The Court authorized the Notice be sent to you because you or someone in your family or an investment account for which you serve as custodian may have purchased shares of Amneal Common Stock during the Settlement Class Period. The Court has directed us to send you the Notice because, as a potential Settlement Class Member, you have the right to understand how this class action lawsuit may generally affect your legal rights. If the Court approves the Settlement and the Plan of Allocation (or some other plan of allocation), the Claims Administrator selected by Plaintiff and approved by the Court will make payments pursuant to the Settlement after any objections and appeals are resolved. 

The purpose of the Notice is to inform you 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. It is also being sent to inform you of the terms of the proposed Settlement and of a hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement, the proposed Plan of Allocation, and Class Counsel’s motion for an award of attorneys’ fees and Litigation Expenses (“Settlement Hearing”). See paragraphs 57-58 within the Notice for details about the Settlement Hearing, including the date and location of the hearing. 

The issuance of the Notice is not an expression of any opinion by the Court concerning the merits of any claim in the Action, and the Court still must decide whether to approve the Settlement. If the Court approves the Settlement and a plan of allocation, then payments to Authorized Claimants will be made after any appeals are resolved and after the completion of all claims processing. Please be patient, as this process can take some time. 

Amneal is a global pharmaceutical company that develops, licenses, manufactures, markets, and distributes generic and specialty pharmaceutical products in a variety of dosage forms and therapeutic categories. Amneal was formed in May 2018 as the result of the business combination of Legacy Amneal and Impax. Beginning on May 7, 2018, Amneal Common Stock traded on the NYSE under the ticker symbol AMRX. 

On December 18, 2019, Plaintiff filed and served a class action complaint in the Superior Court of New Jersey (Somerset County, Law Division) (the “Court”), styled Cambridge Retirement System v. Amneal Pharmaceuticals Inc., et al., Docket No. SOM-L-1701-19, asserting claims for violations of Sections 11, 12(a)(2), and 15 of the Securities Act against Defendants. 

On March 11, 2020, Plaintiff filed and served its Amended Class Action Complaint (the “Amended Complaint”) asserting claims under Section 11 of the Securities Act against all Defendants, under Section 12(a)(2) of the Securities Act against Amneal and Amneal Holdings, and under Section 15 of the Securities Act against the Individual Defendants. In the Amended Complaint, Plaintiff alleged that the registration statement and prospectus, as amended (collectively, the “Registration Statement”) issued in connection with the business combination of Legacy Amneal and Impax contained materially untrue statements and omissions of material fact concerning alleged collusive conduct related to the market for generic drugs. Plaintiff alleged that a result of the foregoing, Defendants’ statements in the Registration Statement concerning Amneal’s operations, financial results, and exposure to Legacy Amneal’s illegal conduct were materially false and misleading. 

On March 13, 2020, Plaintiff moved to appoint Bernstein Litowitz Berger & Grossmann LLP as interim class counsel for the putative class and Carella Byrne as interim local class counsel. The motion was unopposed and the Court granted that motion on April 9, 2020. 13. On March 31, 2020, Defendants filed their motion to dismiss the Amended Complaint. On May 15, 2020, Plaintiff filed its memorandum of law in opposition to that motion. On June 12, 2020, Defendants filed their reply papers in support of the motion to dismiss. 

On July 15, 2020, the Court filed a Statement of Reasons denying Defendants’ motion to dismiss the Amended Complaint. Discovery in the Action commenced in August 2020. Plaintiff prepared and served Requests for the Production of Documents and Interrogatories on Defendants on August 20, 2020. Additionally, Plaintiff prepared and served document subpoenas on twelve non-parties. Plaintiff exchanged numerous letters and held numerous meet and confers with Defendants concerning discovery issues. Plaintiff also noticed the deposition of a third party and deposed Defendants’ expert Joel Seligman. Defendants and third parties produced a total of over 1,300,000 pages of documents to Plaintiff, and Plaintiff produced over 22,000 pages of documents to Defendants in response to their discovery requests. 

On October 30, 2020, Plaintiff filed its motion for class certification and supporting papers (the “Class Certification Motion”). On March 5, 2021, Defendants filed their opposition to Plaintiff’s Class Certification Motion. On March 26, 2021, Plaintiff filed its reply papers in further support of the Class Certification Motion. On August 16, 2021, Defendants filed a sur-reply in further opposition to Plaintiff’s Class Certification Motion. On October 8, 2021, Plaintiff filed a sur-sur-reply in further support of Plaintiff’s Class Certification Motion. Four depositions were conducted in connection with class certification discovery—a representative of Plaintiff, two of Plaintiff’s experts and one of Defendants’ experts. On October 6, 2021, Defendants filed a motion to exclude the expert report of Harvey L. Pitt, one of Plaintiff’s experts who had filed a report in support of Plaintiff’s Class Certification Motion (the “Motion to Exclude”). On October 14, 2021, Plaintiff served and filed its opposition to the Motion to Exclude, and on October 18, 2021, Defendants served and filed their reply to the Motion to Exclude. The Class Certification Motion and the Motion to Exclude were still pending at the time the Settlement was reached.

On March 26, 2021, Plaintiff also filed a motion for leave to file a Second Amended Complaint in response to arguments made by Defendants in their opposition to Plaintiff’s Class Certification Motion. Defendants did not oppose this motion, which was then granted by the Court on April 27, 2021. On May 7, 2021, Defendants filed a motion to dismiss the Second Amended Complaint. On June 4, 2021, Plaintiff filed its opposition to the motion to dismiss the Second Amended Complaint. On June 30, 2021, Defendants filed their reply in further support of the motion to dismiss the Second Amended Complaint. The motion to dismiss the Second Amended Complaint was still pending at the time the Settlement was reached.

On November 17, 2020, the Court ordered the parties to mediate this case in good faith and with a sense of urgency. In response, the Parties agreed to engage in private mediation and retained former United States District Court Judge Layn R. Phillips to act as mediator in the Action. Pursuant to a schedule set by Judge Phillips, the Parties exchanged mediation statements on April 2, 2021, and participated in a full-day mediation session via Zoom on April 16, 2021. The April 16, 2021 mediation did not result in an agreement to resolve the Action.

While the Parties continued to conduct legal briefing on the Class Certification Motion and the motion to dismiss the Second Amended Complaint and engaged in discovery, they also continued settlement negotiations with the assistance of Judge Phillips. On November 17, 2021, Judge Phillips issued a mediator’s recommendation to settle the action for $25 million in cash. On December 2, 2021, the Parties accepted Judge Phillips’ recommendation and reached an agreement in principle to settle the Action for $25 million. On February 7, 2022, the Parties entered a term sheet memorializing the principal terms of the Settlement.

On March 28, 2022, the Parties entered into the Stipulation, which sets forth the full terms and conditions of the Settlement. The Stipulation can be viewed on the Important Documents page of this website.

On April 29, 2022, the Court preliminarily approved the Settlement and authorized notice of the Settlement to potential Settlement Class Members. On May 3, 2022, the Court entered an amended order, which scheduled the Settlement Hearing to consider whether to grant final approval of the Settlement for August 15, 2022 at 9:00 a.m. 

If you are a member of the Settlement Class, you are subject to the Settlement, unless you timely request to be excluded from the Settlement Class. The Settlement Class certified by the Court, solely for purposes of effectuating the Settlement, consists of: 

all persons and entities who purchased or otherwise acquired Amneal Common Stock issued in connection with the business combination between Legacy Amneal and Impax pursuant or traceable to, or registered in the Registration Statement, during the Settlement Class Period [i.e., from May 7, 2018 through May 5, 2021, inclusive], and were damaged thereby. 

Excluded from the Settlement Class are: (i) Defendants; (ii) Officers, directors, and affiliates of Amneal, Amneal Holdings, Legacy Amneal, or Impax, currently or during the Settlement Class Period; (iii) members of the Immediate Families of any individual included in (i) or (ii); (iv) any entity in which any Defendant has or had a controlling interest; and (v) the legal representatives, heirs, successors, or assigns of any person or entity included in (i), (ii) or (iii). Also excluded from the Settlement Class will beany persons or entities who exclude themselves by submitting a request for exclusion that is accepted by the Court. See “What If I Do Not Want To Be A Member Of The Settlement Class? How Do I Exclude Myself?”, below. 

Please note: Receipt of the Notice does not mean that you are a Settlement Class Member or that you will be entitled to receive proceeds from the Settlement. 

If you wish to be eligible to participate in the distribution of proceeds from the Settlement, you are required to submit the Claim Form that is being distributed with the Notice and the required supporting documentation postmarked (if mailed), or online, no later than September 26, 2022. 

Plaintiff and Class Counsel believe that the claims asserted against Defendants have merit. They recognize, however, the significant expense and length of the continued proceedings that would be necessary to pursue the claims against Defendants through resolution of the pending motions for class certification and for dismissal of the Second Amended Complaint, the completion of substantial fact and expert discovery, summary judgment, trial, and appeals. 

Plaintiff and Class Counsel also recognized that there were significant risks in this litigation that could have led to no recovery or a lesser recovery in the Action. Defendants have argued, and would continue to argue, that Plaintiff would not be able to prove all of the elements of their Securities Act claims and would be unable to certify a class. First, Defendants have argued, and would continue to argue, that—because Amneal had issued identical common shares pursuant to two different registration statements (one issued in November 2017 and another in May 2018) and the shares registered under both registration statements began trading at the same time in connection with the business combination of Legacy Amneal and Impax—Plaintiff and other Settlement Class Members would not be able to trace the shares they purchased during the Settlement Class Period to one specific registration statement, which Defendants contended was required under the applicable case law. Second, Defendants argued that any claims relating to the November 2017 registration were also time barred under the Securities Act’s statute of limitations and statute of repose. Third, Defendants argued that Plaintiff would be unable to establish, at summary judgment or trial, that the alleged misstatements were in fact false. Because governmental investigations into Amneal’s alleged anticompetitive behavior have not resulted in any charges (let alone a verdict or findings of fact), Defendants would argue that Plaintiff would have to prove the both the existence of the underlying anticompetitive behavior and that Defendants made a false or misleading statement or omission in order to succeed in this Action. Defendants had also indicated that they would oppose certification of the class, and would argue that Plaintiff was not an adequate representative of other class members and that individual issues as to class members’ knowledge and damages would predominate over common issues. Finally, with respect to damages, Defendants had substantial arguments that damages available would be significantly reduced because Defendants would be able to show that many of the declines in the price of Amneal common stock were not caused by the alleged misstatements. While Plaintiff had responses to all of these issues, Plaintiff and Class Counsel recognize that that continued litigation posed substantial risks for the Settlement Class. 

In light of these risks, the amount of the Settlement, and the immediacy of recovery to the Settlement Class, Plaintiff and Class Counsel believe that the proposed Settlement is fair, reasonable, and adequate, and in the best interests of the Settlement Class. Plaintiff and Class Counsel believe that the Settlement provides a favorable result for the Settlement Class, namely $25,000,000 in cash (less the various deductions described in the Notice), as compared to the risk that the claims in the Action would produce a smaller, or no, recovery after full discovery, a class certification motion, summary judgment, trial, and appeals, possibly years in the future.

If there were no Settlement, and Plaintiff failed to establish any essential legal or factual element of its claims against Defendants, neither Plaintiff nor the other members of the Settlement Class would recover anything from Defendants. Also, if Defendants were successful in establishing any of their defenses either at summary judgment, at trial, or on appeal, the Settlement Class could recover less than the amount provided in the Settlement, or nothing at all.

 As a Settlement Class Member, you are represented by Plaintiff and Class Counsel, unless you enter an appearance through counsel of your own choice and at your own expense. You are not required to retain your own counsel, but if you choose to do so, such counsel must file a notice of appearance on your behalf and must serve copies of his or her appearance on the attorneys listed in the section entitled, “When And Where Will The Court Decide Whether To Approve The Settlement?,” see below. 

If you are a Settlement Class Member and do not wish to remain a Settlement Class Member, you must exclude yourself from the Settlement Class by following the instructions in the section entitled, “What If I Do Not Want To Be A Member Of The Settlement Class? How Do I Exclude Myself?,” see below.

If you are a Settlement Class Member and you wish to object to the Settlement, the Plan of Allocation, and/or Class Counsel’s application for attorneys’ fees and Litigation Expenses, and if you do not exclude yourself from the Settlement Class, you may present your objections by following the instructions in the section entitled, “When And Where Will The Court Decide Whether To Approve The Settlement?,” see below. 

If you are a Settlement Class Member and you do not exclude yourself from the Settlement Class, you will be bound by any orders issued by the Court. If the Settlement is approved, the Court will enter a judgment (“Judgment”). The Judgment will dismiss with prejudice the claims against Defendants and will provide that, upon the Effective Date of the Settlement, Plaintiff and each of the other Settlement Class Members, on behalf of themselves, and their respective heirs, executors, administrators, predecessors, successors, or assigns, in their capacities as such: (i) will have fully, finally, and forever compromised, settled, released, resolved, relinquished, waived, and discharged each and every Released Plaintiff’s Claim (as defined in below) against Defendants and the other Defendants’ Releasees (as defined below), (ii) will have covenanted not to sue, directly or indirectly, any of the Defendants’ Releasees with respect to any or all of the Released Plaintiff’s Claims; and (iii) will forever be barred and enjoined from directly or indirectly prosecuting, filing, commencing, instituting, maintaining, or intervening in any action, suit, cause of action, arbitration, claim demand, or other proceeding in any jurisdiction, on their own behalf or in a representative capacity, that is based upon or arises out of any or all of the Released Plaintiff’s Claims against any of the Defendants and the other Defendants’ Releasees. 

"Released Plaintiff’s Claims” means all claims, rights, actions, issues, controversies, causes of action, duties, obligations, demands, debts, sums of money, suits, contracts, agreements, promises, damages, and liabilities of every nature and description, including both known claims and Unknown Claims, that Plaintiff or any other member of the Settlement Class had, has, or may in the future have against the Defendants’ Releasees: (i) that were asserted in the Complaint; (ii) could have been asserted in the Action or any other forum (including, without limitation, any federal or state court, or in any other court, arbitration proceeding, administrative agency, or other forum, in the United States or elsewhere) arising out of or relating to (a) the purchase, acquisition, or sale of Amneal Common Stock during the Settlement Class Period, and (b) the acts, facts, matters, allegations, transactions, events, disclosures, occurrences, representations, statements, acts, omissions, or failures to act, that were alleged, set forth, referred to, or involved in the Action or the Complaint; and (iii) any claims arising out of or relating to the defense, settlement, or resolution of the Action. For the avoidance of doubt, Released Plaintiff’s Claims do not include: (i) any claims relating to the enforcement of the Settlement; (ii) any claims by any governmental entity that arise out of any governmental investigation of Defendants relating to the wrongful conduct alleged in the Action; (iii) any claims of any person or entity that submits a request for exclusion that is accepted by the Court; and (iv) the antitrust or competition law claims asserted in In re: Generic Pharmaceuticals Pricing Antitrust Litigation, MDL 2724 (E.D. Pa.). 

“Defendants’ Releasees” means Defendants and their respective present and former parents, affiliates, subsidiaries, divisions, directors, Officers, general partners and limited partners, successors in interest, including but without limitation (as applicable to either (i) an Individual Defendant or (ii) the corporate Defendant and its respective present and former parents, affiliates, subsidiaries, divisions, directors, Officers, general partners and limited partners, or successors in interest), any person or entity in which any Defendant has or had a controlling interest, the present and former members of the Immediate Family, heirs, principals, trustees, trusts, executors, administrators, predecessors, successors, assigns, members, agents, subsidiaries, employees, Officers, managers, directors, general partners, limited partners, bankers, actuarial and other consultants, attorneys, accountants, auditors, representatives, estates, divisions, advisors, estate managers, indemnifiers, and insurers of each of the foregoing persons and entities, in their respective capacities as such. 

“Unknown Claims” means any Released Plaintiff’s Claims that Plaintiff or any other Settlement Class Member does not know or suspect to exist in his, her, or its favor at the time of the release of such claims, and any Released Defendants’ Claims that any Defendant does not know or suspect to exist in his, her, or its favor at the time of the release of such claims, and that, if known by him, her, or it, might have affected his, her, or its decision(s) with respect to this Settlement. With respect to any and all Released Claims, the Parties stipulate and agree that, upon the Effective Date of the Settlement, Plaintiff and Defendants shall expressly waive, and each of the other Settlement Class Members shall be deemed to have waived, and by operation of the Judgment or Alternate Judgment, if applicable, shall have expressly waived, any and all provisions, rights, and benefits conferred by any law of any state or territory of the United States or principle of common law or foreign law that is similar, comparable, or equivalent to California Civil Code § 1542, which provides: A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party. Plaintiff and Defendants acknowledge, and each of the other Settlement Class Members shall be deemed by operation of law to have acknowledged, that the foregoing waiver was separately bargained for and a key element of the Settlement. 

Pursuant to the Judgment, without further action by anyone, upon the Effective Date of the Settlement, Defendants, on behalf of themselves, and their respective heirs, executors, administrators, predecessors, successors, and assigns, in their capacities as such, will have fully, finally, and forever compromised, settled, released, resolved, relinquished, waived, and discharged each and every Released Defendants’ Claim (as defined below) against Plaintiff and the other Plaintiff’s Releasees (as defined below). This release shall not apply to any person or entity who or which submits a request for exclusion from the Settlement Class that is accepted by the Court. 

"Released Defendants’ Claims” all claims and causes of action of every nature and description, whether known claims or Unknown Claims, whether arising under federal, state, common or foreign law, that arise out of or relate to the initiation, prosecution, settlement, or resolution of the Action. Released Defendants’ Claims do not include: (i) any claims relating to the enforcement of the Settlement; or (ii) any claims against any person or entity that submits a request for exclusion from the Settlement Class that is accepted by the Court. 

“Plaintiff’s Releasees” means Plaintiff, Plaintiff’s Counsel, Settlement Class Members, and their respective predecessors, successors, parents, direct and indirect subsidiaries, affiliates, related entities and divisions, and any and all present or former officers, directors, employees, agents,
shareholders, attorneys, and representatives and assigns of any of the foregoing. 

To be eligible for a payment from the proceeds of the Settlement, you must be a member of the Settlement Class and you must timely complete and return the Claim Form with adequate supporting documentation postmarked (if mailed), or submitted online under File a Claim, no later than September 26, 2022. A Claim Form is included with the Notice, or you may obtain one from the website maintained by the Claims Administrator, or you may request that a Claim Form be mailed to you by calling the Claims Administrator toll free at 866-615-0973, or by emailing the Claims Administrator at info@AmnealSecuritiesLitigation.com. Please retain all records of your ownership of and transactions in Amneal Common Stock, as they may be needed to document your Claim. If you request exclusion from the Settlement Class or do not submit a timely and valid Claim Form, you will not be eligible to share in the Net Settlement Fund.

At this time, it is not possible to make any determination as to how much any individual Settlement Class Member may receive from the Settlement.

Pursuant to the Settlement, Defendants shall pay or cause to be paid $25,000,000 in cash. The Settlement Amount will be deposited into an escrow account. The Settlement Amount plus any interest earned thereon is referred to as the “Settlement Fund.” If the Settlement is approved by the Court and the Effective Date occurs, the “Net Settlement Fund” (that is, the Settlement Fund less (i) any Taxes; (ii) any Notice and Administration Costs; (iii) any Litigation Expenses awarded by the Court; (iv) any attorneys’ fees awarded by the Court; and (v) any other costs or fees approved by the Court) will be distributed to Settlement Class Members who submit valid Claim Forms in accordance with the proposed Plan of Allocation or such other plan of allocation as the Court may approve. 

The Net Settlement Fund will not be distributed unless and until the Court has approved the Settlement and a plan of allocation, and the time for any petition for rehearing, appeal, or review, whether by certiorari or otherwise, has expired.

Neither Defendants, the Defendants’ Releasees, nor any other person or entity who or which paid any portion of the Settlement Amount on their behalf are entitled to get back any portion of the Settlement Fund once the Court’s order or Judgment approving the Settlement becomes Final. Defendants and the other Defendants’ Releasees shall not have any liability, obligation, or responsibility for the administration of the Settlement, the disbursement of the Net Settlement Fund, or the Plan of Allocation.

Approval of the Settlement is independent from approval of a plan of allocation. Any determination with respect to a plan of allocation will not affect the Settlement, if approved.

Unless the Court otherwise orders, any Settlement Class Member who fails to submit a Claim Form postmarked (if mailed), or online, on or before September 26, 2022, shall be fully and foreverbarred from receiving payments pursuant to the Settlement but will in all other respects remain a Settlement Class Member and be subject to the provisions of the Stipulation, including the terms of any Judgment entered and the Releases given. This means that each Settlement Class Member releases the Released Plaintiff’s Claims (as defined above) against the Defendants’ Releasees (as defined above) and will be permanently barred and enjoined from bringing any action, claim, or other proceeding of any kind against the Defendants’ Releasees with respect to the Released Plaintiff’s Claims whether or not such Settlement Class Member submits a Claim Form. 

Participants in and beneficiaries of any employee retirement and/or benefit plan covered by ERISA (“ERISA Plan”) should NOT include any information relating to shares of Amneal Common Stock purchased through the ERISA Plan in any Claim Form they submit in this Action. They should include ONLY those eligible shares of Amneal Common Stock purchased outside of an ERISA Plan. Claims based on any ERISA Plan’s purchases of Amneal Common Stock during the Settlement Class Period may be made by the plan’s trustees. 

The Court has reserved jurisdiction to allow, disallow, or adjust on equitable grounds the Claim of any Settlement Class Member. 

Each Claimant shall be deemed to have submitted to the jurisdiction of the Court with respect to his, her, or its Claim Form. 

Only Settlement Class Members, i.e., persons and entities who purchased Amneal Common Stock during the Settlement Class Period, will be eligible to share in the distribution of the Net Settlement Fund. Persons and entities who are excluded from the Settlement Class by definition or who exclude themselves from the Settlement Class pursuant to an exclusion request will not be eligible to receive a distribution from the Net Settlement Fund and should not submit Claim Forms. The only security that is included in the Settlement is Amneal Class A common stock (“Amneal Common Stock”). 

Appendix A to the Notice sets forth the Plan of Allocation for allocating the Net Settlement Fund among Authorized Claimants, as proposed by Plaintiff. At the Settlement Hearing, Class Counsel will request the Court approve the Plan of Allocation. The Court may modify the Plan of Allocation, or approve a different plan of allocation, without further notice to the Settlement Class. 

Plaintiff’s Counsel has not received any payment for their services in pursuing claims against Defendants on behalf of the Settlement Class; nor have Plaintiff’s Counsel been paid for their litigation expenses. Before final approval of the Settlement, Class Counsel will apply to the Court for an award of attorneys’ fees to Plaintiff’s Counsel in an amount not to exceed 28% of the Settlement Fund. At the same time, Class Counsel also intends to apply for payment from the Settlement Fund of Plaintiff’s Counsel’s Litigation Expenses in a total amount not to exceed $650,000, which may include a request for a service award to Plaintiff, including for reimbursement of its costs and expenses related to its representation of the Settlement Class. The Court will determine the amount of any award of attorneys’ fees or Litigation Expenses. Such sums as may be approved by the Court will be paid from the Settlement Fund. Settlement Class Members are not personally liable for any such fees or expenses.

Each Settlement Class Member will be bound by all determinations and judgments in this lawsuit related to the Settlement, whether favorable or unfavorable, unless such person or entity mails or delivers a written request for exclusion addressed to: Amneal Securities Litigation, EXCLUSIONS, c/o JND Legal Administration, P.O. Box 91234, Seattle, WA 98111. The request for exclusion must be received no later than July 25, 2022. You will not be able to exclude yourself from the Settlement Class after that date. 

Each request for exclusion must: (i) state the name, address, and telephone number of the person or entity requesting exclusion, and in the case of entities, the name and telephone number of the appropriate contact person; (ii) state that such person or entity “requests exclusion from the Settlement Class in Cambridge Retirement System v. Amneal Pharmaceuticals, Inc., SOM-L-1701-19, Superior Court of New Jersey (Somerset County, Law Division)”; (iii) state the number of shares of Amneal Common Stock that the person or entity requesting exclusion purchased/acquired and/or sold during the Settlement Class Period (i.e., from May 7, 2018, through May 5, 2021, inclusive), as well as the date, number of shares, and price of each such purchase/acquisition and sale; and (iv) be signed by the person or entity requesting exclusion or an authorized representative.

A request for exclusion shall not be valid and effective unless it provides all the information called for in paragraph 51 within the Notice and is received within the time stated above or is otherwise accepted by the Court. 

If you do not want to be part of the Settlement Class, you must follow these instructions for exclusion even if you have pending, or later file, another lawsuit, arbitration, or other proceeding relating to any Released Plaintiff’s Claim against any of the Defendants’ Releasees. Excluding yourself from the Settlement Class is the only option that allows you to be part of any other current or future lawsuit against Defendants or any of the other Defendants’ Releasees concerning the Released Plaintiff’s Claims. Please note: If you exclude yourself from the Settlement Class, you may be time-barred from asserting the claims covered by the Action by a statute of repose. In addition, Defendants and the other Defendants’ Releasees will have the right to assert any and all defenses they may have to any claims that you may seek to assert. 

If you ask to be excluded from the Settlement Class, you will not be eligible to receive any payment out of the Net Settlement Fund.

Defendants have the right to terminate the Settlement if valid requests for exclusion are received from persons and entities entitled to be members of the Settlement Class in an amount that exceeds an amount agreed to by Plaintiff and Defendants. 

Settlement Class Members do not need to attend the Settlement Hearing. The Court will consider any submission made in accordance with the provisions below even if a Settlement Class Member does not attend the hearing. You can participate in the Settlement without attending the Settlement Hearing. 

The Settlement Hearing will be held on August 15, 2022, at 9:00 a.m., Eastern Time before the Honorable Kevin M. Shanahan. The Settlement Hearing will be conducted by videoconference. Any Settlement Class Member who wishes to attend or participate in the hearing by videoconference may do so by contacting Class Counsel at settlements@blbglaw.com to obtain the access information. The Settlement Hearing will be held for the following purposes: (a) to determine whether the proposed Settlement on the terms and conditions provided for in the Stipulation is fair, reasonable, and adequate to the Settlement Class, and should be finally approved by the Court; (b) to determine whether a Judgment substantially in the form attached as Exhibit B to the Stipulation should be entered dismissing the Action with prejudice against Defendants; (c) to determine whether the Settlement Class should be certified for purposes of the Settlement; (d) to determine whether the proposed Plan of Allocation for the proceeds of the Settlement is fair and reasonable and should be approved; (e) to determine whether the motion by Class Counsel for attorneys’ fees and Litigation Expenses should be approved; and (f) to consider any other matters that may properly be brought before the Court in connection with the Settlement. The Court reserves the right to approve the Settlement, the Plan of Allocation, Class Counsel’s motion for an award of attorneys’ fees and Litigation Expenses, and/or any other matter related to the Settlement at or after the Settlement Hearing without further notice to the members of the Settlement Class.

Any Settlement Class Member who or which does not request exclusion may object to the Settlement, the Plan of Allocation, and/or Class Counsel’s motion for an award of attorneys’ fees and Litigation Expenses. Objections must be in writing. You must file any written objection, together with copies of all other papers and briefs supporting the objection, with the Clerk’s Office at the Superior Court of New Jersey (Somerset County, Law Division) at the address set forth below as well as serve copies on Class Counsel and Defendants’ Counsel at the addresses set forth below on or before July 25, 2022

You must also email the objection and any supporting papers on or before July 25, 2022, to settlements@blbglaw.com and jordan.peterson@kirkland.com. 

Any objections, filings, and other submissions by the objecting Settlement Class Member: (a) must identify the case name and docket number, Cambridge Retirement System v. Amneal Pharmaceuticals, Inc., SOM-L-1701-19, Superior Court of New Jersey (Somerset County, Law Division); (b) must state the name, address, and telephone number of the person or entity objecting and must be signed by the objector; (c) must state with specificity the grounds for the Settlement Class Member’s objection, including any legal and evidentiary support the Settlement Class Member wishes to bring to the Court’s attention and whether the objection applies only to the objector, to a specific subset of the Settlement Class, or to the entire Settlement Class; and (d) must include documents sufficient to prove membership in the Settlement Class, including the number of shares of Amneal Common Stock that the objecting Settlement Class Member purchased/acquired and/or sold during the Settlement Class Period (i.e., from May 7, 2018 through May 5, 2021, inclusive), as well as the date, number of shares, and price of each such purchase/acquisition and sale. The objecting Settlement Class Member shall provide documentation establishing membership in the Settlement Class through copies of brokerage confirmation slips or monthly brokerage account statements, or an authorized statement from the objector’s broker containing the transactional and holding information found in a broker confirmation slip or account statement. 

You may not object to the Settlement, Plan of Allocation, and/or Class Counsel’s motion for an award of attorneys’ fees and Litigation Expenses if you exclude yourself from the Settlement Class or if you are not a member of the Settlement Class. 

You may submit an objection without having to appear at the Settlement Hearing. You may not, however, appear at the Settlement Hearing to present your objection unless (i) you first submit a written objection in accordance with the procedures described above and (ii) you first submit your notice of appearance in accordance with the procedures described below; unless the Court orders otherwise. 

If you wish to be heard orally at the hearing in opposition to the approval of the Settlement, the Plan of Allocation, and/or Class Counsel’s motion for an award of attorneys’ fees and Litigation Expenses, and if you timely submit a written objection as described above, you must also file a notice of appearance with the Clerk’s Office and serve it on Class Counsel and Defendants’ Counsel at the addresses set forth in above so that it is received on or before July 25, 2022. Persons who intend to object and desire to present evidence at the Settlement Hearing must include in their written objection or notice of appearance the identity of any witnesses they may call to testify and any exhibits they intend to introduce into evidence at the hearing. Such persons may be heard orally at the discretion of the Court. 

You are not required to hire an attorney to represent you in making written objections or in appearing at the Settlement Hearing. However, if you decide to hire an attorney, it will be at your own expense, and that attorney must file a notice of appearance with the Court and serve it on Class Counsel and Defendants’ Counsel at the addresses set forth in above so that the notice is received on or before July 25, 2022. 

Unless the Court orders otherwise, any Settlement Class Member who does not object in the manner described above will be deemed to have waived any objection and shall be forever foreclosed from making any objection to the proposed Settlement, the proposed Plan of Allocation, and/or Class Counsel’s motion for an award of attorneys’ fees and Litigation Expenses. Settlement Class Members do not need to appear at the Settlement Hearing or take any other action to indicate their approval. 

If you purchased or otherwise acquired Amneal Common Stock during the Settlement Class Period (i.e., from May 7, 2018 through May 5, 2021, inclusive) for the beneficial interest of a person or entity other than yourself, you must either (i) within seven (7) calendar days of receipt of the Notice, request from the Claims Administrator sufficient copies of the Notice and Claim Form (“Notice Packet”) to forward to all such beneficial owners and within seven (7) calendar days of receipt of those Notice Packets forward them to all such beneficial owners; or (ii) within seven (7) calendar days of receipt of the Notice, provide a list of the names, mailing addresses, and, if available, email addresses, of all such beneficial owners to Amneal Securities Litigation, c/o JND Legal Administration, P.O. Box 91234, Seattle, WA 98111. If you choose the second option, the Claims Administrator will send a copy of the Notice Packet to the beneficial owners. Upon full compliance with these directions, such nominees may seek reimbursement of their reasonable expenses actually incurred, by providing the Claims Administrator with proper documentation supporting the expenses for which reimbursement is sought. Copies of the Notice and the Claim Form may be obtained from the Settlement website, by calling the Claims Administrator toll-free at 866-615-0973, or by emailing the Claims Administrator at AMNSecurities@jndla.com.

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 on the website under Important Documents. Copies of any related orders entered by the Court and certain other filings in this Action will be also posted on this website. More detailed information about the matters involved in this Action can be obtained by visiting, during regular office hours, the Office of the Clerk, Superior Court of New Jersey (Somerset County, Law Division), Somerset County Courthouse, 20 North Bridge Street, Somerville, New Jersey 08876. 

All inquiries concerning the Notice and the Claim Form should be directed to:

PLEASE DO NOT CALL OR WRITE THE COURT, THE CLERK’S OFFICE, DEFENDANTS, OR DEFENDANTS’ COUNSEL REGARDING THE NOTICE.