Airbus Securities Settlement
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WELCOME TO THE AIRBUS SECURITIES SETTLEMENT WEBSITE

This website has been established to provide general information related to the proposed settlement of the lawsuit referred to as Kornecki v. Airbus SE, et al., No. 2:20-cv-10084-KM-JBC (the “Litigation”), and pending before the Honorable Kevin McNulty in the United States District Court for the District of New Jersey (the “Court”). The capitalized terms used on this website, and not otherwise defined, shall have the same meanings ascribed to them in the Amended Stipulation and Agreement of Settlement dated June 7, 2022 (the "Stipulation"), which can be found and downloaded by clicking on the Case Documents tab above.

The law firm of Robbins Geller Rudman & Dowd LLP represents you and other Class Members. You will not be charged for these lawyers. They will be paid from the Settlement Fund to the extent the Court approves their application for fees and expenses. If you want to be represented by your own lawyer, you may hire one at your own expense.

WHAT IS THIS LAWSUIT ABOUT?

This is a securities class action brought by Lead Plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund ("Lead Plaintiff") against Airbus SE ("Airbus" or the "Company") and Guillaume M.J.D. Faury, Tom Enders, Dominik Asam and Harald Wilhelm (collectively, "Defendants") for alleged violations of Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (“Exchange Act”). The Litigation asserts claims on behalf of all Persons who purchased or otherwise acquired Airbus Securities in the United States as American Depository Receipts ("ADRs") and foreign ordinaries under the ticker symbols "EADSY" and "EADSF" during the period from February 24, 2016 through July 30, 2020, inclusive, and were allegedly damaged thereby.

Lead Plaintiff's claims in the Litigation are set forth in the Class Action Complaint filed on August 6, 2020 (the “Complaint”). The Complaint asserted that Defendants made material misstatements and omissions regarding, among other things: (i) the sufficiency of Airbus’s policies and protocols to ensure compliance with relevant anti-corruption laws and regulations; (ii) Airbus’s involvement in a bribery and corruption scheme to enhance its commercial aircraft, helicopter, and defense business; (iii) Airbus’s earnings derived in part from alleged unlawful conduct and the sustainability of such earnings; and (iv) whether and to what extent the resolution of government investigations and enforcement actions would foreseeably cost Airbus substantial settlements and legal fees and subject the Company to significant continuing government oversight. Defendants deny all of the claims and contentions of wrongdoing alleged by Lead Plaintiff in the Litigation. 

If you purchased or otherwise acquired Airbus Securities in the United States as ADRs and foreign ordinaries under the ticker symbols "EADSY" and "EADSF" during the period between February 24, 2016 through and including July 30, 2020, and were allegedly damaged thereby, you are a Class Member. Excluded from the Class are: (i) Defendants, (ii) the current and Class Period officers and directors of the Company, (iii) members of the immediate families of the Individual Defendants, and (iv) the legal representatives, heirs, successors-in-interest, or assigns of any excluded person or entity, and any entity in which such excluded persons have or had a controlling interest. Also excluded from the Class are those Persons who timely and validly exclude themselves from the Class.

WHAT DOES THE SETTLEMENT PROVIDE?

The proposed Settlement will create a cash settlement fund of $5,000,000 (the “Settlement Fund”), plus any interest that may accrue thereon less certain deductions.

The Settlement Fund, subject to deduction for, among other things, costs of class notice and administration and certain taxes and tax-related expenses, as well as attorneys’ fees and expenses, and the amount to Lead Plaintiff in connection with its representation of the Class, as approved by the Court, will be available for distribution to Class Members. Your share of the Net Settlement Fund will depend on several things, including the total amount of claims represented by the valid Proofs of Claim that Class Members send in, compared to the amount of your claim, all as calculated under the Plan of Allocation outlined in the Notice of Pendency and Proposed Settlement of Class Action ("Notice").

ADDITIONAL INFORMATION

Although the information on this website is intended to assist you, it does not replace the information contained in the Notice and the Stipulation. We recommend you read the Notice and other relevant case documents carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

SUBMIT A PROOF OF CLAIM

The only way to be eligible to receive a payment from the Settlement. Proofs of Claim must be postmarked or submitted online on or before September 13, 2022.

EXCLUDE YOURSELF 

Get no payment. This is the only option that potentially allows you to ever be part of any other lawsuit against the Defendants or any other Released Parties about the legal claims being resolved by this Settlement. Exclusions must be postmarked on or before September 9, 2022.

OBJECT 

Write to the Court about why you do not like the Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and expenses. You will still be a Member of the Class. Objections must be received by the Court and counsel on or before September 9, 2022.

GO TO THE HEARING ON SEPTEMBER 30, 2022

Ask to speak in Court about the fairness of the Settlement. Requests to speak must be received by the Court and counsel on or before September 9, 2022.

DO NOTHING 

Receive no payment.  You will, however, still be a Member of the Class, which means that you give up your right to ever be part of any other lawsuit against the Defendants or any other Released Parties about the legal claims being resolved by this Settlement and you will be bound by any judgments or orders entered by the Court in the Litigation.


IMPORTANT DATES AND DEADLINES

Submit Proof of Claim

September 13, 2022

Request Exclusion

September 9, 2022

Submit Written Objection

September 9, 2022

Submit Notice of Intent to Appear 

September 9, 2022

Settlement Hearing 

September 30, 2022, at 2:00 p.m. EST