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UNITED STATES DISTRICT COURT FOR THE ... - LCD Class Action

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Case3:07-md-01827-SI Document6141-11 Filed07/12/12 Page6 of 138<br />

14. A 30-second television advertisement will run over a period of two weeks<br />

on cable networks that may include CNN, CNBC, DIY, Fox News Channel, HGTV, Golf<br />

Channel, MSNBC, and the Science Channel.<br />

15. For the purpose of evaluating the strength and efficiency of the media, the<br />

national newspaper supplements, national consumer magazines and Internet banner<br />

advertising were measured against the target audiences to establish the estimated reach 8<br />

of the media program and the estimated frequency 9 of exposure to the media vehicles. An<br />

estimated 85.0% of Adults 25 years and older with a household income of $60,000 or<br />

more will be reached with an average estimated frequency of 3.5 times. An estimated<br />

83.7% of Adults 25 years and older will be reached with an average estimated frequency<br />

of 3.6.<br />

16. All print advertising will carry a toll-free number, text messaging code,<br />

and a website address for potential <strong>Class</strong> Members to request or access the <strong>Class</strong> Notice.<br />

Online Media<br />

17. An informational, interactive website is a critical component of the Notice<br />

Program. A website is a constant information source instantly accessible to <strong>Class</strong><br />

Members. The site will utilize the Internet’s ability to serve as a key distribution channel<br />

and customer service bureau.<br />

18. A website will be established at www.<strong>LCD</strong>class.com to enable potential<br />

<strong>Class</strong> Members to get information about the claim.<br />

19. Appropriate keywords will be sponsored on the Google, Yahoo!, and Bing<br />

search engines to encourage <strong>Class</strong> Members to visit the website.<br />

8<br />

Reach is the estimated percentage of a target audience reached through a specific media vehicle or combination of<br />

media vehicles.<br />

9<br />

Frequency is the estimated average number of opportunities an audience member has to see the notice.<br />

DECLARATION OF KA<strong>THE</strong>RINE KINSELLA<br />

5

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