United States District Court for the Eastern District of Pennsylvania
Lorisa Pineda v. Lake Consumer Products, Inc., Case No. 5:2024-cv-01074-CH
If You Purchased MG217® Coal Tar Shampoo Products,
You May Be Eligible for a Cash Refund and/or a Product
Voucher From a Class Action Settlement
A federal court authorized this notice. This is not a solicitation from a lawyer.
• A Proposed Settlement has been reached in a class action lawsuit. Purchasers of
MG217® coal tar shampoo products, such as MG217® Psoriasis Extra Strength,
MG217® Psoriasis Medicated Conditioning 3% Coal Tar Shampoo, and MG217®
Dandruff Therapeutic Shampoo (the “Products”), sued the manufacturer, Lake Consumer
Products, Inc. (“Lake”), generally alleging that Lake did not properly manufacture these
products in accordance with current Good Manufacturing Practices (“cGMPs”) and
industry practice as to the levels of benzene present in the Products. Lake denies
Plaintiff’s claims and denies any fault or wrongdoing. The Court has not decided whether
Lake did anything wrong. The parties agreed to the Proposed Settlement to resolve the
lawsuit to avoid the expenses and uncertainties of continuing the lawsuit.
• You are eligible to participate in the Proposed Settlement if you purchased any
formulation of the Products in the United States from January 1, 2021 until June 25,
2026:
Please read this Notice carefully and in its entirety.
Your rights may be affected by the Proposed Settlement of this Lawsuit,
and you have a choice to make now about how to act:
YOUR LEGAL RIGHTS AND OPTIONS
A Settlement has been reached in a class action lawsuit. The
lawsuit involves Lake. Plaintiff generally alleges that Lake did
not properly manufacture the Products in accordance with current
Good Manufacturing Practices (“cGMPs”) and industry practice
WHAT IS THIS? as to the levels of benzene present in the Products. Lake denies
Plaintiff’s claims and denies any fault or wrongdoing. The Court
has not decided whether Lake did anything wrong. The parties
agreed to the Proposed Settlement to resolve the lawsuit in order
to avoid the expenses and uncertainties of continuing the lawsuit.
Questions? Visit www.MG217ShampooSettlement.com or Contact the Settlement Administrator
Toll Free at 1-888-722-7084
-1-
YOUR LEGAL RIGHTS AND OPTIONS
This is the only way to receive a monetary payment or
voucher from the Proposed Settlement. By remaining in the
SUBMIT A CLAIM FORM Proposed Settlement, whether or not you submit a claim, you will
POSTMARKED BY give up any rights to sue Lake separately about the legal claims
SEPTEMBER 24, 2026 in this lawsuit. Claim Forms are available at
www.MG217ShampooSettlement.com. For more detail about the
claim process, please see questions 5, 6 and 7 below.
If you opt out of the Proposed Settlement, you will not be eligible
to receive the monetary payment or voucher, but you will keep
your right to sue Lake about the same legal claims in this lawsuit.
EXCLUDE YOURSELF
Requests for exclusion must be postmarked by September 24,
FROM THE CLASS BY
2026, and mailed to Lake Consumer Products Settlement, 1060
SEPTEMBER 24, 2026
Broadway, Suite 308, Albany, NY 12204. For more detail about
excluding yourself from the Class, please see questions 9 and 11
below.
You may write to the Court about why you do, or do not, like the
Proposed Settlement. You must remain in the class to comment
OBJECT OR COMMENT in support of or in opposition to the Settlement. Objections and
BY SEPTEMBER 24, 2026 comments must be filed with the Court and served on the Parties
by September 24, 2026. For more detail about objecting or
commenting, please see questions 10 and 11 below.
You may ask to speak in Court about the fairness of the Proposed
Settlement. Written notice of your intent to appear in the Lawsuit
APPEAR IN THE LAWSUIT must be filed with the Court and served on the Parties by
OR ATTEND A HEARING September 24, 2026. You may enter your appearance in Court
ON OCTOBER 15, 2026 through an attorney at your own expense if you so desire. For
more detail about appearing in this lawsuit or attending the final
hearing, please see questions 10, 14, 15 and 16 below.
By doing nothing, you will not receive a monetary payment. You
DO NOTHING will also give up any rights to sue Lake separately about the legal
claims in this lawsuit.
• Your rights and options – and the deadlines to exercise them – are further explained in
this notice.
• The Court in charge of this case still has to decide whether to approve the Proposed
Settlement. The Settlement Benefit (i.e., the monetary payments and vouchers described
herein) will be made available if the Court approves the Settlement, and after any appeals
are resolved, if they are resolved in favor of settlement approval.
• If you have any questions, please read on and/or visit
Questions? Visit www.MG217ShampooSettlement.com or Contact the Settlement Administrator
Toll Free at 1-888-722-7084
-2-
www.MG217ShampooSettlement.com.
BASIC INFORMATION
1. Why did I get this notice?
If you purchased any of the Products, as described on page 1 of this Notice, you have a right to
know about the proposed Settlement of a class action lawsuit and your options. If you have
received word of this Notice in the mail or by e-mail, you have been identified from available
records as a possible purchaser of the Products at issue in the lawsuit. You also may have
received this Notice because you requested more information after reading the Settlement
Website. If the Court approves it, and if objections and all appeals are resolved in favor of
settlement approval, an administrator approved by the Court will oversee the distribution of the
Settlement Benefits that the Proposed Settlement allows. You will be informed of the progress
of the Proposed Settlement on the settlement website.
This Notice explains the lawsuit, the Proposed Settlement, your legal rights, what benefits are
available, who is eligible for them, and how to get them. Judge Henry of the United States
District Court for the Eastern District of Pennsylvania is overseeing the lawsuit, which is known
as Lorisa Pineda v. Lake Consumer Products, Inc., Case No. 5:2024-cv-01074-CH. The persons
who sued are called the Plaintiff, and the company they sued, Lake, is called the Defendant. The
Proposed Settlement resolves the pending action styled Lorisa Pineda v. Lake Consumer
Products, Inc., Case No. 5:2024-cv-01074-CH (the “Action”).
2. What is this lawsuit about?
In this lawsuit, the Plaintiff claims that Lake failed to manufacture these products in accordance
with current Good Manufacturing Practices (“cGMPs”) and industry practice. Lake denies
Plaintiff’s claims, denies any wrongdoing, and asserts that the Products are safe and conform
with all state and federal regulations. The Court has not determined which side is right. Rather,
the Parties have agreed to settle the lawsuit to avoid the expenses and uncertainties associated
with ongoing litigation.
3. What is a class action and who is involved?
In a class action lawsuit, one or more people called “Class Representatives” sue on behalf of
other people who have similar claims. The people together are a “Class” or “Class Members.”
The named plaintiffs who sued – and all the Class Members like them – are called the Plaintiffs.
The company they sued (in this case, Lake) is called the Defendant. One court resolves the
issues for everyone in the Class – except for those people who choose to exclude themselves
from the Class.
4. Am I part of this Class?
You are part of the class if you purchased any variety of the Products in the United States from
January 1, 2021, until June 25, 2026.
Questions? Visit www.MG217ShampooSettlement.com or Contact the Settlement Administrator
Toll Free at 1-888-722-7084
-3-
THE SETTLEMENT BENEFITS
5. What does the Settlement provide?
Lake has agreed to provide $1,200,000 in settlement benefits in the form of a non-reversionary
Cash Settlement Fund in the amount of $700,000 and a non-reversionary Non-Monetary Fund
in the amount of $500,000 in vouchers.
If the Settlement is approved and becomes final, it will provide the following benefits to Class
Members. If you submit a timely and valid Claim Form, you will receive a Cash Benefit or
Voucher, depending on which benefit you select.
Cash Benefit. Settlement Class Members who submit a valid and timely Claim Form will be
entitled to a cash payment (the “Cash Benefit”) equal to the amount of the purchase price for
each qualifying purchase accompanied by a Proof of Purchase, subject to a pro rata increase or
decrease based on the number of Claims received that were accompanied by Proofs of Purchase.
An Authorized Claimant may receive a Cash Benefit up to $7.00 for each qualifying purchase
not accompanied by a Proof of Purchase, subject to a pro rata increase or decrease based on the
number of qualifying purchases claimed without Proof of Purchase. The Settlement
Administrator will calculate and implement the pro rata increases or decreases described in this
Section to ensure the Net Cash Settlement Fund is paid fully to Authorized Claimants. At the
discretion of Class Counsel, the Settlement Administrator may implement a cap on the total
amount of Cash Benefits an Authorized Claimant may receive for each qualifying purchase not
accompanied by a Proof of Purchase.
The actual amount of these cash benefits, however, is currently unknown because the amount
depends in large part on the number of Settlement Class Members who submit timely and valid
Claim Forms. The exact amount of Settlement Class Members’ Cash Benefits cannot be
determined until the notice process is complete and the Court makes a final decision on the
amount of attorneys’ fees (i.e., the amount of compensation for legal services provided by the
Class Counsel), reimbursable costs and expenses awarded to Class Counsel (i.e., the costs and
expenses incurred to litigate the case that Class Counsel may be reimbursed for), settlement
administration costs (i.e., the amount paid to the third-party Settlement Administrator for
administering the Settlement) and any Service Payment to the Class Representative (i.e., funds
that may be awarded to the Class Representative to compensate for their participation in the
Action), and until the Settlement Administrator has received and validated the total number of
claims.
Voucher. Settlement Class Members who submit a valid and timely Claim Form may elect to
receive a Voucher. Vouchers are redeemable after the purchase of any of the MG217® Product
Line via the code that will be provided by the Settlement Administrator along with a proof of
purchase. Vouchers do not expire and may be applied in addition to other discount codes,
promotions, or gift cards. Vouchers are transferrable and are not required to be used in a single
transaction. An Authorized Claimant may elect in a Claim Form to receive both a Cash Benefit
and a Voucher provided they submit Proof of Purchase.
One Voucher in the amount of a $25.00 credit will be allocated to each Authorized Claimant
Questions? Visit www.MG217ShampooSettlement.com or Contact the Settlement Administrator
Toll Free at 1-888-722-7084
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who elects to receive Voucher, up to a maximum distribution of Vouchers equal to the value of
the Non-Monetary Fund. If the total value of Vouchers elected exceeds the Non-Monetary Fund
after a first distribution, each Voucher’s value will be reduced on a pro rata basis so that the
total does not exceed the Non-Monetary Fund. If the total value of Vouchers elected does not
exceed the Non-Monetary Fund after a first distribution, an additional distribution will be made
of one Voucher to each Authorized Claimant whether they elected a Cash Benefit, Voucher, or
both. Subsequent one Voucher distributions will be made the same way until the Non-Monetary
Fund is exhausted, provided no individual Authorized Claimant receives more than $50.00 in
Vouchers. If any Vouchers remain after all possible distributions, those Vouchers will be
distributed to the cy pres recipient identified in Section 3.8.
Injunctive Relief. Lake has agreed to not manufacture, market, distribute, or sell any of the
Products unless the amount of coal tar in the finished product is no more than 0.5% by weight.
The Parties have further agreed that Lake will pay the costs to administer this Proposed
Settlement, reasonable attorneys’ fees, costs and expenses, and a payment to the named Plaintiff
(see questions 13 and 15 below) out of the Settlement Fund. A detailed description of the
settlement benefits can also be found in the Settlement Agreement here
www.MG217ShampooSettlement.com.
6. When will I get my monetary payment?
The hearing to consider the fairness of the Settlement is scheduled for October 15, 2026. If the
Court approves the Settlement, then eligible Class Members whose claims were approved by
the Claims Administrator will receive their payment within the time specified in the Settlement
has been finally approved and/or after any appeals process is complete. Class members may
choose to receive payments electronically (e.g., PayPal, Venmo, InstaPay, etc.), or will receive
payments by paper check or prepaid debit card.
HOW TO GET THE SETTLEMENT BENEFITS
7. How do I get my monetary payment or voucher?
If you are a Class Member and want to receive a payment under the Settlement, you must
complete and submit a Claim Form no later than September 24, 2026. Claims Forms can be
found and submitted on-line, or they can be mailed and postmarked by September 24, 2026.
You may have received a link to the Claim Form via e-mail, or in the mail as a postcard notice
of the Settlement. To submit a Claim Form on-line or to request a paper copy, go to
www.MG217ShampooSettlement.com or call toll free, 1-888-722-7084.
To be considered valid, the Claim Form must contain the Settlement Class member’s name,
mailing address, attestation of purchase(s) of Products showing the number of Products
purchased during the Class period, and must be signed by the Settlement Class Member under
penalty of perjury.
Questions? Visit www.MG217ShampooSettlement.com or Contact the Settlement Administrator
Toll Free at 1-888-722-7084
-5-
YOUR RIGHTS AND OPTIONS
8. What happens if I do nothing at all?
If you do nothing, then you will remain in the Class and not receive any payment from this
Settlement. If the Court approves the Settlement, you will be bound by its terms, you will no
longer have the ability to sue Lake with respect to the claims being resolved by the Settlement,
and your claims will be released and dismissed.
The Settlement Agreement describes the released claims in more detail, so please read it
carefully. If you have any questions, you can contact the lawyers listed in question 10 for free
to discuss, or you can talk to another lawyer of your own choosing if you have questions about
what this means.
9. How do I exclude myself from the Settlement?
If you exclude yourself from the Settlement – which is sometimes called “opting out” – you
won’t get any money or benefits from the Settlement. However, you may then be able to
separately sue or continue to sue Lake for the legal claims that are the subject of the lawsuit. If
you bring your own lawsuit against Lake after you exclude yourself, you will have to hire your
own lawyer for that lawsuit, and you will have to prove your claims.
To exclude yourself from the Settlement, you must submit an electronic or written request for
exclusion to the Claims Administrator, stating that you “want to be excluded from the Settlement
in Lorisa Pineda v. Lake Consumer Products, Inc., Eastern District of Pennsylvania, Case No.
5:2024-cv-01074-CH.” Your request for exclusion must also include your name, current
address, and telephone number. And the request must be signed/e-signed and dated by you. If
submitted in hard copy, your request for exclusion must be mailed and postmarked on or before
September 24, 2026 to:
Lake Consumer Products Settlement
1060 Broadway
Suite 308
Albany, NY 12204
10. How do I object to the Settlement?
If you are a Class Member, you can object to the Settlement if you don’t like any part of it. You
can give reasons why you think the Court should not approve the Settlement. The Court will
consider your views. To object, you must submit a written objection by U.S. Mail to the
Settlement Administrator entitled “Objection to Class Settlement in Lorisa Pineda v. Lake
Consumer Products, Inc., Eastern District of Pennsylvania, Case No. 5:2024-cv-01074-CH”
that identifies all the reasons for your objections and any legal and factual support for those
reasons. Your written objection must also include your name, address, telephone number, and
email address if available, and it must state information showing that you are a Class Member
(i.e. Proof of Purchase or a verification under penalty of perjury as to the date and location of
your purchase(s)). It must also state if you are represented by legal counsel, and, if so, provide
contact information for your lawyer, including his or her email address if available. The
Questions? Visit www.MG217ShampooSettlement.com or Contact the Settlement Administrator
Toll Free at 1-888-722-7084
-6-
objection must be signed by you or your authorized representative.
If you intend to appear and speak at the Final Approval Hearing to object to the Settlement, with
or without a lawyer (explained below in questions 14, 15 and 16), you must also state your
intention to appear in your written objection.
You must file your written objection with the Court and mail a copy to the following persons
and places, postmarked no later than September 24, 2026.
Court Class Counsel Lake’s Counsel
The Honorable Catherine Ruben Honik Jordan Factor
Henry David J. Stanoch Vandana Koelsch
United States District Court Honik LLC Michael Best & Friedrich LLP
for the Eastern District of 1515 Market St., Suite 675 15th Street, Suite 2000
1100
Pennsylvania Denver, CO 80202
Philadelphia, PA 19102
602 Market Street [email protected] [email protected]
Philadelphia, PA [email protected] [email protected]
om
Conlee S. Whiteley Eric C. Milby
Kanner & Whiteley LLC Zachary Silverstein
701 Camp Street Lundy Beldecos & Milby PC
New Orleans, LA 70130 450 N. Narberth Ave
c.whiteley@kanner- Narberth, PA 19072-1898
law.com [email protected]
[email protected]
11. What is the difference between objecting and excluding myself from the
Settlement?
Objecting means telling the Court that you don’t like something about the Settlement. You can
object only if you stay in the Class. Excluding yourself from the Settlement means that you do
not want to be part of the Class. If you exclude yourself, then you have no basis to object to the
Settlement because the case no longer affects you.
THE LAWYERS REPRESENTING YOU
12. Do I have a lawyer in this case?
The Court appointed the law firms of Honik LLC and Kanner & Whiteley LLC to represent the
Plaintiff and all Class Members as “Class Counsel.” Class Counsel believe, after conducting an
extensive investigation, that the Settlement is fair, reasonable, and in the best interests of the
Class Members. You will not be charged for these lawyers. If you want to be represented by a
different lawyer in this case, you may hire one at your own expense.
Questions? Visit www.MG217ShampooSettlement.com or Contact the Settlement Administrator
Toll Free at 1-888-722-7084
-7-
13. How will the lawyers be paid?
A portion of the Cash Settlement Fund will be used to pay Class Counsel’s attorneys’ fees and
costs, in an amount subject to approval by the Court. The Parties have not agreed to any
particular amount of Plaintiff’s Counsel’s Fees, but Plaintiff’s Counsel do not currently intend
to seek an amount of attorneys’ fees exceeding one-third of the net value created for the Class
between the Cash Settlement Fund and Non-Monetary Fund. Any attorney’s fees and costs
approved by the Court will be paid from the Cash Settlement Fund.
THE CLASS REPRESENTATIVES REPRESENTING YOU
14. Who is the class representative?
The Class Representative that has been appointed by the Court to represent the Class is Plaintiff
Lorisa Pineda.
15. Will the class representatives be paid?
As part of this Settlement and subject to approval by the Court, the Class Representative will
apply for an award not to exceed $10,000 to compensate them for their services as the
representative of the Settlement Class. Any service amount awarded by the Court to the Class
Representative will be paid from the Cash Settlement Fund. The award will be in addition to
any other benefit to which the Class Representatives will be entitled as a Settlement Class
Member.
THE COURT’S FINAL APPROVAL HEARING FOR THE SETTLEMENT
16. Where and when will the Court decide whether to approve the Settlement?
The Court will hold the Final Approval Hearing at 11:00 a.m. on October 15, 2026 in U.S. District
Court, 101 Larry Holmes Dr. #400, Easton, PA 18042 . The purpose of the hearing will be for the Court
to determine whether to approve the Settlement as fair, reasonable, adequate, and in the best
interests of the Class; to consider Class Counsel’s request for attorneys’ fees, costs and
expenses. At that hearing, the Court will be available to hear any objections and arguments
concerning the fairness of the Settlement.
The hearing may be postponed to a different date or time without notice, so please check
www.MG217ShampooSettlement.com or call 1-888-722-7084 from time to time. If, however,
you timely objected to the Settlement and advised the Court that you intend to appear and speak
at the Final Approval Hearing, you will receive notice of any change in the time and date of
such hearing.
17. Do I have to come to the Final Approval Hearing?
No. You do not need to attend the Final Approval Hearing. Class Counsel will answer any
Questions? Visit www.MG217ShampooSettlement.com or Contact the Settlement Administrator
Toll Free at 1-888-722-7084
-8-
questions the Court may have on behalf of the Class Members. But, you are welcome to attend
the Final Approval Hearing at your own expense. If you submit an objection or comment, you
do not have to come to Court to talk about it. As long as you filed and mailed your written
objection on time, the Court will consider it. You may also pay to have another lawyer attend
on your behalf, but that is not required.
18. May I speak at the Final Approval Hearing?
Yes. You may ask the Court for permission to speak at the Final Approval Hearing. To do so,
you must include in your written objection to the Settlement a statement saying that it is your
intent to appear at the Final Approval Hearing in Lorisa Pineda v. Lake Consumer Products,
Inc., Eastern District of Pennsylvania, Case No. 5:2024-cv-01074-CH. Your written objection
and notice of intent to appear must be postmarked no later than September 24, 2026, and sent to
the addresses listed in question 10.
GETTING MORE INFORMATION
19. Are more details available?
This Notice summarizes the Settlement. More details are in the Settlement Agreement, which
can be found at www.MG217ShampooSettlement.com. You may also write with questions to
Lake Consumer Products Settlement, 1060 Broadway, Suite 308, Albany, NY 12204. You can
also call the Claims Administrator at 1-888-722-7084 or Class Counsel at 267-435-1300 (Toll
Free), if you have questions.
Questions? Visit www.MG217ShampooSettlement.com or Contact the Settlement Administrator
Toll Free at 1-888-722-7084
-9-
