NOTICE OF PROPOSED CLASS-ACTION SETTLEMENT
UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS, WESTERN DIVISION
A court authorized this Notice. You are not being sued. This is not a solicitation from a lawyer.
If you purchased Repair Services for John Deere Large
Agricultural Equipment from John Deere or a Deere-authorized
Dealer in the United States during the period of January 10,
2018 through May 18, 2026, you may get a payment from a
class-action Settlement.
• The purpose of this Notice is to alert you to a proposed settlement of a class-action lawsuit in which
Plaintiffs have alleged, among other things, that defendant Deere & Company, doing business as John
Deere (“Deere” or “John Deere”), engaged in an anticompetitive scheme to withhold from customers
and independent repair providers (“IRPs”) certain repair tools for Deere-manufactured agricultural
equipment that depend for their functioning, in part, on electronic control units and which include
large and medium tractors (all 6000, 7000, 8000 and 9000 Series models); combines; cotton pickers;
cotton strippers; sugarcane harvesters; tillage, seeding (including planters), and application
equipment and sprayers (“Large Agricultural Equipment”). Plaintiffs allege that Class members were
thus required to use Deere-authorized Dealers for the diagnosis, maintenance, and repair of their
Deere Large Agricultural Equipment (“Repair Services”) and, as a result, paid more than they should
have for those Repair Services. John Deere denies any wrongdoing. The lawsuit is referred to in the
rest of this document as the “Action.”
• Plaintiffs and John Deere have reached a proposed settlement to end the Action (the “Settlement”)
consisting of $99 million dollars and injunctive relief involving changes to Deere’s business
practices relating to repair. At the time of this Notice, the total value of the Settlement is estimated
by Plaintiffs’ expert to be between $392.9 million and $747 million. This Settlement value includes:
(1) $99 million cash, plus interest that has been accruing since January 15, 2026 (the “Settlement
Fund”); and (2) injunctive relief requiring Deere to make repair capabilities and tools available to
farmers and IRPs. The estimated value of the injunctive relief is between $293.9 million and $648
million. The injunctive relief provisions require Deere to provide customers and IRPs with all the
digital tools required for the maintenance, diagnosis, and repair of Deere Large Agricultural
Equipment without which such equipment cannot be operated in the manner for which it was
designed. The repair tools to be provided by Deere to farmers and IRPs under the Settlement will
mean that farmers will no longer have to go to Deere-authorized Dealers for repairs.
• PLEASE NOTE that the Federal Trade Commission and the attorneys general of five states (the
“FTC”) has entered into an independent settlement with Deere (the “FTC Settlement”) for
injunctive relief, for which you will be receiving a separate notice. Despite some language
1
differences in the settlement agreements, the repair resources covered by the injunctive provisions
in this Settlement and the FTC Settlement are the same in substance and meaning and, for the
avoidance of doubt, the parties have agreed that the scope of repair resources covered by this
Settlement and the FTC Settlement shall be interpreted identically. In contrast to this case, however,
the FTC Settlement does not provide for any monetary recovery for individual class members. To
obtain monetary relief, you must follow the instructions set forth in this Notice.
• For purposes of this Settlement, the “Settlement Class” is defined as: All persons and entities who
purchased Repair Services for Deere Large Agricultural Equipment from John Deere or its authorized
Dealers in the United States between January 10, 2018 and May 18, 2026 (the “Class Period”).
Excluded from the Settlement Class are all governmental entities; Deere and any parent, subsidiary,
or affiliate thereof; Deere’s officers, directors, employees, and immediate families; and any judicial
officer presiding over this Action and the members of his/her judicial staff and immediate family.
• The injunctive relief in the Settlement will be provided for the benefit of all members of the
Settlement Class.
• A portion of the Settlement Fund Amount will be used by the settlement administrator (“the
Settlement Administrator”) to distribute notice and administer the Settlement; this includes sending
notice of the proposed Settlement, managing the claims process, and distributing funds to eligible
claimants, among other tasks. Attorneys for the Class (“Settlement Class Counsel”) will also apply
for an award of attorneys’ fees not to exceed $45 million, reimbursement of litigation costs and
expenses not to exceed $6 million, and $25,000 service awards to each of the Named Plaintiffs, which
will be paid from the Settlement Fund Amount if approved by the Court.
• The remainder of the Settlement’s proceeds (the “Net Settlement Fund”) will be available for
distribution to Settlement Class members who file valid and timely claims. Cash payments from the
Net Settlement Fund will be made to only those Settlement Class members who file valid, timely
Claims.
• Visit www.DeereRepairSettlement.com for more information about the Settlement.
• Please read this Notice carefully. Your legal rights will be affected, and you have a choice to make
now.
SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS REGARDING THE SETTLEMENT
FILE A CLAIM FORM Filing a claim form is the only way to receive money from the Settlement. That
claim form must be submitted on or before December 31, 2026 for you to be eligible
to receive payment from the Net Settlement Fund.
You do not need to file a claim form to receive the benefit of the injunctive relief.
DEADLINE: December The injunctive relief provided by the Settlement applies uniformly to you and all
31, 2026 members of the Settlement Class, regardless of whether you file a claim form.
Your interests will be represented by the Settlement Class Representatives and
Settlement Class Counsel listed below. As a member of the Settlement Class, you
will be bound by any judgment dismissing with prejudice the claims against John
2
Deere, and you will not be able to file or maintain your own lawsuit against John
Deere regarding the subject of this lawsuit.
DO NOTHING AND If you do nothing, and do not exclude yourself by December 4, 2026, you will
REMAIN IN THE remain a member of the Settlement Class, you will be bound by any judgment
SETTLEMENT CLASS dismissing with prejudice the claims against John Deere, and you will not be able
to file or maintain your own lawsuit against Deere regarding the subject of this
Action. If you do not file a claim by December 31, 2026, you will not be eligible to
receive a payment under the Settlement, but you will still receive the benefit of the
injunctive relief.
SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS REGARDING THE SETTLEMENT
EXCLUDE YOURSELF Excluding yourself from the Settlement means you will get no payment. This is the
only option that allows you to keep the right to assert your own claims for damages
or other relief against John Deere based on allegations related to this Action.
DEADLINE: December 4,
2026
OBJECT AND/OR You can object to any part of the Settlement. If you wish to object to the Settlement,
ATTEND HEARING or anything else referenced in this Notice, you must file a written objection by
December 4, 2026. You may also request to be heard at the Fairness Hearing.
DEADLINE: December 4,
2026
FUTURE The Court in this case will have jurisdiction to enforce the injunctive relief provided
ENFORCEMENT OF in the Settlement Agreement for the next ten years. This means that if you believe
THE SETTLEMENT John Deere is not complying with the requirements in the Settlement Agreement,
AGREEMENT & you may—after providing written notice of non-compliance to Settlement Class
INJUNCTIVE RELIEF Counsel and John Deere and engaging in good-faith discussions to try to resolve
PROVISIONS the issues you raise—file a motion and request that the Court enforce the terms of
the Agreement. You can learn more about your right to ask the Court to enforce the
Settlement Agreement in that Agreement, which is available at
www.DeereRepairSettlement.com.
• These rights and options—and the deadline to exercise them—are explained in this Notice.
• The Court in charge of this Action still must decide whether to approve the Settlement. Injunctive
relief will be implemented and payments from the Net Settlement Fund will be made only after the
Court finally approves the Settlement and after any appeals are resolved.
3
WHAT THIS NOTICE CONTAINS
BASIC INFORMATION…………………………………………………………………………….4
THE SETTLEMENT CLASS………………………………………………………………….…….5
THE SETTLEMENT BENEFITS…………………………………………………………………….6
HOW TO GET A PAYMENT—MAKING A CLAIM………………………………………………....8
THE LAWYERS REPRESENTING YOU………………………………………………………….....8
EXCLUDING YOURSELF FROM THE SETTLEMENT ………………………………………...….....9
OBJECTING TO THE SETTLEMENT……………………………………………………………...10
THE COURT’S FAIRNESS HEARING………………………………………………………….… 12
IF I DO NOTHING…………………………………………………………………………….… 13
GETTING MORE INFORMATION…………………………………………………………..…… 13
BASIC INFORMATION
1. Why did I receive a Notice?
A Court authorized this Notice to explain the rights Settlement Class members have pursuant to the
Settlement. If you are a member of the Settlement Class and the Settlement is approved, you will receive
the benefit of the injunctive relief in the Settlement, and you could be eligible to receive a payment from
the Net Settlement Fund. To know if you qualify, see the answer to Question 5.
2. What is this lawsuit about?
The people who sued are called “Named Plaintiffs.” The plaintiffs representing you in this Settlement are
referred to as “Class Representatives.” Deere & Company, doing business as John Deere, is the defendant.
The lawsuit alleged, among other things, that Deere violated the federal antitrust laws by engaging in an
anticompetitive scheme to withhold from customers and IRPs certain repair tools for Large Agricultural
Equipment, which led customers to pay more for repair services for their Large Agricultural Equipment
than they would have in a fully competitive market. John Deere denies these allegations. The Court has not
decided who is right.
Important information on the case will be posted on the Settlement website,
www.DeereRepairSettlement.com, as it becomes available. Please check the website to be kept informed
about any future developments.
4
3. What is a class action?
In a class action, plaintiffs sue on behalf of themselves and other people who have similar claims. This
group of people is called the “class,” and the people in the class are called “class members.” One court
resolves the issues for all class members, except for the people who exclude themselves from the class.
Here, the Honorable Iain D. Johnston of the United States District Court for the Northern District of Illinois,
Western Division is the judge presiding over this case. The case is In re Deere & Company Repair Services
Antitrust Litigation, Case No. 3:22-cv-50188.
4. Why is there a Settlement of this lawsuit?
The Court did not decide in favor of the Plaintiffs or Deere. Instead, both sides agreed to the Settlement.
Class members receive the benefit of injunctive relief and can get compensation. Class Counsel think the
Settlement is best for the Settlement Class.
THE SETTLEMENT CLASS
5. Who is in the Settlement?
The Settlement Class consists of persons or entities who purchased Repair Services for Deere Large
Agricultural Equipment from John Deere or its authorized Dealers in the United States between January
10, 2018 and May 18, 2026. Excluded from the Settlement Class are all governmental entities; Deere and
any parent, subsidiary, or affiliate thereof; Deere’s officers, directors, employees, and immediate families;
and any judicial officer presiding over this action and the members of his/her judicial staff and immediate
family.
Equipment qualifying as “Deere Large Agricultural Equipment” is agricultural equipment manufactured by
John Deere, which depend for their functioning, in part, on electronic control units (“ECUs”) and which
include large and medium tractors (all 6000, 7000, 8000, and 9000 Series models); combines; cotton
pickers; cotton strippers; sugarcane harvesters; tillage, seeding (including planters), and application
equipment and sprayers.
“Repair Services” refers to the diagnosis, maintenance, and/or repair of any Deere Large Agricultural
Equipment.
6. What should I do if I am still not sure whether I am included?
If you are not sure whether you are included in the Settlement Class, you can ask for free help by calling
the Settlement Administrator at 1-844-644-4294 or email [email protected] for more
information.
5
THE SETTLEMENT BENEFITS
7. What does the Settlement provide?
Deere has agreed to provide injunctive relief to the Settlement Class by providing customers and IRPs
access to digital tools required for the maintenance, diagnosis, and repair of Deere Large Agricultural
Equipment, and without which such equipment cannot be operated in the manner for which it was designed.
This relief means that farmers do not have to use the services of a Deere-authorized dealer to obtain Repair
Services.
Deere will also pay $99 million, plus interest accruing since January 15, 2026, into a “Settlement Fund.”
After deduction for attorneys’ fees not to exceed $45 million, litigation costs and expenses not to exceed
$6 million, $25,000 service awards for each of the seven Named Plaintiffs, notice and claims-administration
costs, and applicable taxes and tax-preparation expenses (see Question 15), the Net Settlement Fund will
be distributed to Settlement Class members who submit valid and timely claims.
At the time of this Notice, the total value of the proposed Settlement is estimated by Plaintiffs’ expert to be
between $392.9 million and $747 million ($99 million cash, plus the value of the injunctive relief, which
is estimated to be between $293.9 million and $648 million).
More details are in the Settlement Agreement, available at www.DeereRepairSettlement.com.
8. What is the difference between injunctive relief and monetary relief?
This Settlement has two parts: 1) injunctive relief; and 2) monetary relief.
Injunctive relief concerns the actions John Deere must take under the Settlement Agreement; in this regard,
John Deere has agreed to provide customers and IRPs access, on fair and reasonable terms, to digital tools
required for the maintenance, diagnosis, and repair of Deere Large Agricultural Equipment, and without
which such equipment cannot be operated in the manner for which it was designed. The injunctive relief is
intended to provide repair tools and diagnostic capabilities so that farmers and IRPs do not have to use an
authorized Deere dealer for their repair needs. You do not have to do anything to receive this injunctive
relief. As a member of the Settlement Class, you will have access, on fair and reasonable terms, to these
digital tools (along with new repair tools as soon as Deere makes them available), and you—along with all
other owners of Deere Large Agricultural Equipment and IRPs—will be able to obtain and use them. (New
tools covered by the injunction are “available” when they pass Deere’s internal development and testing
processes and are distributed to more than 50% of authorized Deere dealers for widespread use in the Deere
repair ecosystem.) The Court in this case will have jurisdiction to enforce the injunctive relief in the
Settlement Agreement for ten years.
Monetary relief is the money that John Deere is paying into the Settlement Fund. Settlement Class members
must file a valid claim to be eligible to receive payment from the Net Settlement Fund.
6
9. How much money can I get from the Settlement and what is the distribution plan?
The amount of your payment will be determined by the Plan of Allocation, if it is approved, or by such
other plan of allocation that the Court approves.
The Plan of Allocation provides for a pro rata distribution of the Net Settlement Fund to eligible claimants
that purchased Repair Services for Large Agricultural Equipment by direct payment or extended warranty
coverage (but not Deere factory warranty repairs). Each eligible claimant’s award will be calculated based
on the total number of labor hours expended on Repair Services for the claimant’s qualifying Large
Agricultural Equipment between January 10, 2018 and May 18, 2026. By tying monetary relief to actual
hours spent by Deere authorized Dealers providing Repair Services on Large Agricultural Equipment
during the Class Period, each Settlement Class member’s individual share of the Settlement will be pegged
to the anticompetitive harm they suffered. As an example, if during the Class Period Deere-authorized
Dealers expended on your Large Agricultural Equipment 1% of all labor hours included in validly submitted
claims, you would receive 1% of the Net Settlement Fund.
If the qualifying Repair Services on your Large Agricultural Equipment were completed under an extended
warranty that you purchased, you are eligible to receive payment for those Repair Services. You must,
however, include in your claim form the requested information about the purchase of the extended warranty.
Repairs made pursuant to Deere factory warranties are not eligible for recovery in the Settlement.
Plaintiffs have data from John Deere and other sources regarding the number of labor hours expended
repairing each piece of Deere Large Agricultural Equipment during the Class Period. In many instances,
your qualifying Repair Services will be reflected in those records, and you will receive by mail or email a
notice instructing you how to access that information using a Notice ID and Confirmation Code. If your
Repair Services are not included in the data from John Deere—such that you do not receive a notice with a
Notice ID and Confirmation Code—or you believe the data from John Deere does not include all of your
qualifying Repair Services, you will need to provide records or documentation of the Repair Services for
which you seek compensation.
Should the Settlement Administrator request additional information regarding your claim after it is
submitted, you must provide those records or risk having the Repair Services that are the subject of the
request deducted from your recovery.
For more information on how to make a claim, see Question 11 and www.DeereRepairSettlement.com.
10. What am I giving up if I stay in the Settlement Class?
Unless you exclude yourself from the Settlement with a valid request for exclusion (see Question 16), you
cannot sue, continue to sue, or be part of any other lawsuit against John Deere relating to the issues in this
case.
The “Released Claims” in the Settlement Agreement describes the legal claims that you give up if you
remain in the Settlement. The Settlement Agreement can be viewed at www.DeereRepairSettlement.com.
7
HOW TO GET A PAYMENT—MAKING A CLAIM FOR MONETARY
DAMAGES
11. How can I get a payment?
Any person or entity who purchased Repair Services for Deere Large Agricultural Equipment from John
Deere or its authorized Dealers in the United States between January 10, 2018 and May 18, 2026 can file a
claim at www.DeereRepairSettlement.com, or return the claim form to the Settlement Administrator at the
address set forth below in Question 26 on or before December 31, 2026.
12. When will I get my payment?
At this time, it is not known precisely how much each eligible claimant will receive or when payments will
be made. The Court will hold a hearing on January 19, 2027 at 10:00 a.m. Central, at the Stanley J.
Roszkowski U.S. Courthouse, 327 South Church Street, Rockford, IL 61101, Courtroom 5200, to decide
whether to approve the Settlement. If the Court approves the Settlement, there may still be appeals of that
decision. No payments to Settlement Class members will be made until any such appeals are resolved and
the claims process has been completed, and it is hard to estimate how long that might take.
Updates regarding the Settlement and when payouts will be made will be posted on the Settlement website,
www.DeereRepairSettlement.com.
THE LAWYERS REPRESENTING YOU
13. Do I have a lawyer in the case?
Yes. The Court appointed the law firms of Wexler Boley & Elgersma LLP, Gustafson Gluek PLLC, and
Cotchett, Pitre & McCarthy, LLP to represent you and the other Settlement Class members. These firms
are called Settlement Class Counsel. You will not be charged for their services.
14. Should I get my own lawyer?
You do not need to hire your own lawyer because Settlement Class Counsel is working on your behalf. If
you want your own lawyer, you may hire one, but you will be responsible for any payment for that lawyer’s
services. For example, you can ask your own lawyer to appear in Court for you if you want someone other
than Settlement Class Counsel to speak for you. You may also appear for yourself without a lawyer.
15. How will the lawyers be paid?
You do not have to pay Settlement Class Counsel. Settlement Class Counsel, who have not been paid for
their services since this case began in 2022, will seek an award of attorneys’ fees out of the Settlement
Fund, as well as reimbursement for litigation costs and expenses they advanced in pursuing the claims. The
attorneys’ fees will compensate Settlement Class Counsel for investigating the facts, litigating the case, and
8
negotiating and administering the Settlement. Settlement Class Counsel’s attorneys’ fee request will not
exceed one-third of the combined value of the Settlement Fund and the value of the injunctive relief. In no
event will Settlement Class Counsel seek a fee exceeding $45 million. Additionally, Settlement Class
Counsel will seek reimbursement of their out-of-pocket litigation expenses to be paid out of the Settlement
Fund in an amount not to exceed $6 million.
Plaintiffs will also ask the Court to approve $25,000 service-award payments out of the Settlement Fund
for each of the seven Named Plaintiffs, each of whom sat for a deposition, produced documents, and actively
participated in the Action.
The costs of providing this Notice and administering the Settlement, including managing the claims process
and distributing funds to eligible claimants, are also being paid from the Settlement Fund.
Applicable taxes on the Settlement Fund and tax-preparation expenses will also be paid from the Settlement
Fund.
EXCLUDING YOURSELF FROM THE SETTLEMENT
If you do not want the benefits from the Settlement and you want to keep your right, if any, to sue John
Deere for relief addressing the factual and legal issues in this case, then you must take steps to get out of
the Settlement. This is called excluding yourself from—or “opting out” of—the Settlement.
16. How do I get out of the Settlement?
Any Settlement Class member may opt out of the Settlement by sending a letter that includes the following
to the address below:
• The case name and number;
• Your full name, current mailing address, telephone number, and email address;
• A statement that the person or entity wants to be excluded from the Settlement Class for monetary
relief; and
• Your signature if you are an individual, or if the Class Member is an entity, a signature from the
authorized representative of the entity along with a statement of that person’s position or authority
by which he or she has the power to exclude the entity from the Settlement Class.
Deere Repair Services Antitrust Litigation
Attn: Exclusions
P.O. Box 58220, Philadelphia, PA 19102
Settlement Class members are not permitted to exclude other Settlement Class members. Group or class-
wide exclusions also are not permitted. A request for exclusion must be submitted by each Settlement Class
member on an individual basis, and any request for exclusion by a purported authorized agent or
representative of a Settlement Class member must include proof of the representative’s legal authority and
authorization to act and request exclusion on behalf of each Settlement Class member they seek to opt out.
If you exclude yourself from the Settlement, you will not receive any money from the Net Settlement Fund,
you will not be legally bound by anything that happens in the lawsuit, and you may be able to sue (or
continue to sue) John Deere in the future in connection with the issues in this case.
9
Mailed opt-out requests must be sent (i) by first-class U.S. mail, with postage prepaid and postmarked on
or before December 4, 2026, or (ii) by registered, or certified mail delivery as shown by receipt as sent on
or before December 4, 2026.
A request for exclusion that does not include all of the foregoing information, that does not contain the
proper signature, that is sent to an address other than the one designated above, or that is not sent within the
time specified shall be invalid and the individual or entity filing such an invalid request shall remain a
Settlement Class member and shall be bound by the Settlement, if approved.
17. If I do not opt out, can I sue John Deere for the same thing later?
No. Unless you opt out, you give up the right to sue John Deere for the claims the Settlement resolves. You
must exclude yourself from the Settlement Class if you want to try to pursue your own lawsuit.
18. What will happen if I opt out?
If you opt out of the Settlement, you will not have any rights as a member of the Settlement Class under the
Settlement; you will not receive any payment as part of the Settlement; you will not be able to object to the
Settlement; you will not be bound by any further orders or judgments in this Action; and you will keep the
right, if any, to sue John Deere regarding the claims alleged in this Action by filing or continuing your own
lawsuit at your own expense.
OBJECTING TO THE SETTLEMENT
19. How do I tell the Court if I do not like the Settlement?
If you are a Settlement Class Member and do not opt out of the Settlement, you can ask the Court to deny
approval of the Settlement by filing an objection. You cannot ask the Court to order a larger settlement; the
Court can only approve or deny the Settlement as submitted by the parties. If the Court denies approval, no
Settlement payments will be made, the injunction will not go into effect, and the lawsuit will continue
against Deere. If that is what you want to happen, you may object. You may also object to the requests for
attorneys’ fees, litigation costs and expenses, and service awards. You may choose to appear at the Fairness
Hearing, either in person or through your own attorney, although you are not required to do so. If you appear
through your own attorney, you are responsible for paying that attorney.
Your objection must be in writing.
To object, you must file a document with the Court saying that you object to the proposed Settlement in In
re Deere & Company Repair Services Antitrust Litigation, Civil Action No. 3:22-cv-50188, MDL No. 3030.
Your objection must include:
• Your name, address, email address, and the identity of and contact information for any attorney
representing you;
• Whether you plan to appear, either in person or through counsel, at the Fairness Hearing;
10
• Proof of membership in the Settlement Class, including any documentation evidencing you
purchased Repair Services from Deere or an authorized Dealer during the Class Period;
• The specific reasons you object, along with any supporting materials or documents in support of
the objection;
• Whether your objection applies only to yourself, to a subset of the Settlement Class, or to the
Settlement Class as a whole;
• A list of all class action settlements to which you and/or your counsel have previously objected;
and
• Your signature.
You must send the objection to the Court at the address indicated below, by first-class U.S. mail postmarked
no later than December 4, 2026, or by registered or certified mail delivery as shown by receipt as sent on
or before December 4, 2026. You must also send your objection to the lawyers listed below, either by mail
(as just described) or by email to each of the following addresses:
Court Class Counsel Counsel for John Deere
Clerk of the Court Kenneth A. Wexler Tiffany D. Lipscomb-Jackson
United States District Court Wexler Boley & Elgersma LLP JONES DAY
for the Northern District of 311 South Wacker Drive, 325 John H. McConnell Blvd.
Illinois Suite 5450 Suite 600
Western Division Chicago, IL 60606 Columbus, OH 43215-2673
Stanley J. Roszkowski United [email protected] [email protected]
States Courthouse
327 South Church Street Daniel C. Hedlund
Rockford, IL 61101 Gustafson Gluek PLLC
120 South Sixth Street
Suite 2600
Minneapolis, MN 55402
[email protected]
Adam J. Zapala
Cotchett, Pitre & McCarthy LLP
840 Malcom Road
Burlingame, CA 94010
[email protected]
If your mailed objection is not postmarked by the deadline and does not include the information listed
above, it will not be valid. Similarly, if the objection emailed to Class Counsel is not received by December
4, 2026, and does not include the information listed above, it will not be valid.
In addition, any objector or counsel for an objector that desires to appear at the Fairness Hearing must file
with the Court, and send to the designees of Class Counsel and John Deere’s Counsel identified above, by
first-class U.S. mail and postmarked by December 4, 2026, by registered or certified mail delivery as shown
by receipt as sent on or before December 4, 2026, or by email sent on or before December 4, 2026, a
separate notice of intention to appear in In re Deere & Company Repair Services Antitrust Litigation, Case
No. 3:22-cv-50188 (N.D. Ill.) that identifies by name, position, address, email address, and telephone
number each person who intends to appear at the Fairness Hearing on behalf of the objector as well as the
objector’s signature.
11
20. What is the difference between objecting and excluding?
Objecting is telling the Court that you do not like something about the Settlement. You can object to the
Settlement only if you do not exclude yourself from the Settlement. Excluding yourself from the Settlement
is opting out and telling the Court that you do not want to be part of the Settlement. If you opt out of the
Settlement, you cannot object to it because it no longer affects you.
THE COURT’S FAIRNESS HEARING
21. When and where will the Court decide whether to approve the Settlement?
The Court will hold a Fairness Hearing on January 19, 2027 at 10:00 a.m. Central in the United States
District Court for the Northern District of Illinois, Western Division, in Courtroom 5200 located at the
Stanley J. Roszkowski United States Courthouse, 327 South Church Street, Rockford, IL 61101.
At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate and whether
to award the requested attorneys’ fees, litigation costs and expenses, and service awards. If there are
objections, the Court will consider them. The Court will listen to people who have asked to speak at the
hearing.
The Court may reschedule the Fairness Hearing or change any of the deadlines described in this Notice.
The date of the Fairness Hearing may change without further notice. Be sure to check the website,
www.DeereRepairSettlement.com, for news of any such changes.
22. Do I have to come to the Fairness Hearing?
No. Settlement Class Counsel will answer any questions the Court may have. You may attend at your own
expense if you wish. If you send an objection, you do not have to come to Court to talk about it. As long as
you mail your written objection on time, the Court will consider it. You may also pay your own lawyer to
attend, but doing so is not necessary.
23. May I speak at the hearing?
You may ask the Court for permission to speak at the Fairness Hearing. To do so, you must include a
statement in your written objection (discussed above at Question 19) that you intend to appear at the hearing.
You must include your name, address, and signature. You cannot speak at the hearing if you exclude
yourself from the Settlement Class.
12
IF I DO NOTHING
24. What happens if I do nothing at all?
If you do nothing and do not exclude yourself by December 4, 2026, you will remain a member of the
Settlement Class, you will be bound by any judgment dismissing with prejudice the claims against John
Deere, and you will not be able to file or maintain your own lawsuit against John Deere regarding the
subject of this Action. If you do not file a claim by December 31, 2026, you will not be eligible to receive
a payment under the Settlement.
GETTING MORE INFORMATION
25. Are more details about the Settlement available?
Yes. This Notice summarizes the proposed Settlement—more details are in the Settlement Agreement and
other important case documents. You can get a copy of these documents at
www.DeereRepairSettlement.com.
PLEASE DO NOT TELEPHONE THE COURT OR THE COURT CLERK’S OFFICE TO ASK ABOUT
THIS SETTLEMENT OR THE CLAIMS PROCESS.
26. How do I get more information?
The Settlement Website at www.DeereRepairSettlement.com has important Court documents and answers
to questions about the Settlement and other information to help you determine whether you are eligible for
a payment.
You can also call or write to the Settlement Administrator at:
Deere Repair Services Antitrust Litigation
Settlement Administrator
1650 Arch Street, Suite 2210
Philadelphia, PA19103
[email protected]
13
