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AIG Securities Litigation - Gen Re Settlement


IMPORTANT:  On September 30, 2014, the Court issued orders approving the initial distributions of the settlement proceeds from the four settlements in the AIG Securities Litigation – the “PwC,” “Company,” “Starr,” and “Gen Re” Settlements.  On November 18, 2014, pursuant to the Court’s Orders, 90% of the PwC, Company, Starr, and Gen Re Net Settlement Funds were distributed.  The remaining funds will be distributed at a future date to eligible claimants who cash their initial distribution payments.  If you receive a check from this distribution, please cash it promptly as it will become stale on the date listed on the check.


The following is a summary of information presented in more detail in the Notice of Proposed Settlement, Motion for Attorneys’ Fees and Expenses Award and Fairness Hearing (the "Notice"), which Class Members should have received in the mail, and which you can access by clicking on the “Notice” link on the left. Since this is just a summary, you should review the full Notice for additional details.

Please read this information carefully. If you are a Class Member (as defined in the Notice), your rights will be affected by these proceedings and you may be entitled to receive benefits under a proposed settlement.

If You Purchased or Otherwise Acquired Securities Issued by American International Group, Inc. During the Period From October 28, 1999 Through April 1, 2005, Inclusive, (the “Class Period”) and Were Damaged Thereby, You May Be Entitled to Share in a $72 Million Settlement With General Reinsurance Corporation.

If you would like information about:

American International Group Securities Litigation-PwC Settlement please click here.
American International Group Securities Litigation-Company Settlement please click here.
American International Group Securities Litigation-Starr Defendants Settlement please click here.

Securities Brokers and other Nominees: Please see instructions at the end of the Notice. 

 Important Dates and Deadlines

File a Proof of Claim  Postmarked no later than September 12, 2013 
File an Exclusion  Postmarked no later than August 20, 2013 
File an Objection  Postmarked no later than August 20, 2013 
File a Release Form  Postmarked no later than September 12, 2013 
Fariness Hearing 

September 10, 2013 at 3:00 p.m.
United States District Court
Southern District of New York


Fairness Hearing

 A hearing will be held before the Honorable Deborah A. Batts, in the United States District Court for the Southern District of New York, United States Courthouse, 500 Pearl Street, New York, New York 10007 at 3:00 p.m. on September 10, 2013 to determine whether the proposed Settlement with Gen Re should be approved by the Court as fair, reasonable and adequate, to consider final certification of the proposed Settlement Class, to consider the application of Lead Plaintiff’s Counsel for attorneys’ fees and reimbursement of litigation expenses and to consider the application of Lead Plaintiff for the reimbursement of costs and expenses.  The Court may change the date of the hearing without providing additional notice to Class Members.

The issuance of the Notice is not an expression of the Court’s opinion on the merits of any claim in the Action, and the Court still has to decide whether to approve the Settlement.  If the Court approves the Settlement, payment will be made after all appeals, if any, are resolved and after the completion of all claims processing.  Please be patient.


What is this case about?

The allegations against the Gen Re Defendants are limited to a single transaction.  Lead Plaintiff alleges that (i) the Gen Re Defendants knowingly, or with severe recklessness, designed and executed the Gen Re Transaction to inflate AIG’s financial results; and (ii) the Gen Re Transaction allowed defendants to mislead investors during the Class Period.  Lead Plaintiff also alleges that disclosures in February, March and April 2005 of a massive accounting fraud at AIG, including the Gen Re Transaction, resulted in AIG’s $3.9 billion restatement or adjustment of earnings in May 2005.  At the end of the Class Period, the price of AIG’s stock dropped significantly when these frauds were disclosed, resulting in alleged damages to the Settlement Class. 

Gen Re denies all liability and the Settlement is not and may not be construed or deemed to be evidence of, or an admission or a concession on the part of Gen Re, of any fault or liability whatsoever or of any infirmity in any defenses it has asserted or intended to assert, or of the merits of Lead Plaintiff’s claims.  Gen Re, while affirmatively denying liability, considers it desirable and in its best interest that the claims against Gen Re in the Action be dismissed under the terms of the proposed Settlement in order to avoid further expense, uncertainty and distraction, and protracted litigation.


Terms of the Settlement

In exchange for the Settlement and dismissal of the Released Claims, Gen Re has agreed to fund a $72 million (before interest) account to be divided, after deduction of Court-awarded attorneys’ fees and expenses, Lead Plaintiff expenses, Notice and Administrative Expenses, and any applicable taxes, (“Distribution Amount”) among all Class Members who timely submit valid Proof of Claim forms that show a Recognized Loss.  Your share of the Distribution Amount will depend on several things, including: (1) the amount of Recognized Losses of other Class Members who file valid Proofs of Claim; (2) how many AIG Securities you bought; (3) how much you paid for them; (4) the type of security bought; (5) when you bought them; (6) whether or when you sold them (and, if so, for how much you sold them).

Your Recognized Loss will be calculated according to the formula shown below in the Plan of Allocation.  It is unlikely that you will get a payment for your entire Recognized Loss, given the number of potential Class Members with Recognized Losses.  After all Class Members have sent in their Proof of Claim forms, the payment you get will be a portion of the Distribution Amount equal to your Recognized Loss divided by the total of all Class Members’ Recognized Losses and multiplied by the total Distribution Amount. (See the Plan of Allocation beginning on page 9 of the Notice for more information.)

Once all the Proofs of Claim are processed and claims are calculated, Lead Plaintiff’s counsel, without further notice to the Settlement Class, will apply to the Court for an order distributing the Distribution Amount to the members of the Settlement Class.  Counsel will also ask the Court to approve payment of the Administrator’s fees and expenses incurred in connection with administering the Settlement that have not already been reimbursed.


The Rights of the Settlement Class Members

If you are a Settlement Class Member, you have the following options:
If you already submitted a Proof of Claim form in the PwC, Company and/or Starr Settlements, the trading information you already supplied will be used to determine your claim in this Settlement.  DO NOT submit another Proof of Claim. The trading information you already provided will be used to determine your claim in this Settlement with Gen Re. Instead, you should have received a Release Form with the Notice, which must be completed and signed in order for you to recover. You may also submit a Release Form through this website by clicking on the “Release Form” link on the left.

To qualify for a payment if you did NOT submit a Proof of Claim in the PwC, Company and/or Starr Settlements, you must timely send in a completed Proof of Claim form with supporting documents (DO NOT SEND ORIGINALS) to the Administrator.  DO NOT SEND Proof of Claim forms to counsel for the Settling Parties or the Court.  A Proof of Claim form is being circulated with the Notice.  You may also get a Proof of Claim form by clicking on the “Proof of Claim” link on the left, or on the Internet at the website for Lead Plaintiff’s counsel: Please read the instructions carefully, fill out the Proof of Claim form, include all the documents the form asks for, sign it, and mail it to the Administrator by first class mail, postmarked no later than September 12, 2013.  The Administrator needs all of the information requested in the Proof of Claim in order to determine what you may be entitled to.

Each Class Member will be bound by all determinations and judgments in this Action concerning the Settlement, whether favorable or unfavorable, unless such person mails, by first class mail, a written request for exclusion from the Settlement Class, postmarked no later than August 20, 2013, addressed to In re AIG Securities Litigation – Gen Re EXCLUSIONS, c/o Rust Consulting, Inc., P.O. Box 24676, West Palm Beach, FL 33416.  No person may exclude himself, herself or itself from the Settlement Class after this deadline. You may not exclude yourself by telephone or e-mail.

In order to be valid, each request for exclusion must set forth the name and address of the person or entity requesting exclusion, must state that such person or entity “requests exclusion from the Gen Re Settlement Class in In re AIG Securities Litigation, Master File No. 04-8141 (DAB)” and must be signed by such person or entity.  The following information must also be provided: a daytime telephone number; date(s), price(s), and number(s) of shares of all purchases and sales of AIG Securities during the Class Period.  Requests for exclusion will NOT be accepted if the requests do not include the required information or if the requests are not made within the time stated above, unless the requests for exclusion are otherwise accepted by the Court.

If a Class Member requests to be excluded from the Settlement Class, that Class Member will not receive any benefit provided for in the Agreement.

Any Class Member who does not request exclusion by August 20, 2013 may ask the Court to consider their objection to any of the matters to be considered at the Fairness Hearing (and may also appear at the Fairness Hearing) provided, however, that no such person shall be heard unless his, her or its objection is made in writing and is filed, together with copies of all other papers and briefs to be submitted to the Court at the Fairness Hearing, by him, her or it (including proof of all purchases and sales of AIG Securities during the Class Period) with the Clerk’s Office at the United States District Court for the Southern District of New York, United States Courthouse, 500 Pearl Street, New York, New York 10007, postmarked no later than August 20, 2013, and is served on the same day, by first class mail, hand or overnight delivery to each of the following: 

Thomas A. Dubbs
Louis Gottlieb
Labaton Sucharow LLP
140 Broadway
New York, NY 10005 
George M. Garvey
David H. Fry
Munger, Tolles & Olson LLP
335 South Grand Ave. 35th Floor
Los Angeles, CA  90071 
Counsel for Lead Plaintiff and the Settlement Class  Counsel for Gen Re 


Further Information

Further information regarding the Action, the Notice and how to file your Proof of Claim or Release form may be obtained by contacting the Administrator or reading through the Notice, Proof of Claim form and Release Form links on the left.



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