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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 Page18 of 138<br />

In Re TFT-<strong>LCD</strong> (Flat Panel) Antitrust Litigation<br />

NOTICE PROGRAM OVERVIEW:<br />

PROGRAM COMPONENTS<br />

This Notice Program outlines procedures to provide notice of the partial Settlements as well as the<br />

continuing litigation in In Re TFT-<strong>LCD</strong> (Flat Panel) Antitrust Litigation, consistent with the<br />

requirements set forth in Rule 23 of the Federal Rules of Civil Procedure.<br />

Based upon information provided by <strong>Class</strong> Counsel and research on <strong>Class</strong> Members’ media habits, KM<br />

recommends the following Notice Program.<br />

➢ PAID MEDIA: KM recommends the use of measurable paid media to reach unidentifiable<br />

<strong>Class</strong> Members. Paid media advertising is guaranteed to appear, allowing for control of the<br />

content, timing, and positioning of the message. After careful research of the demographics of<br />

<strong>Class</strong> Members, KM recommends broad paid media notice comprised of print, television and<br />

Internet vehicles that will reach <strong>Class</strong> Members, including:<br />

§ Print: Consumer magazines, national newspapers, newspaper supplements, and<br />

local U.S territory newspapers.<br />

§ Television: Cable television will be used for the purpose of driving people to the<br />

website to register for a claim form.<br />

§ Internet: Banner advertising on multiple networks reaching hundreds of websites as<br />

well as content-targeted websites.<br />

➢ EARNED MEDIA: KM recommends amplifying the paid media notice efforts with an earned<br />

media outreach program, to provide additional opportunities for the message to be seen by<br />

those affected by the litigation and Settlements, including:<br />

§ National press release with a Twitter post.<br />

§ Blogger outreach.<br />

§ Really Simple Syndication (“RSS”) technology feed.<br />

➢ O<strong>THE</strong>R PROGRAM COMPONENTS: To complement the Notice Program and to ensure<br />

<strong>Class</strong> Members’ easy access to updated information, KM recommends the following:<br />

§ Keyword sponsorships.<br />

§ Text messaging.<br />

§ Toll-Free telephone support.<br />

© 2011 KINSELLA MEDIA, LLC<br />

9

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