IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KEITH K. KRUCHTEN, ANGEL D. MURATALLA
and WILLIAM BEGANI, individually and on behalf
of all others similarly situated,
Plaintiffs,
v. Civil Action No. 2:22-cv-00678-JS
RICOH USA, INC., THE BOARD OF DIRECTORS
OF RICOH USA, INC., THE RICOH RETIREMENT
PLANS COMMITTEE and JOHN DOES 1-30,
Defendants.
CLEO BATTEN, individually and on behalf of all
others similarly situated,
Plaintiff,
v. Civil Action No. 2:25-cv-04658-JS
RICOH USA, INC., THE BOARD OF DIRECTORS
OF RICOH USA, INC., THE RICOH RETIREMENT
PLANS COMMITTEE and JOHN DOES 1-30,
Defendants.
NOTICE OF CLASS ACTION SETTLEMENT
A federal court has authorized this Notice. This is not a solicitation from a lawyer.
PLEASE READ THIS NOTICE CAREFULLY AS IT MAY AFFECT YOUR RIGHTS
This Notice of Class Action Settlement (“Notice”) is being published and made available to you because the records of the
Ricoh USA, Inc. Retirement Savings Plan, and each of its predecessor plans or successor plans, individually and collectively
(the “Plan”), indicate that you were a participant in the Plan during the period February 22, 2016, March 24, 2026 (the “Class
Period”). As such, your rights may be affected by a proposed settlement of this class action lawsuit (the “Settlement”).
Please read the following information carefully to find out what the lawsuit is about, what the terms of the proposed
Settlement are, what rights you have to object to the proposed Settlement Agreement if you disagree with its terms,
and what deadlines apply.
This Notice contains summary information with respect to the Settlement. The complete terms and conditions of the
Settlement are set forth in a Settlement Agreement (“Settlement Agreement”). Capitalized terms used in this Notice, but
not defined in this Notice, have the meanings assigned to them in the Settlement Agreement. The Settlement Agreement,
and additional information with respect to the Actions and the Settlement, is available at an Internet site dedicated to the
Settlement, www.RicohERISAsettlement.com.
The litigation involves two separate but related class actions called Kruchten, et al. v. Ricoh USA, Inc., et al., Case No.
2:22-cv-00678-JS, and Batten v. Ricoh USA, Inc., et al., Case No. 2:25-cv-04658-JS (the “Actions”). Both cases assert
ERISA claims concerning the management, operation and administration of the Plan, and are consolidated for purposes of
settlement.
QUESTIONS? VISIT WWW.RICOHERISASETTLEMENT.COM OR CALL TOLL-FREE (855) 294-0138
DO NOT CONTACT THE COURT OR RICOH WITH YOUR QUESTIONS.
The Court presiding over the Actions is the United States District Court for the Eastern District of Pennsylvania. The
Plaintiffs are Keith Kruchten, Angel Muratalla, William Begani, and Cleo Batten. The Defendants are Ricoh USA, Inc.
(“Ricoh”), the Board of Directors of Ricoh USA, Inc. (the “Board”), and the Ricoh Retirement Plans Committee (“the
Committee”).
YOUR LEGAL RIGHTS AND OPTIONS UNDER THE SETTLEMENT
YOU ARE NOT
REQUIRED TO FILE
A CLAIM IF YOU If the Settlement is approved by the Court and you are a member of the Settlement
ARE ENTITLED TO Class, you will not need to file a claim in order to receive a Settlement payment if
A PAYMENT UNDER you are entitled to receive a payment under the Settlement Agreement.
THE SETTLEMENT
AGREEMENT.
If you currently have a positive account balance in the Plan and are a Settlement Class
HOW SETTLEMENT member, any share of the Net Settlement Amount to which you are entitled will be
PAYMENTS WILL BE deposited into your Plan account. If you are a Former Participant (i.e., no longer a
DISTRIBUTED. participant in the Plan) and are a Settlement Class member, such funds, if any, shall be
paid directly to you by check.
YOU MAY OBJECT TO If you wish to object to any part of the Settlement, you may (as discussed below)
THE SETTLEMENT BY write to the Court and the attorneys for the Parties about why you object to the
SEPTEMBER 21, 2026. Settlement.
If you submit a written objection to the Settlement to the Court and counsel before
the Court-approved deadline, you may (but do not have to) attend the Fairness
YOU MAY ATTEND THE
Hearing about the Settlement and present your objections to the Court. You may
FAIRNESS HEARING TO
attend the Fairness Hearing even if you do not file a written objection, but you will
BE HELD ON OCTOBER
only be allowed to speak at the Fairness Hearing if you file a written objection by the
8, 2026.
Court-approved deadline in advance of the Fairness Hearing AND you file a Notice
of Intention To Appear, as described in the answer to Question 16 in this Notice.
• These rights and options—and the deadlines to exercise them—are explained in this Notice.
• The Court still has to decide whether to approve the Settlement. Payments will be made only if the Court approves the
Settlement and that approval is upheld in the event of any appeal.
Further information regarding this litigation and this Notice may be obtained by contacting the following Class Counsel:
Mark K. Gyandoh
Capozzi Adler. P.C.
Merion Station, PA 19066
Telephone: (610) 890-0200
Facsimile: (717) 233-4103
Class Counsel has established a toll-free phone number to receive your comments and questions: (855) 294-0138. You may
also send an email to [email protected]. In the subject line please write “Ricoh Settlement.” You should contact
Class Counsel with any questions regarding this Settlement. YOU SHOULD NOT CONTACT THE COURT, RICOH,
OR COUNSEL FOR THE DEFENDANTS. THEY WILL NOT BE ABLE TO ANSWER YOUR QUESTIONS.
QUESTIONS? VISIT WWW.RICOHERISASETTLEMENT.COM OR CALL TOLL-FREE (855) 294-0138
DO NOT CONTACT THE COURT OR RICOH WITH YOUR QUESTIONS.
2
WHAT THIS NOTICE CONTAINS
SUMMARY OF SETTLEMENT...............................................................................................................................3
BASIC INFORMATION........................................................................................................................................4
1. WHY DID I GET THIS NOTICE PACKAGE?...........................................................................................4
2. WHAT ARE THE ACTIONS ABOUT?.......................................................................................................5
3. WHY ARE THESE CASES CLASS ACTIONS?........................................................................................5
4. WHY IS THERE A SETTLEMENT?...........................................................................................................5
5. HOW DO I KNOW WHETHER I AM PART OF THE SETTLEMENT?...................................................6
THE SETTLEMENT BENEFITS—WHAT YOU MAY GET....................................................................................6
6. WHAT DOES THE SETTLEMENT PROVIDE?........................................................................................6
7. HOW MUCH WILL MY PAYMENT BE?...................................................................................................6
8. HOW MAY I RECEIVE A PAYMENT?......................................................................................................7
9. WHEN WOULD I GET MY PAYMENT?...................................................................................................7
10. CAN I GET OUT OF THE SETTLEMENT?.............................................................................................................7
THE LAWYERS REPRESENTING YOU.................................................................................................................7
11. DO I HAVE A LAWYER IN THE CASE?...................................................................................................7
12. HOW WILL THE LAWYERS BE PAID?....................................................................................................7
OBJECTING TO THE ATTORNEYS’ FEES......................................................................................................................8
13. HOW DO I TELL THE COURT IF I DO NOT LIKE THE SETTLEMENT?............................................8
THE FAIRNESS HEARING.....................................................................................................................................8
14. WHEN AND WHERE WILL THE COURT DECIDE WHETHER
TO APPROVE THE SETTLEMENT?.........................................................................................................8
15. DO I HAVE TO COME TO THE HEARING?............................................................................................8
16. MAY I SPEAK AT THE HEARING?...........................................................................................................9
IF YOU DO NOTHING.............................................................................................................................................9
17. WHAT HAPPENS IF I DO NOTHING AT ALL?.......................................................................................9
GETTING MORE INFORMATION.........................................................................................................................9
18. ARE THERE MORE DETAILS ABOUT THE SETTLEMENT?...............................................................9
SUMMARY OF SETTLEMENT
This litigation (the “Actions”) are class actions in which Plaintiffs Keith Kruchten, Angel Muratalla, William Begani, and
Cleo Batten (“Named Plaintiffs”) allege that the Defendants breached fiduciary duties owed to the participants in and ben-
eficiaries of the Plan under ERISA by mismanaging the Plan and utilizing forfeited funds in the Plan for Ricoh’s benefit,
rather than the sole interest of the Plan’s participants. Copies of the Complaints in Kruchten and Batten, as well as other
documents filed in the Actions are available at www.RicohERISAsettlement.com or from Class Counsel. Defendants have
denied and continue to deny all of the claims and allegations in the Actions and deny any liability or wrongful conduct of any
kind. Defendants believe they have administered the Plan properly, prudently, and in the best interests of Plan participants.
A Settlement Fund consisting of $1,750,000 (one million, seven hundred and fifty thousand dollars) in cash (the “Gross
Settlement Amount”) is being established in the Actions. The Gross Settlement Amount will be deposited into an escrow
account, and the Gross Settlement Amount, together with any interest earned, will constitute the Settlement Fund. Payment
of any taxes, approved attorneys’ fees and litigation expenses; payment of Case Contribution Awards to the Named Plaintiffs;
and the costs of administering the Settlement will be paid out of the Settlement Fund. After the payment of such fees,
expenses, and awards, the amount that remains will constitute the Net Settlement Amount. The Net Settlement Amount will
be allocated to Settlement Class members according to a Plan of Allocation to be approved by the Court.
QUESTIONS? VISIT WWW.RICOHERISASETTLEMENT.COM OR CALL TOLL-FREE (855) 294-0138
DO NOT CONTACT THE COURT OR RICOH WITH YOUR QUESTIONS.
3
STATEMENT OF POTENTIAL OUTCOME OF THE ACTIONS
Defendants strongly dispute each of the claims asserted in the Actions and deny that they ever engaged in any wrongdoing,
violation of law, or breach of duty. Further, Named Plaintiffs would face an uncertain outcome if the Actions were to continue.
If settlement had not been reached, Defendants would present evidence that they reasonably and prudently managed the
Plan and fulfilled all of their fiduciary obligations. As a result, continued litigation could result in a judgment in favor of
the Defendants and against the Named Plaintiffs and Settlement Class. Even if the Named Plaintiffs and Settlement Class
prevailed, they might recover a judgment less than the benefits obtained as part of the Settlement, or no recovery at all.
The Named Plaintiffs and the Defendants disagree on liability and do not agree on the amount that would be recoverable
even if the Named Plaintiffs were to prevail at trial. The Defendants deny all claims and contentions by the Named Plaintiffs.
The Defendants deny that they are liable to the Settlement Class and deny that the Settlement Class or the Plan has suffered
any damages for which the Defendants could be held legally responsible. Having considered the uncertainty, costs, and risks
inherent in any litigation, particularly in a complex case such as this, the Named Plaintiffs and Defendants have concluded
that it is desirable that the Actions be fully and finally settled on the terms and conditions set forth in the Settlement
Agreement.
STATEMENT OF ATTORNEYS’ FEES AND EXPENSES SOUGHT IN THE ACTIONS
Class Counsel will apply to the Court for an order awarding attorneys’ fees not in excess of thirty-three and one third percent
(33 1/3%) of the Settlement Amount (a maximum amount of $583,333.33), plus reimbursement of expenses not to exceed
$50,000.00. Any amount approved by the Court will be paid from the Settlement Fund.
WHAT WILL THE NAMED PLAINTIFFS GET?
The Named Plaintiffs will share in the allocation of the Net Settlement Amount on the same basis as all other members of the
Settlement Class. In addition, the Named Plaintiffs will ask the Court to award up to $5,000 to each of the Named Plaintiffs as
Case Contribution Awards for their participation in the Actions and representation of the Settlement Class. Any such awards
will be paid solely from the Settlement Fund.
BASIC INFORMATION
1. WHY DID I GET THIS NOTICE PACKAGE?
You or someone in your family may have been a participant in or a beneficiary of the Plan during the period from February
22, 2016 to March 24, 2026.
The Court directed that this Notice be published because, if you fall within the definition of the Settlement Class, you have
a right to know about the Settlement and the options available to you regarding the Settlement before the Court decides
whether to approve the Settlement. If the Court approves the Settlement, and after any objections and appeals are resolved,
the Net Settlement Amount will be distributed to the Settlement Class members according to a Court-approved Plan of
Allocation described below. This Notice describes the Actions, the Settlement, your legal rights, what benefits are available,
who is eligible for them, and how to get them.
2. WHAT ARE THE ACTIONS ABOUT?
The Actions claim that under ERISA, Defendants owed fiduciary duties of care and prudence to the Plan, and that they violated
those duties in three primary ways. First, Named Plaintiffs allege Defendants failed to prudently monitor and control the
recordkeeping fees charged to Plan participants. Recordkeeping in simple terms refers to the suite of administrative services
provided to retirement plan participants that generally includes provision of account statements to participants. Second,
Named Plaintiffs allege the Plan’s offering of the Ricoh Stable Value Fund as an investment option was unreasonable and
imprudent. Third, Named Plaintiffs allege Defendants improperly utilized “forfeitures”—forfeited employer contributions
from participants who terminated before vesting—to offset other employer contributions rather than to pay Plan expenses.
QUESTIONS? VISIT WWW.RICOHERISASETTLEMENT.COM OR CALL TOLL-FREE (855) 294-0138
DO NOT CONTACT THE COURT OR RICOH WITH YOUR QUESTIONS.
4
THE DEFENSES IN THE ACTIONS
Defendants deny all of the claims and allegations made in the Actions and deny that they ever engaged in any wrongful
conduct. If the Actions were to continue, the Defendants would raise numerous defenses to liability, including:
• Defendants did not engage in any of the allegedly improper conduct charged in the Complaint;
• Defendants reasonably and prudently managed the Plan’s fees and fulfilled all of their fiduciary obligations;
• Defendants had a thorough process for monitoring the performance of the Ricoh Stable Value Fund that more than
satisfied their fiduciary duties;
• Defendants’ use of forfeitures was reasonable and in accordance with the Plan; and
• Even if a court were to determine that Defendants failed to discharge any duty under ERISA, any such breach of
fiduciary duty did not cause the Plan or its participants to suffer any loss.
STATUS OF THE LITIGATION
Class Counsel has extensively investigated the allegations in the Actions. Among other efforts, Class Counsel reviewed
Plan-governing documents and materials, communications with Plan participants, U.S. Department of Labor filings, and
other documents regarding the general and specific matters that were alleged in the Second Amended Complaint filed in
Kruchten on December 27, 2022 and the Complaint filed in Batten on August 13, 2025. The Parties engaged in document
discovery before agreeing to attempt to resolve the case through mediation. The Parties reached a settlement on November
5, 2025.
3. WHY ARE THESE CASES CLASS ACTIONS?
In a class action, one or more plaintiffs, called “class representatives” or “named plaintiffs,” sue on behalf of people who
have similar claims. All of these people who have similar claims collectively make up the “class” and are referred to
individually as “class members.” One case resolves the issues for all class members together. Because the conduct alleged
in the Actions are claimed to have affected large groups of people – participants in the Plan during the Class Period – in
a similar way, the Named Plaintiffs filed these cases as class actions.
4. WHY IS THERE A SETTLEMENT?
As in any litigation, all parties face an uncertain outcome. On the one hand, continuation of the case against the Defendants
could result in a judgment greater than this Settlement. On the other hand, continuing the case could result in Plaintiffs
obtaining no recovery at all or obtaining a recovery that is less than the amount of the Settlement. Based on these factors,
the Named Plaintiffs and Class Counsel have concluded that the proposed Settlement is in the best interests of all Settlement
Class members.
5. HOW DO I KNOW WHETHER I AM PART OF THE SETTLEMENT?
You are a member of the Settlement Class if you fall within the definition of the Settlement Class preliminarily approved by
Judge Juan R. Sanchez:
All persons who participated in the Plan at any time during the Class Period, including any Beneficiary of a deceased
Person who participated in the Plan at any time during the Class Period, and any Alternate Payee of a Person subject
to a QDRO who participated in the Plan at any time during the Class Period. Excluded from the Settlement Class
are Defendants and their Beneficiaries.
The “class period” referred to in this definition is from February 22, 2016 to March 24, 2026. If you are a member of the
Settlement Class, the amount of money you will receive, if any, will depend upon the Plan of Allocation, described below.
QUESTIONS? VISIT WWW.RICOHERISASETTLEMENT.COM OR CALL TOLL-FREE (855) 294-0138
DO NOT CONTACT THE COURT OR RICOH WITH YOUR QUESTIONS.
5
THE SETTLEMENT BENEFITS—WHAT YOU MAY GET
6. WHAT DOES THE SETTLEMENT PROVIDE?
Provided that the Settlement becomes Final, a Settlement Fund consisting of $1,750,000.00 will be established in the
Actions. The amount of money that will be allocated among members of the Settlement Class, after the payment of any
taxes and Court-approved costs, fees, and expenses, including attorneys’ fees and expenses of Class Counsel, any Court-
approved Case Contribution Awards to be paid to the Named Plaintiffs, and payment of expenses incurred in calculating the
Settlement payments and administering the Settlement, is called the Net Settlement Amount. The Net Settlement Amount
will not be known until these other amounts are quantified and deducted. The Net Settlement Amount will be allocated to
members of the Settlement Class according to a Plan of Allocation to be approved by the Court. The Plan of Allocation
describes how Settlement payments will be distributed to Settlement Class members who receive a payment.
If the Settlement is approved by the Court, all Settlement Class members and anyone claiming through them shall be deemed
to fully release the Released Parties from Released Claims.
The Released Parties are (a) Defendants; (b) Defendants’ insurers, co-insurers, and reinsurers; (c) Ricoh’s direct and indirect past,
present, and future affiliates, parents, subsidiaries, divisions, joint ventures, predecessors, successors, successors-in-interest,
assigns, boards of trustees, boards of directors, officers, trustees, directors, partners, principals, agents, managers, members,
employees or heirs (including any individuals who serve or served in any of the foregoing capacities, such as members of the
boards of trustees or boards of directors that are associated with any of Defendants’ past, present, and future affiliates), and
each Person that controls, is controlled by, or is under common control with them; (d) the Plan and the Plan’s current and past
fiduciaries, administrators, plan administrators, recordkeepers, service providers, consultants, attorneys, agents, insurers and
parties-in-interest; and (e) Defendants’ independent contractors, representatives, attorneys, administrators, insurers, fiduciaries,
accountants, auditors, advisors, consultants, personal representatives, spouses, heirs, executors, administrators, associates,
employee benefit plan fiduciaries (with the exception of the Independent Fiduciary), employee benefit plan administrators,
service providers to the Plan (including their owners and employees), members of their immediate families, consultants,
subcontractors, and all persons acting under, by, through, or in concert with any of them. Released Claims are defined in the
Settlement Agreement and include (but are not limited to) all claims that were or could have been asserted in the Actions. This
means, for example, that Settlement Class members will not have the right to sue the Released Parties for failure to prudently
select and monitor the Plan’s investment options or fees, or related matters, that occurred during the Class Period.
The above description of the proposed Settlement is only a summary. The complete terms, including the definitions of the
Released Parties and Released Claims, are set forth in the Settlement Agreement (including its exhibits), which may be
obtained at a dedicated Settlement Internet site, www.RicohERISAsettlement.com or by contacting Class Counsel listed on
Page 2 above.
7. HOW MUCH WILL MY PAYMENT BE?
Each Settlement Class member’s share will be calculated according to a Court-approved Plan of Allocation by a third-party
vendor (“Settlement Administrator”) selected by Class Counsel. You are not required to calculate the amount you may be
entitled to receive under the Settlement as the Settlement Administrator will do so under the Plan of Allocation approved
by the Court.
You will not be required to produce records that show your Plan activity. If you are entitled to a share of the Settlement
Fund, your share of the Settlement will be determined based on the Plan’s records for your account. If you have questions
regarding the allocation of the Net Settlement Amount, please contact Class Counsel listed on Page 2 above.
8. HOW MAY I RECEIVE A PAYMENT?
You do not need to file a claim. The Final Entitlement Amount for Settlement Class members with an Active Account (an
account with a positive balance) as of the calculation of the Final Entitlement Amount (unless that Plan account is closed in
the intervening period between the calculation of the Final Entitlement Amount and the payment of the Final Entitlement
QUESTIONS? VISIT WWW.RICOHERISASETTLEMENT.COM OR CALL TOLL-FREE (855) 294-0138
DO NOT CONTACT THE COURT OR RICOH WITH YOUR QUESTIONS.
6
Amount, in which case that Class Member will receive their allocation via a check) will be paid into the Plan. Former
Participants entitled to a payment will be paid directly by the Settlement Administrator by check.
All such payments are intended by the Settlement Class to be “restorative payments” in accordance with Internal Revenue
Service Revenue Ruling 2002-45. Checks issued to Former Participants pursuant to this paragraph shall be valid for 180
days from the date of issue. If you are a former Plan participant and have not provided the Plan with your current address,
please contact Class Counsel listed on Page 2 above.
Each Class Member who receives a payment under this Settlement Agreement shall be fully and ultimately responsible for
payment of any and all federal, state, or local taxes resulting from or attributable to the payment received by such person.
9. WHEN WOULD I GET MY PAYMENT?
The Settlement cannot be completed unless and until several events occur. These events include final approval of the
Settlement by the Court, approval of the Settlement by an independent fiduciary to the Plan, transfer of the Net Settlement
Amount to the Plan, and calculation of the amount of the Settlement owed to each Settlement Class member. If objections
are made to the Settlement or appeals are taken by objectors who oppose the approval of the Settlement, this process may
take a long time to complete, possibly several years.
There will be no payments if the Settlement Agreement is terminated.
The Settlement Agreement may be terminated for several reasons, including if (1) the Court does not approve or materially
modifies the Settlement Agreement, or (2) the Court approves the Settlement Agreement but the approval is reversed or
materially modified by an appellate court. If the Settlement Agreement is terminated, the Actions will proceed again as if the
Settlement Agreement had not been entered into. The Settlement is not conditioned upon the Court’s approval of attorneys’
fees or the reimbursement of expenses/costs sought by Class Counsel, the Case Contribution Awards sought by the Named
Plaintiffs, or any appeals solely related thereto.
10. CAN I GET OUT OF THE SETTLEMENT?
You do not have the right to exclude yourself from the Settlement. The Settlement Agreement provides for certification
of the Settlement Class as a non-opt-out class action under Federal Rule of Civil Procedure 23(b)(1), and the Court has
preliminarily determined that the requirements of that rule have been satisfied. Thus, it is not possible for any Settlement Class
members to exclude themselves from the Settlement. As a Settlement Class member, you will be bound by any judgments
or orders that are entered in the Actions for all claims that were or could have been asserted in the Actions or are otherwise
released under the Settlement.
Although you cannot opt out of the Settlement, you can object to the Settlement and ask the Court not to approve it. For more
information on how to object to the Settlement, see the answer to Question 13 below.
THE LAWYERS REPRESENTING YOU
11. DO I HAVE A LAWYER IN THE CASE?
The Court has preliminarily appointed the law firm of Capozzi Adler, P.C. as Class Counsel for the Named Plaintiffs in the
Actions. You will not be charged directly by these lawyers. If you want to be represented by your own lawyer, you may hire
one at your own expense.
12. HOW WILL THE LAWYERS BE PAID?
Class Counsel will file a motion for the award of attorneys’ fees of not more than one third (33 1/3%) of the Settlement
Amount, plus reimbursement of expenses incurred in connection with the prosecution of the Actions. This motion will be
considered at the Fairness Hearing described below.
QUESTIONS? VISIT WWW.RICOHERISASETTLEMENT.COM OR CALL TOLL-FREE (855) 294-0138
DO NOT CONTACT THE COURT OR RICOH WITH YOUR QUESTIONS.
7
OBJECTING TO THE ATTORNEYS’ FEES
By following the procedures described in the answer to Question 13, you can tell the Court that you do not agree with the
fees and expenses the attorneys intend to seek and ask the Court to deny their motion or limit the award.
13. HOW DO I TELL THE COURT IF I DO NOT LIKE THE SETTLEMENT?
If you are a Settlement Class Member, you can object to the Settlement if you do not like any part of it. You can give reasons
why you think the Court should not approve it. To object, you must send a letter or other writing saying that you object to
the Settlement in Kruchten, et al. v. Ricoh USA Inc., et al., No. 2:22-cv-00678-JS. Be sure to include your name, address,
telephone number, signature, and a full explanation of all the reasons why you object to the Settlement. You must file your
objection with the Clerk of the Court of the United States District Court for the Eastern District of Pennsylvania so that it
is received no later than September 21, 2026. The address is:
Clerk of the Court
United States District Court for the Eastern District of Pennsylvania
James A. Byrne U.S. Courthouse
601 Market Street #2609
Philadelphia, PA 19106
The objection must refer prominently to this case name: Kruchten, et al. v. Ricoh USA Inc., et al., No. 2:22-cv-00678-JS.
A copy of your objection must also be provided to Class Counsel and Defense Counsel by email to settlement@Capozziadler.
com (writing “Ricoh Settlement” in the subject line) or write to the following respective addresses for Class and Defense
Counsel:
Class Counsel Defense Counsel
Mark K. Gyandoh Jeremy P. Blumenfeld
Capozzi Adler, P.C. Morgan, Lewis & Bockius LLP
312 Old Lancaster Rd 2222 Market Street
Merion Station, PA 19066 Philadelphia, PA 19103
THE FAIRNESS HEARING
The Court will hold a Fairness Hearing to decide whether to approve the Settlement as fair, reasonable, and adequate. You
may participate in the Fairness Hearing, which may be held telephonically or by video conference, and you may ask
to speak if you have timely asserted an objection, but you do not have to participate in the Fairness Hearing to have your
objection considered. It is your obligation to ensure that your written objection is received by the Court by no later
than September 21, 2026.
14. WHEN AND WHERE WILL THE COURT DECIDE WHETHER TO APPROVE THE SETTLEMENT?
The Fairness Hearing currently is scheduled for 9:30 a.m. on October 8, 2026, at the United States District Court for the
Eastern District of Pennsylvania, Courtroom 14-B, or such other courtroom as the Court may designate. The Court may
adjourn the Fairness Hearing without further notice to the Settlement Class and also may schedule the hearing to be
done by telephone or video conference. If you wish to attend, you should confirm the date and time of the Fairness
Hearing with Class Counsel before doing so. At that hearing, the Court will consider whether the Settlement is fair,
reasonable, and adequate. If there are objections, the Court will consider them. The Court will also rule on the motions for
attorneys’ fees and reimbursement of expenses and for Case Contribution Awards for the Named Plaintiffs. The Parties do
not know how long these decisions will take or whether appeals will be filed.
15. DO I HAVE TO COME TO THE HEARING?
No, but you are welcome to come at your own expense. If you file an objection, you do not have to come to Court to talk
about it. As long as you mailed your written objection on time, it will be before the Court when the Court considers whether
QUESTIONS? VISIT WWW.RICOHERISASETTLEMENT.COM OR CALL TOLL-FREE (855) 294-0138
DO NOT CONTACT THE COURT OR RICOH WITH YOUR QUESTIONS.
8
to approve the Settlement. You also may pay your own lawyer to attend the Fairness Hearing, but such attendance is also
not necessary.
16. MAY I SPEAK AT THE HEARING?
If you submit a written objection to the Settlement to the Court and counsel before the Court-approved deadline,
you may (but do not have to) attend the Fairness Hearing and present your objections to the Court. You may
attend the Fairness Hearing even if you do not file a written objection, but you will only be allowed to speak at
the Fairness Hearing if you file a written objection in advance of the Fairness Hearing AND you file a Notice
of Intention To Appear, as described in this paragraph. To do so, you must file with the Court a letter or other
paper called a “Notice of Intention to Appear at Fairness Hearing in Kruchten, et al. v. Ricoh USA Inc., et al., No.
2:22-cv-00678-JS.” Be sure to include your name, address, telephone number, and your signature. Your Notice
of Intention To Appear must be received by the attorneys listed in the answer to Question 13 above, no later than
September 21, 2026, and must be filed with the Clerk of the Court at the address listed in the answer to Question 13.
IF YOU DO NOTHING
17. WHAT HAPPENS IF I DO NOTHING AT ALL?
If you do nothing and you are a Settlement Class member, you will participate in the Settlement of the Actions as described
above in this Notice.
GETTING MORE INFORMATION
18. ARE THERE MORE DETAILS ABOUT THE SETTLEMENT?
Yes. This Notice summarizes the proposed Settlement. The complete terms are set forth in the Settlement Agreement. You
may obtain a copy of the Settlement Agreement by making a written request to Class Counsel listed on Page 2 above.
Copies may also be obtained at a dedicated Settlement website, www.RicohERISAsettlement.com, by calling the toll-free
number, (855) 294-0138, or by sending an email to [email protected]. In the subject line please write “Ricoh
Settlement.” You are encouraged to read the complete Settlement Agreement.
DO NOT CONTACT THE COURT, THE CLERK’S OFFICE, RICOH, OR COUNSEL FOR RICOH REGARDING
THIS NOTICE. THEY WILL NOT BE ABLE TO ANSWER YOUR QUESTIONS. INSTEAD CONTACT CLASS
COUNSEL, THE SETTLEMENT ADMINISTRATOR TOLL-FREE AT (855) 294-0138, OR VISIT THE WEBSITE
AT WWW.RICOHERISASETTLEMENT.COM.
QUESTIONS? VISIT WWW.RICOHERISASETTLEMENT.COM OR CALL TOLL-FREE (855) 294-0138
DO NOT CONTACT THE COURT OR RICOH WITH YOUR QUESTIONS.
9
