Dow and Huntsman Diisocyanates Antitrust Settlement

The settlement is for people and organizations in the United States, its territories, or Washington, D.C. that directly purchased or received qualifying MDI or TDI from the listed companies during the class period. It is not limited to purchases from Dow or Huntsman.

• The covered products are all kinds of methylene diphenyl diisocyanate (MDI) and toluene diisocyanate (TDI), regardless of trade name.
• The purchase or receipt must have been direct, including through a controlled subsidiary, agent, affiliate, or joint venture.
• The notice lists the possible suppliers: the Defendants, Covestro AG, Wanhua Chemical Group Co., Ltd., Mitsui Chemicals, Inc., Mitsui Chemicals America, Inc., MCNS, MCNS Polyurethanes USA Inc., or their subsidiaries, affiliates, or successors.
• The time period runs from January 1, 2016 through July 29, 2026.

The notice has specific exclusions even if an organization otherwise bought or received the products.

• Defendants and alleged co-conspirators, along with their parents, subsidiaries, and affiliates, are excluded.
• State and federal government entities are excluded.
• The judge and other judicial officers presiding over the case, their immediate families and staff, and assigned jurors are excluded.
• People who timely and validly opt out are excluded.

This is a shared fund, not a fixed payment for each class member.

• Dow and Huntsman have agreed to contribute $20 million to the fund.
• The fund first pays court-approved attorneys’ fees, costs and expenses, service awards, and notice and administration costs.
• Eligible claimants may receive a proportional share of what remains, called the Net Fund.
• The amount will depend on the court-approved Plan of Allocation and the amount of qualifying products purchased. The notice does not promise a particular dollar payment.

The notice gives a special instruction for people who already filed a Claim Form and/or Purchase Audit Request Form in the earlier settlements, but it does not state in this notice what, if anything, those people must do for this settlement.

• If you did not submit a Claim Form and/or Purchase Audit Request Form in the earlier BASF, Covestro, and Wanhua settlements, the notice says you must submit a Claim Form or Purchase Audit Request Form by October 19, 2026 to receive a payment.
• If the purchase amounts on your Claim Form are correct, complete, sign, and submit the Claim Form. No additional purchase documents are required.
• If you want to change or add to the listed purchase amounts, submit a Purchase Audit Request Form with supporting records, such as purchase orders or sales receipts.
• Without that supporting documentation, the notice says the payment calculation will use the purchase amounts shown in the Class Notice from the Defendants’ records.

The deadline for the required claim submission described in the notice is October 19, 2026.

• Forms may be submitted online or mailed to the Settlement Administrator.
• The mailing address is In re: Diisocyanates Antitrust Litigation, c/o Kroll Settlement Administration LLC, P.O. Box 225391, New York, NY 10150-5391.
• Online submission uses the Class ID from the Class Notice. The notice says a person can request a form, Purchase Audit Request Form, or Class ID from the Settlement Administrator.

A court approval date passing does not mean payments will immediately be sent.

• Payments can be distributed only after the settlement receives final approval and any challenges to that approval are resolved.
• The fairness hearing is scheduled for December 7, 2026, but that is not a payment date.
• Appeals may delay payment, and the notice does not provide a specific distribution date.

A person who opts out may revoke that request by mailing a written revocation that is received by December 3, 2026.

• To opt out means to leave the settlement.
• A request must say that you want to be excluded, and include your name, company name, address, telephone number, email address, and signature.
• Mail the request to the Settlement Administrator and have it postmarked by October 19, 2026.
• Opting out preserves the right to sue Dow and Huntsman separately over the claims resolved by this settlement, but a person who opts out cannot object to this settlement.

Objecting asks the Court not to approve all or part of the settlement. It is different from opting out, which removes a person from the settlement.

• An objection must be in writing and filed with the Court by October 19, 2026.
• A copy must also be mailed to Class Counsel, counsel for Dow, counsel for Huntsman, and the Settlement Administrator, postmarked by October 19, 2026.
• The objection must include proof of membership in the settlement class, the grounds for the objection, documents or writings for the Court to consider, and a signature, among other listed information.
• Only class members who do not opt out may object.

The Court has not yet given final approval to the settlement.

• The hearing is scheduled for December 7, 2026, at 1:00 p.m. ET.
• It is scheduled at the Joseph F. Weis, Jr. Courthouse, 700 Grant Street, Pittsburgh, Pennsylvania.
• The Court will consider objections and decide whether to approve the settlement and requested fees, expenses, and service awards.
• Attendance is optional, including for someone who filed a written objection. The hearing date or time may change.

The notice separately describes the submission requirement for receiving a payment for people who did not file forms in the earlier settlements.

• A class member who does nothing remains in the settlement class.
• If the settlement becomes final, that person gives up the right to start, continue, or join another lawsuit against Dow and Huntsman and the released parties over the legal issues resolved by this settlement.
• The person is bound by the settlement’s release terms and the Court’s orders.