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    June 8, 2018
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Notice of Proposed Settlement If you are a resident of Canada, other San Québec and own or use a Simplex or UnicanTM pushbutton lock, you may have a claim in a proposed class acton settement This notice may affect your rights. Please read it carefully Detailed information and updates are available on the Seziement The Proposed Setlement Class Members All residents of Canada, other than residents ot Quebec who uie or own a Smple or UnicanTM ModelSeries 1000, L1000, 2000, 3000, 6200 7000, 7100, 8000 r Fle Guard mechanical pusibution lock manufactured before January 1, 2011 rEnduser#7 or who purchased such a lock to Purpose of this Noice: A setlement has been reached in a proposed class action lawsuit led in the Ontario Supenior Court of Justice (Court) with respect to certain models f Simplex or UnicanTM mechanical pushbuton locks (Settiemen). The Plaintts claim Bat thplx or UnicanTM lacks were impeoperty designed and marketed. The Defendants have denied all claims and contirue to deny the Plaintifts alegations and maintain at Defend ants have not engaged in any wrongfulacts This Settlement is not an admissio of wrongdoing or an indication that any law was violated. The Defendants conckuded that t is in their best this lawsuit be resolved subject to and on the tems and conditions set forth herein The Settiem . The Settlement Benefts A) ment is not eflective unless and untl t is appro ved by the Cout Qualiying End-Use o Simplex or Unican mechanical pushbutton lock models listed above whose claims are approved are eligibile t0 receve one or more ot the foilowing, depending upon a variety oe dferent crtena: a freo doA-yourselfDrn upgrade K. that addresses tho design elements issue in the suit, a free do-t-yoursef om snield mat addresses the design elements at ssue in the asuill, ofr reduced-cost or free professioeal innstaiatio of the Upgrade k B) Qualiying Locksmtts with inventory of unused, resalable Simplex or Unican TM the Defendants did not already upgrade are eligible to exchange that eventory for new inventory that has been upgraded to address the design elements at issue in the ui leventory of the ised modes which has atready been upgraded bears a yellow Check Contents Seal Is Broken" tamper seal on the box lap M. The Settiement Approval Hearing: The Ontario Superior Court of Justice will hoild a hearing to consider whether to certity the action for setlement purposes, and approve the Settiement on August 7, 2018 a 1000 AM. in the Counhouse located at 130 Queer reet Wt Tront,Ontario Approval Hearing) The Cout must be satfed is fair, reasonable and in the best interests of V Your Options you are a Class Member, you may (1) object to the Setiement or (2 d Class Members who do nat wish to object to ee make representations regarding the proposed Settlement do not need to atiend the Approva Hearing in onder to be egble to benelt from he Settement is approved y the Court Class Members who de wish to object to or make reprventations regarding the proposed Setlemenit, ether directly or through their own legal counsel, must nebity Class Counsel of the nature and grounds of thei ejections or representations as well as the apprcimate date of their acquisiion of the Elected Lock and ts model number, in wrfing er by e-mail, by no later than July 27, 2018 This Notice summarues the proposed Settlement. More details are in ne Settlement Agreement, Fee more information on the lawsuit and the Setlement, cortact Class Counsel at the contact information below VIL Class Counsel Arn Gyam 79 Welington Street West TD Tower South Sute 2100 ON MSK 1H Te (416) 3494576 Fax (416) 868-0001 Email: Web: The Cout at the Approval Hearing will also consider a request from Cass counsel fees, dsbursements and taxes. C pursued this lawsuit whelly en a contingency basis and has ageeed that hey would only be paid ther legal fees if here was a Settiement or recovery following a successtul outcome. They will seek approval from the Cout of $296,460.17 plus applicable taxes and an honorarium payment of $2.500 to each of the hwo proposed Reprosent ative Plaintts This Notice has been approved by the Ontanio Superior Court of Jusbice