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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

In re Silver Wheaton Corp. Securities Litigation

Master File No: 2:15-cv-05146-CAS-PJWx c/w: 2:15-cv-05173-CAS(PJWx)


TO ALL PERSONS WHO PURCHASED SILVER WHEATON CORP. SECURITIES ON A UNITED STATES EXCHANGE OR IN DOMESTIC U.S. TRANSACTIONS BETWEEN MARCH 30, 2011 AND JULY 6, 2015, INCLUSIVE

YOU ARE HEREBY NOTIFIED that the above-captioned action has been certified as a class action for settlement purposes and that Plaintiffs have reached a proposed settlement with Silver Wheaton Corp., n/k/a Wheaton Precious Metals Corp., certain of its officers, and Deloitte LLP (Canada) (“Settlement”) pursuant to an Order of the United States District Court for the Central District of California, that a hearing will be held on August 3, 2020 at 10:00 a.m. before the Honorable Christina A. Snyder, United States District Judge of the Central District of California, First Street Courthouse, 350 W. First Street, Courtroom 8D, 8th Floor, Los Angeles, CA 90012 (the “Settlement Hearing”) for the purpose of determining: (1) whether the proposed Settlement consisting of the sum of $41,500,000 in cash should be approved by the Court as fair, reasonable, and adequate; (2) whether the proposed plan to distribute the settlement proceeds is fair, reasonable, and adequate; (3) whether the application for an award of attorneys’ fees of no more than one-third of the settlement amount (or $13,833,333) and reimbursement of expenses of no more than $1,600,000 and a reimbursement award of reasonable costs and expenses (including lost wages) directly relating to their representation of the Class of no more than $12,500 per plaintiff, or $87,500 collectively to all Plaintiffs, should be approved; and (4) whether a Final Judgment should be entered dismissing this Litigation with prejudice and releasing the Released Claims.

If you purchased Silver Wheaton securities on a U.S. exchange or in U.S. transactions between March 30, 2011 and July 6, 2015, inclusive (the “Class Period”), your rights may be affected by the Settlement of this action.  If you have not received a detailed Internet Notice of Pendency and Proposed Settlement of Class Action (“Notice”) and a copy of the Proof of Claim and Release Form (“Proof of Claim”), you may obtain copies by contacting the Claims Administrator at: (1) Mail: Silver Wheaton Corp. Litigation, c/o Strategic Claims Services, P.O. Box 230, 600 N. Jackson St., Ste. 205, Media, PA 19063; (2) Telephone: (866) 410-3013; (3) Facsimile: (610) 565-7985; or (4)Email: info@strategicclaims.net, or by going to the Important Documents page on this website.  If you are a member of the Class, in order to share in the distribution of the Net Settlement Fund, you must electronically submit a properly completed Proof of Claim by 11:59 p.m. on June 13, 2020 to the Claims Administrator, establishing that you are entitled to recovery.  If you are unable to electronically submit a Proof of Claim, you may print and mail a Proof of Claim at your own expense.  If you submit a Proof of Claim by mail, the amount of your payout will be reduced to reflect additional administrative costs.  Unless you submit a written exclusion request, you will be bound by any judgment rendered in the Litigation whether or not you make a claim.   If you desire to be excluded from the Class, you must submit a request for exclusion received no later than June 13, 2020, in the manner and form explained in the detailed Notice to the Claims Administrator as well as the Plaintiffs’ Counsel and Defendants’ Counsel at the addresses listed below.

Any objection to the Settlement, Plan of Allocation, or the Plaintiffs’ Counsel’s request for an award of attorneys’ fees and reimbursement of expenses must be in the manner and form explained in the detailed Notice and received no later than July 20, 2020, to each of the following:

Clerk of the Court
United States District Court
Central District of California
First Street U.S. Courthouse
350 W 1st Street, Suite 4311
Los Angeles, CA 90012

Silver Wheaton Defendants’ Counsel:
Gregory L. Watts
WILSON SONSINI GOODRICH & ROSATI, P.C.
701 Fifth Avenue, Suite 5100
Seattle, WA 98104

Plaintiffs’ Counsel:
Jonathan Horne
THE ROSEN LAW FIRM, P.A.
275 Madison Avenue, 40th Floor
New York, NY 10016

Deloitte’s Counsel:
Lee G. Dunst
GIBSON, DUNN & CRUTCHER LLP
200 Park Avenue
New York, NY 10166

If you have any questions about the Settlement, you may call or write to Plaintiffs’ Counsel at the address listed above. Please visit the Important Documents page for more information.

PLEASE DO NOT CONTACT THE COURT OR THE CLERK’S OFFICE REGARDING THIS NOTICE.