|UNITED STATES DISTRICT COURT|
|SOUTHERN DISTRICT OF NEW YORK|
|In re Altair Nanotechnologies Shareholder|
|CASE NO.: 14-CV-09418-AT|
The Action and Settlement address claims alleging that certain current and former directors and officers of Altair breached their fiduciary duties by failing to implement and/or maintain adequate internal controls over the Company's operations and disclosures, by making or approving false statements to the Company's shareholders, by grossly mismanaging the Company, and by wasting Altair's assets by causing the Company to incur significant potential liability for legal costs, penalties, fines and/or legal fees in connection with the defense of the Individual Defendants' unlawful course of conduct. The Action further alleges that certain Defendants were unjustly enriched at the Company's expense. The Settling Defendants deny and continue to deny all allegations of wrongdoing and deny that Defendants have any liability on the claims asserted in the Action.As part of the Settlement, Altair has agreed to adopt and/or maintain certain corporate governance reforms as set forth in the Stipulation. The terms and conditions of the proposed Settlement are set forth in the Stipulation and Addendum thereto. The Stipulation and Exhibits thereto has been filed with the Court. Plaintiffs' Counsel will request Court approval of the agreed upon attorneys' fees and expenses in an amount not to exceed $150,000, which shall include all attorneys' fees and costs that may be due any counsel (or anyone else) who has asserted, or participated in the assertion of, derivative claims on behalf of Altair in any court. Any award of fees and expenses will be paid by the Company (or its insurer on its behalf). To date, Plaintiffs' Counsel have neither received any payment for their services in conducting the Action, nor have counsel been reimbursed for their out-of-pocket expenses incurred. Plaintiffs will also seek Court approval of an incentive payment of up to $1,500 each for their participation and efforts in the Action. This Incentive Amount shall be paid from the attorneys' fees and expenses awarded by the Court. If the Settlement is approved, the Action will be dismissed with prejudice and the Defendants will be released by Plaintiffs, Altair, and its shareholders from all claims that were or could have been alleged in the Action.
If you are a current Altair Shareholder, you may have certain rights in connection with the proposed settlement. The full and complete Notice along with the Stipulation and Exhibits thereto have been made accessible on Altair's corporate website at http://www.altairnano.com. If you are a current Altair shareholder and do not take steps to appear in this Action or to object to the Settlement, you will be bound by the Court's Judgment and Order of Dismissal, you will forever be barred from raising an objection to such Settlement in this or any other action or proceeding, and certain claims that you might have may be released.PLEASE DO NOT TELEPHONE THE COURT OR ALTAIR REGARDING THIS NOTICE.
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