Market Overview

Miller Law, LLC and Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A. Announce Partial Settlement for Purchasers of Liquid Aluminum Sulfate


If You Purchased Liquid Aluminum Sulfate From January 1, 1997 Through
February 28, 2011, You Could Be Affected By A Proposed Class Action
Settlement announced by Miller Law, LLC and Stearns Weaver Miller
Weissler Alhadeff & Sitterson, P.A.

Please read this entire Notice carefully. Partial settlements
of the lawsuit may affect your rights.

A partial settlement in a lawsuit pending in the United States District
Court for the District of New Jersey ("the Court") against the following
Defendants, General Chemical Corporation; General Chemical Performance
Products, LLC; General Chemical LLC, GenTek Inc., Chemtrade Logistics
Income Fund; Chemtrade Logistics Inc., Chemtrade Chemicals Corporation;
and Chemtrade Chemicals US, LLC.; Chemtrade Solutions, LLC; C&S
Chemicals, Inc., USALCO, LLC, Kemira Chemicals, Inc., Southern Ionics,
Inc., GEO Specialty Chemicals, Inc., Frank A. Reichl, Vincent J.
Opalewski, Alex Avraamides, Amita Gupta, Milton Sundbeck, Kenneth A.
Ghazey, Brian C. Steppig, American Securities LLC, Matthew Lebaron, and
Scott Wolff. Plaintiffs in the lawsuit claim that Defendants hurt
competition and violated state antitrust, consumer protection, and other
laws by allocating customers and markets and fixing the price of Liquid
Aluminum Sulfate ("Alum"), thereby causing indirect purchasers to pay
too much for Alum. Defendants deny any wrongdoing.

A Settlement has been reached with Defendant GEO Specialty Chemicals
Inc. ("GEO"), Kenneth A. Ghazey ("Ghazey") and Brian C. Steppig (the
"GEO Settling Parties"). The lawsuit will continue against the other
Defendants (collectively, "Non-Settling Defendants").

WHO IS INCLUDED IN THE CLASS? The Indirect Purchaser Settlement
Class consists of all persons or entities in AL, AR, AZ, CA, CO, DC, FL,
RI, SC, SD, TN, UT, VT, WV, and WI that purchased liquid aluminum
sulfate, not for resale, which was manufactured, produced or supplied by
Defendants or their unnamed co-conspirators from January 1, 1997 through
February 28, 2011. Excluded from the Class are Defendants,
co-conspirators and their respective parents, subsidiaries, and

agreed to pay into an Escrow Account the sum of up to $4,375,000 (the
"Settlement Funds") as follows. GEO shall use its best efforts to cause
its insurers to pay $801,074 directly into the Indirect Purchaser Escrow
Account within thirty (30) days of Final Judgment. GEO shall also pay
$898,926 into the Indirect Purchaser Escrow Account (collectively, the
"First Installment"). GEO shall make one additional payment of
$1,675,000 that shall be paid into the Indirect Purchaser Escrow Account
on or before the first anniversary of the First Installment. GEO will
undertake a marketing process for a sale of all or substantially all of
its equity interests, a merger of GEO and another entity, or a sale of
all or substantially all of its assets (collectively, a "Sale") that
will commence no later than thirty (30) days after entry of Final
Judgment. If this marketing process is successful, upon the closing of
the Sale, the Indirect Purchaser Settlement Class shall be entitled to
receive from GEO additional compensation pursuant to an equity value
formula up to $1,000,000.

At this time, Interim IPP Lead Counsel are not seeking attorneys' fees
in connection with this Settlement. Interim IPP Lead Counsel intends to
ask for reimbursement of certain of their out of pocket expenses
incurred so far in this litigation, including expert witness expenses
incurred to date, as well as service awards for the class
representatives of up to $25,000.00 each from the Settlement Fund in
recognition of their efforts to date on behalf of the Class. At a later
date, Interim IPP Lead Counsel may seek up to one-third of the aggregate
of funds achieved for the Class, and from any future recovery that may
occur in this Class Action against the Non-Settling Defendants.

distributed yet. The Interim IPP Lead Counsel will continue to pursue
the lawsuit against the Non-Settling Defendants. All Settlement Funds
that remain after payment of the Court-ordered attorneys' fees,
incentive awards, costs, and expenses will be distributed at the
conclusion of the lawsuit or as ordered by the Court.

You may visit the website
for updates on the status of the lawsuit.

WHAT ARE YOUR OPTIONS? If you wish to remain an Indirect
Purchaser Settlement Class Member, you need not take any action at this
time. You will give up your right to sue the GEO Settling Parties for
the claims that the Settlement with them will resolve. If you want to
keep the right to sue or continue to sue the GEO Settling Parties about
the legal issues in this case, then you must exclude yourself from the
Class. If you exclude yourself from the Indirect Purchaser Settlement
Class, you will not get any payment from the Settlement.
To exclude
yourself, you must send a letter to the Settlement Administrator, postmarked
no later than October 2, 2018
. You may also comment on or object to
the proposed Settlement. Your objections must be filed no later than
October 2, 2018.
Details on how to request exclusion, comment, or
object to the Settlement are available on the Settlement website,

WHO REPRESENTS ME? The Court appointed Jay B. Shapiro of Stearns
Weaver Miller Weissler Alhadeff & Sitterson, P.A. and Marvin A. Miller
of Miller Law LLC as Interim IPP Lead Counsel to represent the Indirect
Purchaser Settlement Class on an interim basis and for purposes of the
Settlement. If you want to be represented by your own lawyer, you may
hire one at your own expense.

The Court will hold a final fairness hearing to decide whether to
approve the terms of the Settlement at 10:00 a.m. on November 14, 2018,
at the Martin Luther King, Jr. Building & U.S. Courthouse, 50 Walnut
Street, Newark, New Jersey 07101. If there are objections, the Court
will consider them but may still approve the Settlement. You may appear
at the hearing, but you are not required to do so. The hearing may be
rescheduled without notice to the Class, so if you plan to attend,
please periodically check the Settlement website for any updates.

This notice is only a summary. For more information, please
visit the Settlement website,
or call 1-866-217-4455.

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