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Addendum to the Class Action Settlement Agreement and Release of August 20,2013 Verdejo et al. v. Vanguard Piping Systems, Inc. et al.

As contemplated by Section 12.5 of the Agreement, the Settling Parties agree to modify the Agreement as follows:

13.1. The mailed notice (which will be substantially in the form of Exhibit 1 to the Agreement) shall include an option in the box at the beginning of the document that informs Settlement Class Members of their right and option to "File a Claim."

13.2. The mailed notice (which will be substantially in the form of Exhibit 1 to the Agreement) will disclose that plaintiffs are requesting $5,000 incentive awards per home that is owned by the class representatives.

13.3. Section 7.1 of the Agreement and the corresponding portions of the notices and other documents implementing the Settlement shall be modified to require that Objections be served on the Claims Administrator only {i.e., that Objections need not be served on the Court, Class Counsel, or Defense Counsel). The Claims Administrator shall then immediately notify Class Counsel and Defense Counsel of the receipt of any Objection. In all other respects, Section 7.1 of the Agreement and the corresponding portions of the notices and other documents implementing the Settlement remain unchanged.

13.4. When final approval is sought, Class Counsel is to include evidence showing express approval by the named class representatives of the fee-sharing agreement which controls the allocation of fees awarded and disclose such fee-sharing agreement to the Court, including any agreement to share or reimburse fees on some other basis other than the lodestar allocation of attorney effort.

Dated: September 5, 2013 C •LL-BURDICK feMcDONOUGH LLP

By: MATTHEW. KEMNER ALEXANDER P. IMBERG TROYM. YOSHINO Attorney for Defendants Vanguard Piping Systems, Inc. and Viega LLC

Dated: September 5, 2013 WE; VAUGHAN LLP KASD.

By: ;NNETH S. KASDAN

Attorney for Plaintiffs and the Settlement Class

Dated: September 5,2013 GIRARDI KEE:

GRAHAMRLIPPSMIIH Attorney for Plaintiffs and the Settlement Class

CBM-PRODUCTS\SF601022

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ROSENTHAL DECL. RE: SETTLEMENT NOTICE—CASE NO. BC 448383

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES – CENTRAL CIVIL WEST

DON VERDEJO, individually and on behalf of a class of similarly situated persons, et al.,

Plaintiffs,

v.

VANGUARD PIPING SYSTEMS, a Kansas corporation, et al.,

Defendants.

Case No. BC448383 Judge William F. Highberger Department: CCW307

DECLARATION OF DANIEL ROSENTHAL REGARDING SETTLEMENT NOTICE PLAN Action Filed: October 28, 2010 Trial Date: None Set

AND RELATED CROSS-CLAIMS

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I, DANIEL ROSENTHAL, declare:

1. I am a Special Consultant to Kurtzman Carson Consultants (“KCC”) a class action

settlement administrator. KCC is located at 75 Rowland Way, Suite 250, Novato, California. I am

over 21 years of age and am not a party to this action. I have personal knowledge of all matters

set forth herein unless otherwise indicated, and would testify thereto if called as a witness in this

matter.

2. The purpose of this Declaration is to provide the Parties and the Court with my and

KCC’s qualifications and experience regarding the development of Class Action Notice Plans and

to describe the proposed Notice Plan for the Verdejo v. Vanguard Piping Systems settlement. A

copy of the detailed Settlement Notice Plan is attached hereto as Exhibit A.

OVERVIEW OF THE NOTICE PLAN

3. KCC developed the Notice Program to reach more than 78.2% of Settlement Class

Members with an average frequency of 1.4 exposures through a combination of paid notices in

leading consumer magazines and on a variety of websites and social media. 1 In addition, all

homeowner insurers, who may be Settlement Class Members as the holders of subrogation rights

for leaks, will be reached through a mailed notice effort to homeowner insurance providers. Also,

mailings of the Notice of Pendency and Proposed Settlement of Class Action and Determination

of Good Faith Settlement (the “Notice”) will be directed to known warranty claimants and tens of

thousands of potential Settlement Class Members whose addresses are found in discount

programs offered by Viega to builders, contractors and plumbers. In addition, mailings of the

Motion for Determination of Good Faith Settlement will be directed to approximately 26,500

builders, contractors and plumbers who are in a unique position to convey the Notice to

Settlement Class Members. Lastly, a national informational release will extend the reach among

the Settlement Class beyond the reach of the media and mailing campaigns.

1 The reach or net reach of a notice program is defined as the percentage of a class that was exposed to a notice net of any duplication among people who may have been exposed more than once. The “average frequency” of notice exposure is the average number of times that those reached by the notice would be exposed to that notice.

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EXPERIENCE

4. I have more than 27 years of class action notice and administration experience, and

more than 40 years of advertising agency experience. In 2000 I founded Rosenthal & Company

LLC (“Rosenthal”), a class action administration company. In 1986, I founded the first

advertising agency to specialize in planning and placement of legal notices in all types of media.

Prior to founding Rosenthal, since 1988 I served as Managing Director of a leading class action

administration company, where I developed the methodology, computer systems and staff to

manage the company’s consumer class action administrations. Prior to 1988, I held positions in

the consumer products marketing field, including management positions with McCann-Erickson,

a leading international advertising agency. In 2010, KCC acquired Rosenthal & Company. In July

of 2013 I became Special Consultant to KCC, an advisory role in which I provide expertise in

developing class action notice and administration plans.

5. KCC is a settlement administrator that specializes in providing comprehensive class

action settlement services including, but not limited to, pre-settlement consulting, email and

mailing campaign implementation, website design, claims administration, check and voucher

disbursements, tax reporting, settlement fund escrow and reporting, class member data

management, legal notification, call center support, claims administration, and other related

services critical to the effective administration of class action settlements. KCC has developed

efficient, secure and cost-effective methods to properly handle the voluminous data and mailings

associated with the noticing, claims processing and disbursement requirements of settlements to

ensure the orderly and fair treatment of class members and all parties in interest.

6. KCC’s business is national in scope. Since 2000, KCC (along with Rosenthal) has

administered more than 2,000 matters. As part of these settlements, KCC has provided notice and

administration services for cases with class members that range in numbers from 22 to over 26

million, and has distributed settlement payments totaling well over two billion dollars in the

aggregate. KCC has administered class action administrations for such defendants as Apple, HP-

Compaq, LensCrafters, United Parcel Service, Ford, Mitsubishi, Nissan, Whirlpool, ATI Video

Cards and Twentieth Century Fox.

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NOTICE PLAN SUMMARY

7. KCC designed a Notice Plan that utilizes a schedule of paid notices in leading

consumer magazines and on a variety of websites and social media to reach Settlement Class

Members. In addition, individual notice will be mailed directly to known warranty claimants and

other Settlement Class Members, homeowner insurance providers, and commercial and

residential builders and plumbers. Coverage will be further enhanced by a national informational

release. Potential Settlement Class Members will be able to respond to the Notice by visiting the

case website, where they can review frequently asked questions and answers, download key

documents, and enter contact information to download a claim form.

Case Background and Class Target

8. It is alleged that VG Pipe LLC (successor-in-interest by merger to Vanguard Piping

Systems, Inc.) and Viega, LLC (collectively referred to as “Viega”) manufactured and distributed

brass plumbing fittings and other components (“Viega Brass Fittings”) that are inadequate or of

poor or insufficient quality or defective. Viega denies the Viega Brass Fittings are defective.

9. The “Settlement Class” (or “Settlement Class Members”) is defined as follows: All Persons that own or have owned buildings, homes, residences or any other structures located in the United States that contain or have ever contained Viega Brass Fittings. Also included in this class are all such Persons’ spouses, joint owners, heirs, executors, administrators, mortgagees, tenants, creditors, lenders, predecessors, successors, subsequent owners or occupants, lessees, trusts and trustees, attorneys, agents, and assigns and all Persons who have vested legal rights such that they have legal standing and are entitled to assert a claim on behalf of such Settlement Class Members. Insurance carriers are members of the Settlement Class if they paid insurance claims for a Failure prior to the date of the Preliminary Approval Order and thereby obtained legally vested subrogation rights. Persons who seek contribution or indemnity from Viega on past settlements of claims with Settlement Class Members also are members of the Settlement Class for those Failures if they paid those settlements prior to the date of the Preliminary Approval Order and thereby obtained vested legal rights to pursue such contribution or indemnity claims. To the extent there may in the future be subrogated insurance carriers or Persons who seek contribution or indemnity from Viega because of vesting of legal rights that occurs after the date of the Preliminary Approval Order, they

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shall not be Settlement Class Members, but the rights that they take through a Settlement Class Member shall be limited by all of the terms, time periods, releases, caps, prohibitions on overlapping or double recoveries, and other provisions of this Agreement.

10. Excluded from the Settlement Class are:

a. Persons who validly and timely exclude themselves from the Settlement

Class, using the procedure set forth in the Settlement Agreement;

b. Persons who have settled with, released, or otherwise had claims

adjudicated on the merits against Viega that are substantially similar to those alleged in this

matter;

c. Persons with only personal injury claims as a result of the defects alleged;

d. Except as specified above, insurers or other providers of extended service

contracts or warranties for the Settlement Class Structures; and

e. The Honorable William F. Highberger and members of his family.

11. It is important to note that Viega, like most building supply manufacturers and

distributors that do not sell directly to customers and instead sell their product through

wholesalers, does not possess an exact count of the total number of customers for a particular

time period. Accordingly, to calculate reach in these types of cases, it is customary to develop

estimates based on the most reliable sources available at the time of planning.

12. GfK MediaMark Research & Intelligence, LLC (“MRI”)2 data was studied among

Homeowners, because this broad, over inclusive target group best represents the Settlement Class.

Efforts will also focus on reaching homeowner insurance providers. Based on data provided by a

list provider, there are approximately 150 homeowner insurance providers.

13. Knowing the characteristics, interests, and habits of a target group aids in the media

2 GfK MRI is a nationally accredited research firm that provides consumer demographics, product and brand usage, and audience/exposure in all forms of advertising media. Established in 1979, MRI measures the usage of nearly 6,000 product and service brands across 550 categories, along with readership of hundreds of magazines and newspapers, internet usage, television viewership, national and local radio listening, yellow page usage, and out-of-home exposure. Based on a yearly face-to-face interview of 26,000 consumers in their homes, MRI’s Survey of the American ConsumerTM is the primary source of audience data for the U.S. consumer magazine industry and the most comprehensive and reliable source of multimedia audience data available.

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selection process. Demographic highlights of Homeowners include the following: 89.9% have

graduated from high school and 59.8% have attended or graduated from college or beyond;

88.9% live in a household consisting of two or more people, 73.2% live in a household consisting

of 2-4 people, and 54.0% live in a household consisting of three or more people; 82.9% are white;

82.1% live in a metropolitan CBSA;3 81.1% own a home valued at $100,000 or more and 71.6%

own a home valued between $100,000-$499,999; 77.0% are 35 years of age or older and 59.9%

are 45 years of age or older; 77.0% have a household income of $40,000 or more, 68.8% have a

household income of $50,000 or more, and 60.3% have a household income of $60,000 or more;

72.2% have lived at their current address for five or more years; 64.1% are married; and 51.3%

are women.. On average, Homeowners are 49 years of age, have a household income of $86,741,

and own a home valued at $242,554.4

14. Compared to the general adult population, Homeowners have higher incomes, are

more likely to have lived at their current address for five or more years, and tend to be older,

married and better educated.

Individual Notice

15. It is my understanding that Viega has made best efforts to provide KCC with all

reasonably available data, including warranty claims information and addresses from various

discount programs, specifying Settlement Class Members’ names (where possible), addresses,

and any other contact information that may exist. Approximately 38,000 Notices will be sent to

the addresses of potential claimants, along with a claim form. For each unique name and address

of a known or likely Settlement Class Member, the Notice will be mailed via First Class Mail in a

windowed envelope. Potential Settlement Class Members will be directed to the settlement

3 The Office of Management and Budget defines metropolitan and micropolitan statistical areas (metro and micro areas) as geographic entities for use by Federal statistical agencies in collecting, tabulating, and publishing Federal statistics. The term “Core Based Statistical Area” (CBSA) is a collective term for both metro and micro areas. A metro area contains a core urban area of 50,000 or more population, and a micro area contains an urban core of at least 10,000 (but less than 50,000) population. Each metro or micro area consists of one or more counties and includes the counties containing the core urban area, as well as any adjacent counties that have a high degree of social and economic integration (as measured by commuting to work) with the urban core. 4 The average age for U.S. adults is 46, the average household income is $74,446, and the average home value is $242,554.

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website for detailed information on how to file a claim, to access claim forms, and to seek

assistance as needed with filing a claim.

16. Approximately 150 Notices will be sent to the addresses of homeowner insurance

providers throughout the U.S.

17. Copies of the Motion for Determination of Good Faith Settlement will be mailed to

approximately 26,500 commercial and residential builders, plumbers, and other similar entities

that have been identified.

18. Prior to mailing, addresses will be updated using the National Change of Address

(NCOA) 5 database maintained by the United States Postal Service (USPS); certified via the

Coding Accuracy Support System (CASS); 6 and verified through Delivery Point Validation

(DPV).7

19. Notices returned as undeliverable will be re-mailed to the address provided by the

Postal Service, if any.

20. Any returned mailing not updated by the USPS may be researched through a standard

skip trace in an effort to ascertain the current address of the Settlement Class Member. Whether

or not a new address is found, all returned mail will be re-mailed a second time.

Publication Notice

21. A summary of the Notice will appear in leading consumer publications among

potential Settlement Class Members.

5 The NCOA database contains records of all permanent change of address submissions received by the USPS for the last four years. The USPS makes this data available to mailing firms and lists submitted to it are automatically updated with any reported move based on a comparison with the person’s name and last known address. 6 Coding Accurate Support System is a certification system used by the USPS to ensure the quality of ZIP+4 coding systems. 7 Records that are ZIP+4 coded arc then sent through Delivery Point Validation to verify the address and indentify Commercial Mail Receiving Agencies. DPV verifies the accuracy of addresses and reports exactly what is wrong with incorrect addresses.

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Consumer Publication Issuance Notice Size # of Insertions

Parade Weekly 3/5 Page 1

People Weekly 2/3 Page 1

22. The recommended publications include leading publications in the country—Parade

alone reaches 31.9% of Homeowners and People reaches 18.8%. Parade is distributed in

approximately 743 newspapers throughout the country. In addition, readers of Parade are 12.1%

more likely to be Homeowners, as compared to the general adult population.

Internet Ad and Social Media Campaign

23. In addition to the mailed notice and publication effort, KCC will implement an online

notice campaign. MRI research indicates that 84.1% of Homeowners have access to the internet

at home using a computer and 80.8% have looked at or used the internet in the past 30 days.

Therefore, KCC recommends purchasing 142 million unique impressions over a one-month

period in the form of banner advertisements. The banners will have an embedded link that will

allow access to the case website.

Internet Tactic Details Impressions Facebook Target Adults 18+ 70,000,000

24/7 Real Media Custom Channel

Target Adults 18+ Custom channel to: Home & Garden, News, Family, Real Estate, Finance, Automotive, and Technology sites

72,000,000

TOTAL 142,000,000

Informational Release

24. An informational press release will be issued to approximately 6,450 press outlets

throughout the country. The release will include a case website address so that Settlement Class

Members may easily obtain more information about the settlement.

Exhibit A

2013 KCC LLC Proprietary and Confidential

Class Action Services

______________________________________________________________________

Settlement Notice Plan

Verdejo, et al. v.

Vanguard Piping Systems, et al.

Case No. BC448383 Superior Court of the State of California

County of Los Angeles – Central Civil West

Prepared: August 26, 2013


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Table of Contents

Page

Media Terms 3

Media Resources 4

Program Overview 5

Notice Schedule 7

Target Analysis 8

Individual/Direct Notice 10

Consumer Magazines 11

Internet Activity 12

Earned Media 13

Additional Support 14


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Media Terms The following provides the meaning of media terms highlighted throughout the Notice Plan: Audience: Net number of persons or different persons exposed to a media vehicle. It is larger than a publication’s circulation because it includes pass-along readers who may obtain the publication second hand (e.g., from a reception room, neighbor, friend). Circulation: Total number of publication copies sold through all channels of distribution (e.g. subscriptions, newsstand, bulk). Frequency: Estimated average number of times a population group is exposed to a media vehicle or combination of media vehicles containing a notice within a given period of time. Impressions or Exposures: Total number of opportunities to be exposed to a media vehicle or combination of media vehicles containing a notice. It is a gross or cumulative number that may include the same person more than once. Impressions can exceed the population size. Reach or Coverage: Net percentage of a specific population group exposed to a media vehicle or a combination of media vehicles containing a notice at least once within a given period of time. Reach factors out duplication, representing the total different/net persons. Selectivity Index: Shows the concentration of a specific population group relative to the general adult population. For example, a publication selectivity index of 175 among men indicates that the publication’s readers are 75% more likely to be men as compared to the general adult population.


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Media Resources The following resources were used to develop the media campaign: Alliance for Audited Media (AAM) AAM is a nonprofit organization that connects North America's leading media companies, advertisers and ad agencies. Founded in 1914 as the Audit Bureau of Circulations, the AAM is the preeminent source of cross-media verification and information services, providing standards, audit services and data critical to the advertising industry. The organization independently verifies print and digital circulation, mobile apps, website analytics, social media, technology platforms and audience information for newspapers, magazines and digital media companies in the U.S. and Canada. GfK Mediamark Research & Intelligence, LLC (MRI) MRI is a nationally accredited research firm that provides consumer demographics, product and brand usage, and audience/exposure in all forms of advertising media. Established in 1979, MRI measures the usage of nearly 6,000 product and service brands across 550 categories, along with the readership of hundreds of magazines and newspapers, internet usage, television viewership, national and local radio listening, yellow page usage, and out-of-home exposure. Based on a yearly face-to-face interview of 26,000 consumers in their homes, MRI’s Survey of the American Consumer™ is the primary source of audience data for the U.S. consumer magazine industry and the most comprehensive and reliable source of multi-media audience data available. Telmar Telmar is the world-leading supplier of computer based advertising media information services. Its software provides for survey analysis, data integration, media planning and optimization. With over 5,000 users in 85 countries, Telmar’s clients include many of the world’s leading advertising agencies, publishers, broadcasters and advertisers.


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Program Overview Case Background It is alleged that VG Pipe LLC (successor-in-interest by merger to Vanguard Piping Systems, Inc.) and Viega, LLC (collectively referred to as “Viega”) manufactured and distributed brass plumbing fittings and other components (“Viega Brass Fittings”) that are inadequate or of poor or insufficient quality or defective. Viega denies the Viega Brass Fittings are defective. Class Definition The Settlement Class (or Settlement Class Members) consists of: All Persons that own or have owned buildings, homes, residences or any other structures located in the United States that contain or have ever contained Viega Brass Fittings. Also included in this class are all such Persons’ spouses, joint owners, heirs, executors, administrators, mortgagees, tenants, creditors, lenders, predecessors, successors, subsequent owners or occupants, lessees, trusts and trustees, attorneys, agents, and assigns and all Persons who have vested legal rights such that they have legal standing and are entitled to assert a claim on behalf of such Settlement Class Members. Insurance carriers are members of the Settlement Class if they paid insurance claims for a Failure prior to the date of the Preliminary Approval Order and thereby obtained legally vested subrogation rights. Persons who seek contribution or indemnity from Viega on past settlements of claims with Settlement Class Members also are members of the Settlement Class for those Failures if they paid those settlements prior to the date of the Preliminary Approval Order and thereby obtained vested legal rights to pursue such contribution or indemnity claims. To the extent there may in the future be subrogated insurance carriers or Persons who seek contribution or indemnity from Viega because of vesting of legal rights that occurs after the date of the Preliminary Approval Order, they shall not be Settlement Class Members, but the rights that they take through a Settlement Class Member shall be limited by all of the terms, time periods, releases, caps, prohibitions on overlapping or double recoveries, and other provisions of this Agreement. Excluded from the Settlement Class are:

• Persons who validly and timely exclude themselves from the Settlement Class, using the procedure set forth in the Settlement Agreement;

• Persons who have settled with, released, or otherwise had claims adjudicated on the merits against Viega that are substantially similar to those alleged in this matter;

• Persons with only personal injury claims as a result of the defects alleged; • Except as specified above, insurers or other providers of extended service contracts or warranties

for the Settlement Class Structures; and • The Honorable William F. Highberger and members of his family.

Target Audience MRI data was studied among people who own a home (“Homeowners”), because this broad, over inclusive target group best represents Settlement Class Members. Efforts will also focus on reaching the homeowner insurance providers.


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Strategies The Notice Plan utilizes a schedule of paid notices in leading consumer magazines and on a variety of websites and social media to reach Settlement Class Members. In addition, individual notice will be mailed directly to known warranty claimants and other Settlement Class Members, homeowner insurance providers, and commercial and residential builders and plumbers. Coverage will be further enhanced by a national informational release. Potential Settlement Class Members will be able to respond to the notice by visiting a case website, where they can review frequently asked questions, download key documents, and enter contact information to download a claim form. Plan Delivery The media effort alone will reach approximately 78.2% of likely Settlement Class Members, on average 1.4 times each. Virtually all homeowner insurers who may be Settlement Class Members as the holders of subrogation rights will be reached through the mailed notice effort to homeowner insurance providers. The mailing effort to known Settlement Class Members and to commercial residential builders and plumbers, as well as the national informational release, will extend reach among the Settlement Class even further.


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Notice Schedule

Notice Tactic Issued Week 1 Week 2 Week 3 Week 4 Week 5 Week 6 Issue Informational Release Mailing to Known Settlement Class Members Mailing to Homeowner Insurance Providers Mailing to Commercial and Residential Builders and Plumbers Parade Weekly People Weekly Internet Banner Notices Case Website Constant

Blocks indicate when readers first receive publications (the on-sale date, not the issue/cover date). All media subject to change based on availability at the time of placement.


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Target Analysis There are approximately 150 homeowner insurance providers. Knowing the characteristics, interests, and habits of a target group aids in the media selection process. Demographic Highlights Demographic highlights of Homeowners include the following:

• 89.9% have graduated from high school and 59.8% have attended or graduated from college or beyond;

• 88.9% live in a household consisting of two or more people, 73.2% live in a household consisting of 2-4 people, and 54.0% live in a household consisting of three or more people;

• 82.9% are white; • 82.1% live in a metropolitan CBSA;1 • 81.1% own a home valued at $100,000 or more and 71.6% own a home valued between

$100,000-$499,999; • 77.0% are 35 years of age or older and 59.9% are 45 years of age or older; • 77.0% have a household income of $40,000 or more, 68.8% have a household income of

$50,000 or more, and 60.3% have a household income of $60,000 or more; • 72.2% have lived at their current address for five or more years; • 64.1% are married; and • 51.3% are women.

On average, Homeowners:2

• are 49 years of age; • have a household income of $86,741; and • own a home valued at $242,554.

Compared to the general adult population, Homeowners are:

• 28.6% more likely to have a household income of $150,000 or more, 26.6% more likely to have a household income between $100,000-$149,999, and 21.9% more likely to have a household income of $60,000 or more;

• 27.6% more likely to have lived at their current address for five or more years; • 21.3% more likely to be 65 years of age or older, 18.2% more likely to be 55-64 years of age, and

9.7% more likely to be 45-54 years of age; • 18.2% more likely to be married;

1 The Office of Management and Budget defines metropolitan and micropolitan statistical areas (metro and micro areas) as geographic entities for use by Federal statistical agencies in collecting, tabulating, and publishing Federal statistics. The term “Core Based Statistical Area” (CBSA) is a collective term for both metro and micro areas. A metro area contains a core urban area of 50,000 or more population, and a micro area contains an urban core of at least 10,000 (but less than 50,000) population. Each metro or micro area consists of one or more counties and includes the counties containing the core urban area, as well as any adjacent counties that have a high degree of social and economic integration (as measured by commuting to work) with the urban core. 2 The average age for U.S. adults is 46, the average household income is $74,446, and the average home value is $242,554.


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• 15.9% more likely to have graduated from college or beyond; • 11.6% more likely to live in a micropolitan CBSA; • 10.1% more likely to live in County Size D;3 • 9.1% more likely to live in a household consisting of two people; • 9.0% more likely to be white; and • 8.8% more likely to live in the Midwest Census Region.

Source: 2012 MRI Doublebase Study

3 According to Nielsen, “A” counties are the counties of the top 25 metropolitan areas; “B” counties are all remaining counties with a population over 150,000 plus counties that are part of the metro areas of cities in B counties; “C” counties are all remaining counties not included above with populations over 35,000 plus counties that are part of the metro areas of cities in C counties; and “D” counties are all other remaining counties.


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Individual/Direct Notice

Mailed Notice

• Approximately 38,000 Individual Notices and Claim Forms formatted as Self-Mailers will be sent via First Class Mail to the addresses of homes Vanguard believes may contain brass fittings.

• Approximately 26,500 copies of the Motion for Good Faith Settlement Determination will be sent via Certified Mail, return receipt requested, to commercial and residential builders and plumbers.

• Approximately 150 Summary Notices will be sent to the addresses of homeowner insurance providers throughout the U.S.

• Prior to mailing, the names and addresses will be: o Checked against the USPS National Change of Address (NCOA)4 database o Certified via the Coding Accuracy Support System (CASS);5 and o Verified through Delivery Point Validation (DPV).6

• Notices returned as undeliverable will be re-mailed to any address available through postal

service information. o For example, to the address provided by the USPS on returned pieces for which the

automatic forwarding order has expired, but is still within the period that the USPS returns the piece with the new address indicated.

• Any returned mailing not updated by the USPS may be researched through a standard skip trace in an effort to ascertain the current address of the Settlement Class Member.

4 The NCOA database contains records of all permanent change of address submissions received by the USPS for the last four years. The USPS makes this data available to mailing firms and lists submitted to it are automatically updated with any reported move based on a comparison with the person’s name and last known address. 5 Coding Accurate Support System is a certification system used by the USPS to ensure the quality of ZIP+4 coding systems. 6 Records that are ZIP+4 coded are then sent through Delivery Point Validation to verify the address and indentify Commercial Mail Receiving Agencies. DPV verifies the accuracy of addresses and reports exactly what is wrong with incorrect addresses.


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Consumer Magazines

Consumer Magazine Issuance Notice Size # of Insertions

Parade Weekly 3/5 page 1

People Weekly 2/3 page 1

TOTAL 2

• Circulation: 32,500,019 • Adult Audience: 65,468,000 • Provides the single largest readership of any publication • Reaches 31.9% of Homeowners • Readers are 12.1% more likely to be Homeowners, as compared to the general adult population • Carried in approximately 743 newspapers serving major urban and suburban markets in the U.S.

• Circulation: 3,637,633 • Adult Audience: 43,204,000 • Weekly entertainment magazine featuring celebrity news, biographies and gossip • Reaches 18.8% of Homeowners • Provides a large number of pass along readers


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Internet Activity 84.1% of Homeowners have access to the internet at home using a computer and 80.8% have looked at or used the internet in the past 30 days. Compared to the general adult population, Therefore, to extend coverage, we recommend purchasing 142 million unique impressions over a one-month period. The banners will have an embedded link that will allow access to the case website.

Internet Tactic Details Impressions

Facebook Target Adults 18+ 70,000,000

24/7 Real Media Network Custom Channel

Target Adults 18+ Custom channel to: Home & Garden, News, Family, Real Estate, Finance, Automotive, and Technology sites

72,000,000

TOTAL 142,000,000

24/7 Real Media allows access to over 4,000 premium, high quality websites, reaching approximately 180 million unique adults in an average month. Sample sites include:

L


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Earned Media Although not guaranteed, earned media allows additional notice exposure opportunities beyond what is provided by the paid media. Informational Release

• Issued to approximately 6,450 press outlets throughout the U.S. • Includes the case website address so that Settlement Class Members may easily obtain more

information about the settlement


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Additional Support Case Website

• Provides an easy to remember domain name • Allows Settlement Class Members the ability to obtain additional information and documents

including the complaints, the Settlement Agreement, the Long Form Notice, Motion for Good Faith Settlement Determination and any Court orders relating to the settlement, and any other information that the parties may agree to provide or that the Court may require

• Prominently displayed in all printed notice materials and accessible through an embedded link in the internet banner notices

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