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If you are a person in the United States, the District of Columbia or any
U.S. Territories (including Puerto Rico, Guam, and the U.S. Virgin
Islands) and you purchased Differin branded Acne Treatment in the
United States between January 1, 2020, through February 19, 2026, you
may be eligible to receive benefits from a class action settlement.
A federal court has authorized this Notice. This is not a solicitation from a lawyer.
• A $990,000 settlement has been reached in a class action lawsuit against Galderma Laboratories,
L.P. (“Galderma” or “Defendant”). Plaintiffs assert that Galderma misled consumers regarding
possible benzene contamination in its Differin Daily Deep Cleanser (5% Benzoyl Peroxide
(“BPO”)), Differin Acne Spot Treatment (10% BPO), and Differin Maximum Strength Acne
Foaming Cleanser (10% BPO) (the “Products”). Galderma denies that the labeling and advertising
for its Differin branded Acne Treatment was misleading, that its products were contaminated with
benzene, and denies any wrongdoing or liability. Instead of continuing to litigate the claim in
court, the parties have agreed to a class action settlement to avoid the risk, cost, and time of
continuing the lawsuit.
• You are a Settlement Class Member entitled to receive benefits under the Settlement if the
following Settlement Class definition applies to you: all natural persons who, between January 1,
2020, and February 19, 2026, inclusive, purchased in the United States any Covered Product for
personal, family, or household use, and not for resale.
• If you are a Settlement Class Member, you may file a Claim Form to receive the following
Settlement benefits for each Product you claim. You may submit a Valid Claim for:
• 1 – Valid Claim with Proof of Purchase: If you are a Settlement Class Member and submit
a Valid Claim with proof of purchase, you will receive $9.00 for each Product. There is no
limitation to the number of Products you can seek a cash payment for if a proof of purchase
is provided with your Claim Form.
• 2 – Valid Claim without Proof of Purchase: If you are a Settlement Class Member and
submit a Valid Claim without proof of purchase, you will receive $9.00 for up to a maximum
of 3 Products.
This Notice may affect your rights. Please read it carefully.
Your Legal Rights & Options Deadline
Submit a The only way to get Settlement benefits is to submit Submitted or postmarked by:
Claim Form a timely and valid Claim Form. May 19, 2026
Get no Settlement benefits. Keep your right to file a
Exclude Postmarked by:
lawsuit against Galderma and the Released Parties
Yourself May 19, 2026
for the Released Claims involved in this Settlement.
Object Stay in the Settlement, but tell the Court why you do
Filed by:
to the not agree with the Settlement. You will still be
May 19, 2026
Settlement bound by the Settlement if the Court approves it.
Get no monetary Settlement benefits. Give up your
Do Nothing
legal rights.
• These rights and options—and the deadlines to exercise them—are explained in this Notice.
• The Court must still decide whether to approve the Settlement and attorneys’ fees, reimbursement
of costs, and Service Awards. No Settlement benefits will be provided unless the Court approves
the Settlement.
Questions? Go to www.DifferinBPOProductSettlement.com or call 1-877-317-7638
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BASIC INFORMATION
1. Why is this Notice being provided?
A federal court authorized this Notice because you have the right to know about the Settlement of this
class action lawsuit, and about all of your rights and options, before the Court decides whether to grant
final approval to the Settlement. This Notice explains the lawsuit, the Settlement, your legal rights,
what Settlement benefits are available, who is eligible for them, and how to get them.
The Honorable Lindsay Jenkins of the United States District Court for the Northern District of Illinois is
overseeing this class action. The lawsuit is known as Williams v. Galderma Laboratories, L.P., Case No.
1:24-cv-02222. The person who filed this lawsuit is called the Plaintiff, and the company they sued
Galderma Laboratories, L.P., is the Defendant.
2. What is this lawsuit about?
The Plaintiff filed this lawsuit against Galderma on behalf of Settlement Class Members alleging that
Galderma misled consumers regarding possible benzene contamination in its Differin Daily Deep
Cleanser (5% Benzoyl Peroxide (“BPO”)), Differin Acne Spot Treatment (10% BPO), and Differin
Maximum Strength Acne Foaming Cleanser (10% BPO).
Galderma denies these allegations and denies any wrongdoing or liability. The Court has not made any
determination of any wrongdoing by Galderma or that any law has been violated. Instead, the Plaintiff
and Galderma have agreed to a settlement to avoid the risk, cost, and time of continuing the lawsuit.
3. Why is the lawsuit a class action?
In a class action, one or more people called Class Representatives sue on behalf of other people who
have similar legal claims. Together, the people are a class or class members. One court resolves the
issues for all class members, except for those class members who timely exclude themselves (opt-out)
from the class.
4. Why is there a Settlement?
The Plaintiff and Defendant do not agree about the legal claims made in this lawsuit. The lawsuit has
not gone to trial, and the Court has not decided in favor of the Plaintiff or Defendant. Instead, the
Plaintiff and Defendant have agreed to settle the lawsuit. The Class Representative and her lawyers
believe the Settlement is best for Settlement Class Members because of the Settlement benefits
available and the risks and uncertainty associated with continuing the lawsuit.
WHO IS INCLUDED IN THE SETTLEMENT
5. How do I know if I am part of the Settlement?
You are a Settlement Class Member if the following Settlement Class definition applies to you: all
natural persons who, between January 1, 2020, and February 19, 2026, inclusive, purchased in the
United States the Differin Daily Deep Cleanser (5% Benzoyl Peroxide (“BPO”)), Differin Acne Spot
Treatment (10% BPO), and Differin Maximum Strength Acne Foaming Cleanser (10% BPO) for
personal, family, or household use, and not for resale.
Excluded from the Settlement Class are (1) the judge presiding over the Action and members of her
immediate family; (2) Galderma; (3) any entity in which Galderma has a controlling interest; (4) any
Questions? Go to www.DifferinBPOProductSettlement.com or call 1-877-317-7638
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of Galderma’s past or present subsidiaries, parents, affiliates, and officers, directors, employees, legal
representatives, heirs, successors, or assigns; and (5) any persons who timely exclude themselves from
the Settlement Class.
6. Which products are included in the Settlement?
The Settlement only includes Differin Daily Deep Cleanser (5% Benzoyl Peroxide (“BPO”)), Differin
Acne Spot Treatment (10% BPO), and Differin Maximum Strength Acne Foaming Cleanser (10%
BPO).
7. What if I am still not sure whether I am part of the Settlement?
If you are still not sure whether you are a Settlement Class Member, you may go to
www.DifferinBPOProductSettlement.com or call toll-free at 1-877-317-7638.
THE SETTLEMENT BENEFITS—WHAT YOU GET IF YOU QUALIFY
8. What does the Settlement provide?
Settlement Fund – As a result of the Settlement, Galderma has agreed to pay $990,000 into a
Settlement Fund. Cash payments will be paid from the Settlement Fund to Settlement Class Members
who submit a timely Claim Form that includes all necessary information and documentation, if
required (“Valid Claim”).
The following items will be deducted from the Settlement Fund: attorneys’ fees and
reimbursement of costs to Settlement Class Counsel and Service Awards in an amount to be approved
by the Court; all settlement administration costs (including providing the notice and settlement
administration services, distribution costs, etc.); and after such payments, the remaining “Net
Settlement Amount” will be used to make cash payments to Settlement Class Members who have
filed a Valid Claim.
9. What can I get from the Settlement?
If you are a Settlement Class Member, you may file a Claim Form to receive the following Settlement
benefits for each seat you claim.
You may submit a Valid Claim for:
1 – Valid Claim with Proof of Purchase: If you are a Settlement Class Member and submit a
Valid Claim with proof of purchase, you will receive $9.00 for each Product. There is no
limitation to the number of Products you can seek a cash payment for if a proof of purchase is
provided with your Claim Form.
2 – Valid Claim without Proof of Purchase: If you are a Settlement Class Member and submit
a Valid Claim without proof of purchase, you will receive $9.00 for up to a maximum of 3
Products.
10. What am I giving up to receive Settlement benefits or stay in the Settlement Class?
Unless you exclude yourself (opt-out), you will remain in the Settlement Class. If the Settlement is
approved and becomes final, all the Court’s orders and judgments will apply to you and legally bind
you. You will not be able to sue, continue to sue, or be part of any other lawsuit against Galderma
and Released Parties about the legal claims in this lawsuit that are released by the Settlement
Questions? Go to www.DifferinBPOProductSettlement.com or call 1-877-317-7638
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Agreement. The rights you are giving up are called “Released Claims.” If you remain a Settlement
Class Member you may file a Claim Form for a cash payment.
11. Where can I find out about the rights that I give up if I stay in the Settlement Class?
The rights that you give up if you stay in the Settlement Class are discussed in the Settlement
Agreement in Section 7.1 (titled “Release”), which describes the Release, Released Parties, and
Released Claims in necessary legal terminology. Please read these sections carefully.
The Settlement Agreement is available at www.DifferinBPOProductSettlement.com. For questions
regarding the Release, you can also contact Settlement Class Counsel listed below for free, or you
can talk to your own lawyer at your own expense.
HOW TO GET BENEFITS FROM THE SETTLEMENT
12. How do I submit a Claim Form?
To submit a Claim Form for a cash payment toward the purchase of a Differin Daily Deep Cleanser
(5% Benzoyl Peroxide (“BPO”)), Differin Acne Spot Treatment (10% BPO), and Differin Maximum
Strength Acne Foaming Cleanser (10% BPO) product, you must submit a Claim Form with all the
necessary information and documentation, as required. Your Claim Form must be postmarked or
submitted online by May 19, 2026. The quickest way to file a Claim Form is online.
Claim Forms may be submitted online at www.DifferinBPOProductSettlement.com or printed from
the Settlement Website and mailed to the Claims Administrator at the address on the Claim Form.
Claim Forms are also available by calling 1-877-317-7638 or by writing to:
Differin BPO Product Claims Administrator
PO Box 4100
Portland, OR 97208-4100
13. What happens if my contact information changes after I submit a Claim Form?
If you change your mailing address or email address after you submit a Claim Form, it is your
responsibility to inform the Claims Administrator of your updated information. You may notify the
Claims Administrator of any changes at:
Differin BPO Product Claims Administrator
PO Box 4100
Portland, OR 97208-4100
14. When will I receive my cash payment?
If you file a timely and Valid Claim Form, a cash payment will be provided to you by the Claims
Administrator after the Settlement is approved by the Court and becomes final.
It may take time for the Settlement to be approved and become final. Please be patient and check
www.DifferinBPOProductSettlement.com for updates.
Questions? Go to www.DifferinBPOProductSettlement.com or call 1-877-317-7638
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THE LAWYERS REPRESENTING YOU
15. Do I have a lawyer in this lawsuit?
Yes, the Court has appointed Bryson Harris Suciu & DeMay PLLC; Bursor & Fisher P.A.; Aylstock,
Witkin, Kreis & Overholtz, PLLC; and Milberg Coleman Bryson Phillips Grossman, PLLC as
settlement class counsel to represent you and the Settlement Class for the purposes of this Settlement.
You will not be charged for settlement class counsel. If you want to be represented by your own
lawyer, you may hire one at your own expense.
R. Jason Richards Matthew A. Girardi
Aylstock, Witkin, Kreis & Overholtz, Burson & Fisher P.A.
PLLC 50 Main Street, Suite 475
17 East Main Street White Plains, NY 10606
Pensacola, FL 32505 [email protected]
[email protected]
Gary M. Klinger Trenton Ross Kashima
Milberg PLLC Bryson Harris Suciu & DeMay PLLC
227 W. Monroe Street, Suite 2100 19800 MacArthur Boulevard, Suite 270
Chicago, IL 60606 Irvine, CA 92612
[email protected] [email protected]
16. How will Plaintiff’s Counsel be paid?
Plaintiff’s Counsel will file a motion asking the Court to award attorneys’ fees and reimbursement of
costs. Plaintiff’s Counsel will also ask the Court to approve Service Awards to be paid to the Class
Representative for participating in this lawsuit and for her efforts in achieving the Settlement. If
awarded by the Court, attorneys’ fees and reimbursement of costs and the Service Awards will be
paid from the Settlement Fund. The Court may award less than the amounts requested for attorneys’
fees and reimbursement of costs and Service Awards.
Plaintiff’s Counsel’s motion for attorneys’ fees and reimbursement of costs and Service Awards will
be made available on the Settlement Website at www.DifferinBPOProductSettlement.com before the
deadline for you to object to the Settlement.
EXCLUDING YOURSELF FROM THE SETTLEMENT
If you do not want a cash payment from this Settlement, but you instead want to keep the right to sue
or continue to sue Galderma and the Released Parties on your own, about the legal issues in this
lawsuit, then you must take steps to get out of the Settlement. This is called excluding yourself from—
or “opting out” of—the Settlement.
17. How do I get out of the Settlement?
To exclude yourself from the Settlement, you must mail a written request for exclusion, which
includes the following:
1. The case name Williams v. Galderma Laboratories, L.P., Case No. 1:24-cv-02222;
2. Your full name, current mailing address, and email address;
Questions? Go to www.DifferinBPOProductSettlement.com or call 1-877-317-7638
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3. Your signature; and
4. A clear statement that you want to be excluded from the Settlement Class, such as “I hereby
request to be excluded from the proposed Settlement Class in Williams v. Galderma
Laboratories, L.P., Case No. 1:24-cv-02222.”
The exclusion request must be sent to the Claims Administrator at the following address postmarked
or received by May 19, 2026:
Differin BPO Product Claims Administrator
PO Box 4100
Portland, OR 97208-4100
You cannot exclude yourself by telephone or by email, and you cannot opt out on behalf of anyone else.
You may not request to be excluded from the Settlement Class through “mass” or “class” opt-outs,
meaning that each Person who seeks to be excluded must send an individual, separate, request to the
Claims Administrator that complies with all requirements listed above.
18. If I exclude myself, can I get a cash payment from the Settlement?
No. If you exclude yourself, you will not receive a cash payment for Differin products from this
Settlement. You can only get a cash payment for Differin products if you stay in the Settlement and
submit a Valid Claim Form.
19. If I do not exclude myself, can I sue Galderma for the same thing later?
No. Unless you exclude yourself, you give up any right to sue Galderma and the Released Parties
about the legal claims that are released by the Settlement. You must exclude yourself from this lawsuit
to start or continue with your own lawsuit or be part of any other lawsuit against Galderma and the
Release Parties about the Released Claims in this lawsuit. If you have a pending lawsuit, speak to
your lawyer in that case immediately.
OBJECTING TO THE SETTLEMENT
20. How do I tell the Court that I do not like the Settlement?
If you are a Settlement Class Member, you may object to the Settlement, including the Fee Award or
Service Awards, by filing an objection. You cannot ask the Court to order a different settlement; the
Court can only approve or reject the current Settlement. If the Court denies approval, no cash
payments will be sent out as part of the Settlement, and the lawsuit will continue.
To object, you must file your written objection with the Court electronically or mailed to the Court
and posted on the Court’s docket by May 19, 2026, stating you object to the Settlement in Williams
v. Galderma Laboratories, L.P., Case No. 1:24-cv-02222. To file an objection, you cannot exclude
yourself from the Settlement Class. Your objection must include the following information:
1. the case name Williams v. Galderma Laboratories, L.P., Case No. 1:24-cv-02222;
2. your name, address, and telephone number;
3. the name, address, and telephone number of all counsel (if any) who represent you, including
any former or current counsel who may be entitled to compensation for any reason if the
objection is successful;
4. a detailed statement of any objection asserted, including the grounds therefor;
5. whether the objector is, and any reasons for, requesting the opportunity to appear and be heard
at the Final Approval hearing;
Questions? Go to www.DifferinBPOProductSettlement.com or call 1-877-317-7638
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6. the identity of all counsel (if any) representing the objector who will appear at the Final
Approval hearing and, if applicable, a list of all persons who will be called to testify in support
of the objection;
7. copies of any papers, briefs, declarations, affidavits, or other documents upon which the
objection is based;
8. a detailed list of any other objections submitted by your, or your counsel, to any class actions
submitted in any state or federal court in the United States in the previous five years (or
affirmatively stating that no such prior objection has been made); and
9. your signature, in addition to the signature of the objector’s attorney (if any).
Speaking at the Final Approval Hearing. If you want to speak at the Final Approval Hearing to
object to the Settlement you must state that in your written objection. If you do not file a timely
written objection in the manner specified above, you will waive any objections and will be prohibited
from making any objection (whether by appeal or otherwise) to the Settlement. If you are not a
Settlement Class Member, you may not object to the Settlement.
If You Hire Your Own Lawyer to Represent You for Your Objection. If your lawyer wants to
appear at the Final Approval Hearing, your lawyer must file, through the Federal Court CM/ECF
system, a Notice of Appearance in this lawsuit no later than ten (10) days before the originally-
scheduled date of the Final Approval Hearing (if the Final Approval Hearing is continued, the
deadline runs from the first-scheduled Final Approval Hearing ).
The Parties may seek expedited discovery from an objecting Settlement Class Member regarding the
basis for an objection, to allow them to appropriately respond to the objection. Failure by the objecting
Settlement Class Member to comply with expedited discovery requests may result in the Court
striking the Settlement Class Member’s objection and otherwise denying that Settlement Class
Member the opportunity to make an objection or be further heard.
21. What is the difference between objecting and asking to be excluded?
Objecting is simply telling the Court you do not like something about the Settlement. Requesting
exclusion (opting out) is telling the Court you do not want to be part of the Settlement Class or the
Settlement. If you exclude yourself, you cannot object to the Settlement.
THE FINAL APPROVAL HEARING
22. When and where will the Court decide whether to approve the Settlement?
The Court will hold a Final Approval Hearing on June 30, 2026 at 9:15 a.m. before the Honorable
Lindsay Jenkins, United States District Judge for the United States District Court for the District of
Northern District of Illinois, Everett McKinley Dirksen United States Courthouse, 219 South
Dearborn Street, Chicago, IL 60604, Courtroom 2119. At this hearing, the Court will consider
whether the Settlement is fair, reasonable, and adequate, and decide whether to approve the
Settlement, Settlement Class Counsel’s Fee Award and the Service Awards to the Class
Representatives.
If there are objections, the Court will consider them. If you submit a timely, written objection, and
you would like to speak at the hearing, you must indicate in your written objection that would wish
to speak at the Final Approval Hearing to object to the Settlement. If you file a timely, written
objection and you hire your own lawyer and your lawyer would like to appear at the Final Approval
Hearing, your lawyer must file, through the Federal Court CM/ECF system, a notice of appearance
in the lawsuit no later than ten (10) days before the originally-scheduled date of the Final Approval
Questions? Go to www.DifferinBPOProductSettlement.com or call 1-877-317-7638
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Hearing (if the Final Approval Hearing is postponed, the deadline runs from the first-scheduled Final
Approval Hearing).
Note: The date and time of the Final Approval Hearing are subject to change without further notice
to the Settlement Class. The Court may also decide to hold the hearing via Zoom or telephone. You
should check the Settlement Website www.DifferinBPOProductSettlement.com.
23. Do I have to attend the Final Approval Hearing?
No. Plaintiff’s Counsel will answer any questions the Court may have. However, you are welcome to
attend at your own expense. You cannot speak at the Final Approval Hearing unless you object and
follow the requirements for requesting to speak. If you file an objection, you do not have to attend
the Final Approval Hearing to talk about it. As long as you file your written objection on time, the
Court will consider it.
IF YOU DO NOTHING
24. What happens if I do nothing at all?
If you are a Settlement Class Member and you do nothing, you will not receive a cash payment. You
will give up your right to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit
against Galderma and the Released Parties about the legal claims that are released by the Settlement.
GETTING MORE INFORMATION
25. How do I get more information?
This Notice summarizes the Settlement. Complete details about the Settlement are provided in the
Settlement Agreement. The Settlement Agreement and other related documents are available at
www.DifferinBPOProductSettlement.com. You may get additional information at
www.DifferinBPOProductSettlement.com, by calling toll-free 1-877-317-7638, or by writing to:
Differin BPO Product Claims Administrator
PO Box 4100
Portland, OR 97208-4100
PLEASE DO NOT TELEPHONE THE COURT OR THE COURT CLERK’S OFFICE
REGARDING THIS NOTICE, THE SETTLEMENT OR THE CLAIM PROCESS.
Questions? Go to www.DifferinBPOProductSettlement.com or call 1-877-317-7638
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