UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY
Consumer Economic Loss Class Action Settlement Notice – Aurobindo Settlement
If you are an individual who paid any amount of money for retail purchases of
irbesartan medication manufactured by Aurobindo from January 1, 2016 to the
present, you could receive a payment from a class action settlement.
A Federal Court authorized this notice. This is not a solicitation from a lawyer.
• A Settlement has been reached in an economic loss class action lawsuit against Aurobindo
Pharma Ltd., Aurobindo Pharma USA, Inc., and Aurolife Pharma LLC (collectively, the “Aurobindo
Defendants”). The settlement is part of a larger lawsuit called In re: Valsartan, Losartan, and
Irbesartan Products Liability Litigation, Case No. 1:19-md-02875 (MDL No. 2875) (the “Lawsuit”)
and is currently pending in the United States District Court for the District of New Jersey (“the
Court”). This notice informs you of your legal rights and options.
• The Settlement resolves claims that Aurobindo Defendants violated state laws related to the
manufacture, supply, distribution, marketing, and sale of finished dose using Aurobindo
irbesartan API that was manufactured using Aurobindo’s IC Route of Synthesis allegedly
containing nitrosamine impurities, causing economic losses to the class.
• The Aurobindo Defendants have denied any wrongdoing, have denied that the amounts of
NDEA in the Irbesartan and ICDs at issue were or could be carcinogenic, and have asserted
various legal and factual defenses to the claims asserted on behalf of the Class.
• The Court has not decided whether the Aurobindo Defendants did anything wrong or whether
the Plaintiffs’ claims have merit. This Settlement of irbesartan economic loss claims does not
include or affect any other claims against the Aurobindo Defendants or any other entity,
including but not limited to medical monitoring and personal injury claims, nor does it include
any claims related to Losartan or Valsartan.
• Your legal rights are affected regardless of whether you act or do not act. Please read this Notice
carefully.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT DEADLINE
To receive a Settlement payment, you must submit a Claim
Form. You can submit your Claim online at the Settlement
website www.SartanMedicationSettlement.com or
download a paper Claim Form and submit it by mail.
SUBMIT A CLAIM JUNE 2, 2026
Documentation should be submitted to support your claim,
if possible. After you submit your claim, the Settlement
Notice Administrator may contact you for proof of purchase
from your pharmacy, if needed to approve your claim.
If you do nothing, you will remain a part of the Class and
Settlement. You will receive no payment under the
DO NOTHING NO DEADLINE
Settlement and you will give up your rights to sue the
Aurobindo Defendants about the issues in this case.
21695137.1
Excluding yourself from the Settlement is the only option
that allows you to pursue your own claims against one or
more Aurobindo Defendants for the legal claims made in the
EXCLUDE YOURSELF
Lawsuit. Choosing this option means you will not be bound
FROM THE SETTLEMENT JUNE 2, 2026
by any future determination made in the Settlement;
however, you will also not be eligible for a payment, if any
are awarded. See question 12 for more information.
If you do not like any part of the Settlement, you may write
to the Court and explain your objection. You can not submit
both an exclusion request and objection. You must remain a
part of the Class to object. The Court will consider your
OBJECT TO THE objection at the Final Approval Hearing. If the Court grants
JUNE 2, 2026
SETTLEMENT Final Approval over your objection, you will give up your
rights to sue the Aurobindo Defendants about the issues in
this case. If you also wish to receive payment from the
Settlement, you must submit a Claim Form. See Question 15
for more information.
• These rights and options – and the deadlines to exercise them – are explained in this Notice.
BASIC INFORMATION
1. What is this Notice about?
A federal court directed that this Notice be provided to you because you have a right to know about this
class action Settlement and about all of your rights and options. The Court also authorized and required
the manner by which you received this Notice, and specifically required notice to be provided by email or
text message, where available, or U.S. mail in certain limited circumstances. This Notice explains the
Lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for them, and how
to get them.
The Court presiding over this case is the United States District Court for the District of New Jersey (“the
Court”). The Court is overseeing the class actions in the Lawsuit as part of a Multi-District Litigation
(“MDL”) called In re: Valsartan, Losartan, and Irbesartan Products Liability Litigation, Case No. 1:19-md-
02875-RBK-SAK. The people and entities that filed the Lawsuit are called the “Plaintiffs” and the
companies they sued are called the “Defendants.” The settled part of the Lawsuit relates only to the
Aurobindo Defendants’ sale of irbesartan between January 1, 2016 and the present, and does not involve
Losartan or Valsartan.
2. What is the Settlement about?
The Settlement addresses claims that the Aurobindo Defendants violated state laws by manufacturing,
distributing, selling and/or dispensing irbesartan or ICDs that were contaminated with probable human
carcinogens in the form of NDEA. Aurobindo Defendants deny all allegations of fault, wrongdoing, or
liability made in the Lawsuit, have denied that the amounts of NDEA in the Irbesartan and ICDs at issue
were or could be carcinogenic, and have asserted various legal and factual defenses.
Questions? Call 1-866-875-9644 or visit www.SartanMedicationSettlement.com
Page 2 of 9
21695137.1
3. What is a class action?
In a class action, one or more individuals sue on behalf of other people with similar claims. These
individuals are known as “Class Representatives” or “Plaintiffs.” Together, the people included in the class
action are called a “class” or “class members.” One court resolves a class action lawsuit for all class
members, except for those who opt out of the class and litigation. The Plaintiffs and the Defendants are
the Parties (the “Parties”) in the Litigation.
In this Settlement, which resolves one part of the overall Lawsuit, the Class Representatives are Jacqueline
Harris (“Consumer Plaintiff”) and MSP Recovery Claims, Series LLC (“MSPRC”) (“TPP Plaintiff”). In this
Settlement, the Aurobindo Defendants are Aurobindo Pharma Ltd., Aurobindo Pharma USA, Inc., and
Aurolife Pharma LLC (defined herein to include their predecessors, successors, subsidiaries and affiliates
and each of their past, present and future direct or indirect parent companies, subsidiaries, divisions and
affiliates, joint ventures, and each of their present and former officers, directors, employees,
stockholders, partners, owners, and insurers).
WHO IS INCLUDED IN THE LAWSUIT?
4. Who is included in the Settlement Class?
You are a member of the consumer Settlement Class if you are an individual in the United States and its
territories and possessions who, from January 1, 2016 to the present, paid any amount of money for retail
purchases of irbesartan finished drug formulations manufactured using Aurobindo irbesartan API that was
manufactured using Aurobindo’s IC Route of Synthesis (“IC ROS Irbesartan”).
5. Are there exceptions to being a Class Member?
Yes. Excluded from the Settlement Class are: (a) Any judge or magistrate presiding over this action, and
the members of their families; (b) The Aurobindo Defendants and affiliated entities and their officers and
directors; (c) The Aurobindo Defendants’ counsel of record, assigns and successors; (d) All federal and
state governmental entities except for cities, towns, municipalities, or counties with self-funded
prescription drug plans; (e) Pharmacy Benefit Managers (“PBMs”); (f) Plaintiffs’ counsel of record, assigns,
and successors; (g) Any personal injury plaintiff or claimant in the MDL; and, (h) All persons or entities
who properly execute and file a timely request for exclusion from any Court-approved class.
6. How can I get help in determining if I am eligible?
If you need help in determining your eligibility, you can visit the Settlement Website at
www.SartanMedicationSettlement.com and answer a few simple questions. You can also call 1-866-875-
9644 or email [email protected] for more information.
WHAT DOES THE SETTLEMENT PROVIDE?
7. What does the Settlement provide?
In consideration of the full and complete Release of all Released Claims against the Released Parties, and
the dismissal of the Action with prejudice, the Aurobindo Defendants agree to pay $2,000,000.
Questions? Call 1-866-875-9644 or visit www.SartanMedicationSettlement.com
Page 3 of 9
21695137.1
The net Aurobindo Economic Loss Class Settlement fund (“the Fund”), after deduction of Attorneys’ Fees
and Expenses, Class Notice and administration expenses, and Service Awards, shall be administered and
allocated between the consumers and Third-Party Payors in a method to be determined by their
respective Class Counsel subject to review by the Hon. Joel Schneider U.S.M.J (ret.). The allocation
method will be set forth in Plaintiffs’ Motion for Preliminary Approval and filed with the Court prior to the
hearing.
8. How do I get a payment?
Consumer members of the Settlement Class shall submit Claim Forms documenting their purchases of
Aurobindo IC ROS Irbesartan as provided in the Settlement Agreement and approved by the Court. The
Settlement Notice Administrator will review the Claim Forms and any supporting documentation with
particular attention to the possibility of fraudulent or mistaken claims.
Documentation should be submitted to support your claim, if possible. Your claim will be reviewed by the
Settlement Notice Administrator to determine if sufficient information is provided to accept your claim or
if additional documentation, such as proof of purchase from your pharmacy, is required. You may, if you
so choose, provide documentation with your claim submission to prevent any possible delays in approving
your claim.
If you are an eligible Settlement Class Member, you must submit a Claim Form to receive a Settlement
payment. You can submit your Claim online at the Settlement website
www.SartanMedicationSettlement.com or download a paper Claim Form and submit it by mail. You may
be required to submit supporting documentation. Your Claim Form must be submitted online or
postmarked by June 2, 2026.
9. When will I get my payment?
The Court will consider the fairness of the Settlement at the Final Approval Hearing scheduled for June
30, 2026. If the Court grants Final Approval, following the effective date described in the Settlement
Agreement and any timeline defined in the Court’s Final Approval Order, the Settlement Notice
Administrator will distribute payments. Please be patient, as this process can take some time.
ADDITIONAL RIGHTS AND OPTIONS
10. What happens if I do nothing at all?
If you do nothing, you will remain a part of the Class and Settlement. You will receive no payment under
the Settlement and you will give up your rights to sue the Aurobindo Defendants for economic losses
related to Aurobindo Irbesartan. Submitting a Claim Form is the only way to receive a payment from this
Settlement.
11. Can I opt-out of the Settlement?
Yes, you can choose to opt-out, or exclude yourself, from the Settlement. Choosing this option means you
will not be bound by any future determination made in the Settlement; however, you will also not be
eligible for a payment from this Settlement. This is the only option that allows you to pursue your own
Questions? Call 1-866-875-9644 or visit www.SartanMedicationSettlement.com
Page 4 of 9
21695137.1
claims against one or more Aurobindo Defendants for claimed economic losses related to the Aurobindo
Irbesartan.
12. How do I exclude myself?
If you want to keep your right, if any, to separately sue the Aurobindo Defendants for the claims that are
addressed by the Settlement, you must take steps to exclude yourself from the Class and Lawsuit. This is
called “opting out”. The deadline for requesting exclusion from the Class and Lawsuit is June 2, 2026.
To exclude yourself, you must submit a written request for exclusion that includes the following
information:
• Your full name, current address, and telephone number; and
• A statement specifically and unambiguously indicating your desire to be excluded from the
Settlement Class and election to be excluded from any judgment entered pursuant to the
settlement.
You will also be requested to provide information as to the identification of the at-issue irbesartan you
purchased, if available, however this is not a requirement for exclusion.
A printable exclusion request form is available on the Settlement Website
www.SartanMedicationSettlement.com. Your request for exclusion must be mailed to the address below
so it is postmarked or received no later than June 2, 2026.
Sartan Medication Settlement Administrator
ATTN: Exclusion Request
PO Box 3376
Baton Rouge, LA 70821
You may also email a scanned copy of your signed exclusion request form to
[email protected]. You must download, print, complete, and sign the PDF exclusion
form found on the Settlement Website to qualify for email submission of your exclusion request. You must
include your documentation of purchase or declaration regarding your inability to provide documentation
with your exclusion form submission.
By electing to be excluded: (1) you will not share in any recovery that might be obtained by the Class upon
Final Approval of the Settlement; (2) you will not be bound by any decision related to the Settlement that
is either favorable to the Class or favorable to the Aurobindo Defendants; and (3) you may present any
claims you have against the Aurobindo Defendants related to Irbesartan through your own lawsuit.
Requests for exclusions shall be permitted on an individual basis only. Any purported “class-wide” opt-
outs will be construed as being submitted only on behalf of the person who actually submitted the
exclusion.
13. If I do not exclude myself, can I still sue the Aurobindo Defendants?
Questions? Call 1-866-875-9644 or visit www.SartanMedicationSettlement.com
Page 5 of 9
21695137.1
No. If you stay in the Settlement Class (i.e., do nothing or do not exclude yourself), you give up any right
to separately sue or pursue claims against any of the Aurobindo Defendants for the claims released in this
Settlement.
14. Can I object to the Settlement?
Yes, if you do not like any part of the Settlement, you may write to the Court and explain your objection.
You cannot submit both an exclusion request and objection. You must remain a part of the Class to object.
The Court will consider your objection at the Final Approval Hearing. If the Court grants Final Approval
over your objection, you will give up your rights to sue the Aurobindo Defendants about the issues in this
Settlement. If you also wish to receive payment from the Settlement, you must submit a Claim Form.
15. How do I object to the Settlement?
The deadline for objecting to the Settlement is June 2, 2026.
Any Settlement Class Member who intends to object to the fairness of the Settlement Agreement must,
file any objection via the Court’s electronic filing system, and if not filed via the Court’s electronic system,
must mail, postmarked by the date specified in the Preliminary Approval Order, the objection to the Court
and also serve by first-class mail copies of the objection upon:
Clerk of the Court
United States District Court
District of New Jersey
Mitchell H. Cohen Building
& U.S. Courthouse
4th & Cooper Streets
Camden, New Jersey 08101
Class Counsel for Class Counsel for Counsel for
Consumer Class: TPP Class: Defendants:
John R. Davis Gregory P. Hansel John P. Lavelle, Jr.
Slack Davis Sanger, LLP Preti Flaherty Beliveau & Morgan, Lewis & Bockius LLP
6001 Bold Ruler Way #100 Pachios, Chartered, LLP 502 Carnegie Center
Austin, TX 78746 P.O. Box 9546 Princeton, NJ 08540-6241
One City Center
Ruben Honik Portland, ME 04112-9546
Honik Law
1515 Market Street, Ste. 110 Jorge A. Mestre
Philadelphia, PA, 19102 Rivero Mestre LLP
2525 Ponce De Leon Blvd.
Conlee S. Whiteley Ste. 1000
Kanner & Whiteley, LLC Miami, FL 33134
701 Camp Street
New Orleans, LA 70130
Questions? Call 1-866-875-9644 or visit www.SartanMedicationSettlement.com
Page 6 of 9
21695137.1
Your objection must include:
• Your full name, current address, and telephone number;
• the identification of the Aurobindo Irbesartan purchased by you, the objector, including the NDC
code(s), the date(s) of purchase, and the documentation supporting your purchase(s);
• a written statement that you have reviewed the Settlement Class definition and represent in good
faith that you are a Settlement Class Member;
• a written statement of all grounds for the objection accompanied by any legal support for such
objection sufficient to enable the parties to understand and respond to those specific objections;
• copies of any papers, briefs, or other documents upon which the objection is based and which are
pertinent to the objection; and
• a list of all other objections submitted by you, the objector, and/or your counsel, to any class
action settlements submitted in any state or federal court in the United States in the previous five
(5) years, including the full case name with jurisdiction in which it was filed and the docket
number. If you or your counsel has not objected to any other class action settlement in the United
States in the previous five (5) years, you shall affirmatively so state in the objection
Objections shall be permitted on an individual basis only. Any purported “class-wide” objections will be
construed as being submitted only on behalf of the person who actually submitted the objection.
16. If I object, can I still sue the Aurobindo Defendants?
No. To object, you must stay in the Settlement Class (i.e., do not exclude yourself) and therefore you give
up any right to separately sue any of the Aurobindo Defendants for the claims released in this Settlement.
17. If I object, and the Court grants Final Approval of the Settlement, can I still get a payment?
Yes, but only if you also submit a Claim Form as described in Question 8 above.
THE LAWYERS REPRESENTING YOU
18. Do I have a lawyer in this case?
Yes, if you do not exclude yourself by opting out. The Court has appointed the following law firms to
represent the Settlement Class.
Consumer Economic Loss Class Counsel
• John R. Davis, Slack Davis Sanger, LLP
• Ruben Honik, Honik Law
• Conlee Whiteley, Kanner & Whiteley, LLC
You will not be charged directly for their services. Plaintiffs will apply to the Court for an award of
reasonable attorneys’ fees up to, but not to exceed, one-third of the total amount of the settlement fund,
plus reasonable costs and expenses related to the Aurobindo Irbesartan economic loss litigation.
Attorneys’ Fees and Expenses shall be in addition to any Representative Plaintiffs’ Service Awards that
may be awarded by the Court from the settlement fund.
Questions? Call 1-866-875-9644 or visit www.SartanMedicationSettlement.com
Page 7 of 9
21695137.1
19. Can I have my own lawyer?
If you do not exclude yourself, you do not need to hire your own lawyer because Class Counsel works for
you. If you want to be represented by your own lawyer, you may hire one at your own expense and have
them appear on your behalf in the Lawsuit.
THE COURT PROCESS
20. When and where will the Court decide whether to approve the Settlement?
The Court will hold the Final Approval Hearing at 10:00 am on Tuesday, June 30, 2026, at Courtroom
3D of the United States District Court for the District of New Jersey. The purpose of the hearing is
for the Court to determine whether the Settlement is fair, reasonable, adequate, and in the best interests
of the Settlement Class. At the hearing, the Court will hear any objections and arguments concerning the
fairness of the proposed Settlement, including those related to the amount requested by Class Counsel
for attorneys’ fees and expenses and the requested service awards for the Class Representatives.
Note: The date and time of the Final Approval Hearing are subject to change by Court Order. Any
changes will be posted at the Settlement website, www.SartanMedicationSettlement.com.
21. Do I have to come to the hearing?
No. Class Counsel will answer any questions the Court may have. You are welcome to come at your own
expense. If you send an objection, you don’t have to come to Court to talk about it. As long as your written
objection was filed or mailed on time and meets the other criteria described in Question #15 and detailed
in the Settlement Agreement, the Court will consider it. You may also pay a lawyer to attend, but you
don’t have to.
22. May I speak at the hearing?
Subject to the approval of the Court, any objecting Settlement Class Member may appear, in person or by
counsel, at the Final Fairness Hearing to explain why the proposed settlement should not be approved as
fair, reasonable, and adequate, or to object to any petitions for Attorneys’ Fees, Expenses or Service
Awards.
If you intend to appear at the Final Fairness Hearing, you must file with the Clerk of the Court and serve
upon all counsel designated in Question 15 above a notice of intention to appear at the Fairness Hearing
by the objection deadline as specified in the Preliminary Approval Order. The notice of intention to appear
must include copies of any papers, exhibits, or other evidence, and the identity of witnesses, that you or
your counsel intends to present to the Court in connection with the Final Fairness Hearing.
GET MORE INFORMATION
23. How do I get more information?
For more information about the Settlement, including assistance in determining whether you qualify as a
Class Member, please visit the Settlement Website www.SartanMedicationSettlement.com. You may
Questions? Call 1-866-875-9644 or visit www.SartanMedicationSettlement.com
Page 8 of 9
21695137.1
contact the Settlement Notice Administrator by email at [email protected], by
phone at 1-866-875-9644 or by mail at:
Sartan Medication Settlement Administrator
P.O. Box 3376
Baton Rouge, LA 70821
PLEASE DO NOT WRITE OR CALL THE COURT OR THE CLERK’S OFFICE FOR INFORMATION.
Questions? Call 1-866-875-9644 or visit www.SartanMedicationSettlement.com
Page 9 of 9
21695137.1
