARY OF THE LITIGATION

On August 19, 2002, Lawrence E. Jaffe Pension Plan initiated an action in the United States District Court for the Northern District of Illinois, Eastern Division, by complaint styled as Lawrence E. Jaffe Pension Plan v. Household International, Inc. et al., Lead Case No. 02-C-5893, alleging various violations of the federal securities laws against Household International, Inc. and certain of its executive officers. Thereafter, a number of similar class action complaints were filed.

On December 9, 2002, the Court consolidated the cases. On December 18, 2002, the Court appointed Glickenhaus & Co., PACE Industry Union-Management Pension Fund, and International Union of Operating Engineers Local No. 132 Pension Plan as Lead Plaintiffs and approved its selection of Robbins Geller Rudman & Dowd LLP as Lead Counsel.

On March 13, 2003, Lead Plaintiffs filed a Corrected Amended Complaint (“Amended Complaint”) for violations of the federal securities laws, which included claims for violations of §§10(b) and 20(a) of the Securities Exchange Act of 1934 and Rule 10b-5 promulgated thereunder, and §§11, 12(a)(2) and 15 of the Securities Act of 1933. The named defendants in the Amended Complaint were Household International, Inc.; Officer Defendants William Aldinger, David Schoenholz and Gary Gilmer; Director Defendants Robert Darnall, Gary Dillon, John Edwardson, Mary Evans, J. Dudley Fishburn, Cyrus Friedheim, Louis Levy, George Lorch, John Nichols, James Pitblado, S. Jay Stewart, Louis Sullivan; HFC Director Defendant J.A. Vozar; Auditor Defendant Arthur Andersen; and Investment Bank Defendants Merrill Lynch and Goldman Sachs. Lead Plaintiffs alleged that defendants made materially false representations and omissions in public filings, press releases, analyst reports and other public statements concerning Household, its operations, and financial condition during the period October 23, 1997 through October 11, 2002 (the “Class Period”).

On March 19, 2004, the Court granted in part and denied in part defendants’ motion to dismiss, dismissing claims against the Director Defendants, Goldman Sachs and Merrill Lynch, and upholding claims against Household International, Inc. William Aldinger, David Schoenholz, Gary Gilmer, J.A. Vozar, and Arthur Andersen. Thereafter, Defendants filed answers denying all material allegations in the Amended Complaint and asserting various defenses thereto.

On December 3, 2004, the Court certified a Class in this case, defined as: all Persons who purchased or otherwise acquired the securities of Household during the period between October 23, 1997 and October 11, 2002. Excluded from the Class are defendants herein, members of defendants’ immediate families, any person, firm, trust, corporation, officer, director or other individual or entity in which any defendant has a controlling interest or which is related to or affiliated with any defendant, and the legal representatives, agents, affiliates, heirs, successors-in-interest or assigns of any such excluded party.

On June 16, 2005, the Class and Arthur Andersen reached a settlement for $1.5 million (the “Andersen Settlement”). On January 31, 2006, a notice was sent to Class Members informing them of the Andersen Settlement, of the certification of the Class, and notifying Class Members of the right to be excluded from the Litigation. On April 6, 2006, the Court approved the settlement.

On February 28, 2006, the Court issued an order that all claims based on purchases of Household stock from October 23, 1997 through July 29, 1999 were barred by the applicable statute of limitations provisions of the federal securities laws. On June 30, 2008, the Court ruled that trial in this case would commence on March 30, 2009.

Copies of certain pleadings, orders and other documents filed in this case may be accessed on this website by clicking on Pleadings, Orders and other documents filed in this litigation. A complete copy of the case file may also be inspected at the Office of the Clerk of the United States District Court, Northern District of Illinois, Eastern Division, Everett McKinley Dirksen United States Courthouse, 219 South Dearborn Street, Chicago, IL 60604, during business hours of each business day, under Case No. 02-C-5893.

THE JURY VERDICT

A six (6) week trial commenced on March 30, 2009 against Household International, Inc., William Aldinger, David Schoenholz and Gary Gilmer (the “Trial Defendants”) on behalf of all purchasers of Household stock from July 30, 1999 through October 11, 2002. On May 7, 2009, the jury returned a verdict in the case (the “Jury Verdict”), finding that: (i) all the Trial Defendants violated §10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5; and (ii) all the Trial Defendants except Gilmer violated §20(a) of the Securities Exchange Act of 1934 in connection with public statements made about Household during the period March 23, 2001 to October 11, 2002. The jury found that the Trial Defendants did not violate the federal securities laws related to any purchases made prior to March 23, 2001. The jury also awarded per share damages for each trading day during the Damages Period.

All of the Court’s rulings and the Jury Verdict are subject to appeal. An appellate court may uphold, modify or reverse the verdict.

SUBMISSION OF CLAIMS FOR DAMAGES BY CLASS MEMBERS AND POST-TRIAL PROCEEDINGS

Class Members were required to submit their completed Proof of Claim forms on or before May 24, 2011. Class Members who (i) purchased Household International common stock during the Damages Period; (ii) file a timely and valid Proof of Claim form; and (iii) evidence a Recognized Loss, which is calculated based on the inflation per share on each trading day set forth in the Jury Verdict and the Court-approved formula for calculating damages, may be entitled to damages.

If you failed to file a claim, you will not share in the proceeds of any judgment rendered as a result of the Jury Verdict or the Andersen Settlement which was previously approved by the Court.

As of December 22, 2011, the Court-appointed claims administrator, Gilardi & Co. LLC (“Gilardi”), had received 80,112 claims submitted by potential Class Members. Gilardi completed its review of submitted claims on December 22, 2011. Relying on the Court’s prescribed method of calculating allowed losses, Gilardi determined that there are 45,921 claims that generate an allowed loss. The aggregate loss amount for the 45,921 claims, according to Gilardi’s computation, is $2,225,884,588.31. Gilardi submitted a report to the Court on December 22, 2011 identifying the claims that Gilardi recommends for rejection, as well as the claims that Gilardi believes generate an allowed loss.

As to the 45,921 claims that Gilardi believes generate an allowed loss, the Court ordered Defendants to file any objections to the claims in terms of (a) calculation of the amount; (b) submission of the claim without proper authority of the actual Class Member; or (c) incompleteness, duplication of another claim or some mechanical deficiency in the claim submission itself on or before February 27, 2012. On March 28, 2012, Plaintiffs responded on behalf of the Class Members to Defendants’ objections. The parties and the Court have resolved these ministerial objections as to some claims, while the objections to other claims will need to be resolved by a Court-appointed Special Master.

The Special Master issued a Report and Recommendation on July 11, 2013 setting forth his initial findings and categorizing the claims as follows: List 1 identified 10,902 claims valued at almost $1.5 billion (before prejudgment interest) that were entitled to judgment; List 2 identified 133 claims valued at approximately $58 million that must be resolved at trial; List 3 identified approximately 2,500 claims valued at about $60 million that should be rejected due to the claimant’s failure to answer the claim form question. Approximately 30,000 other claims, which were not set forth in Lists 1-3, remained subject to outstanding objections at that time. Ultimately, the Special Master will have to resolve objections to these claims.

On October 4, 2013, the Court entered an Order denying Defendants’ post-trial motions for judgment as a matter of law and for a new trial. The Court also ordered that Defendants pay Class Members prejudgment interest beginning on October 11, 2002, until the entry of Judgment. On October 17, 2013, the Court entered judgment in favor of 10,902 Class Members with claims valued at $1,476,490,844.21. (Any ministerial objections to those 10,902 claims had already been resolved in favor of the Class Member.) The Court also awarded prejudgment interest of $986,408,772 in favor of these Class Members. The total amount of this Judgment is $2,462,899,616.21. The Judgment, dated October 17, 2013, identifies the 10,902 Class Members by claimant name and claim number. If you wish to confirm that your claim has been allowed, you may access the Judgment at the Office of the Clerk of Court or on the internet at www.householdfraud.com.

As set forth above, the parties are continuing to litigate and, at times, resolve Defendants’ objections to approximately 30,000 additional claims in ongoing proceedings before the Special Master.

THE APPEAL

Defendants have appealed from the Verdict and October 17, 2013 Judgment in favor of 10,902 Class Members. The appeal was fully briefed as of April 11, 2014. The Court of Appeals for the Seventh Circuit will hear argument on the appeal on May 29, 2014.


ROBBINS GELLER
RUDMAN & DOWD LLP
Michael J. Dowd
655 West Broadway, Suite 1900
San Diego, CA 92101-3301
HouseholdClaims@rgrdlaw.com
Lead Counsel for Plaintiffs


For your convenience, copies of all Pleadings, Orders and other documents filed in this Litigation are accessible by clicking on Pleadings, Orders and other documents filed in this Litigation.