2011 MACBOOK PRO LAPTOP (15” OR 17” SCREEN) QUEBEC CLASS ACTION SETTLEMENT

In December 2014, a class action was commenced in Quebec against Apple Canada Inc. and Apple Inc. (collectively “Defendants” or “Apple”) alleging that the 15’’ and 17’’ 2011 MacBook Pro Laptops manufactured by Apple (the “Device(s)”) suffer from a graphics issue or defect (the “Class Action”).

The class is defined as follows:

-          all persons in Quebec, who purchased and/or own a 2011 MacBook Pro Laptop with a 15 inch or 17 inch screen; and

-          all persons, who purchased in Quebec a 2011 MacBook Pro Laptop with a 15 inch or 17 inch screen;

The notice you received will indicate the Class Member group you belong to along with detailed instructions on what you need to do, if anything, in order to receive compensation from the Settlement Agreement. The notice will also include individualised login credentials for you to complete any necessary Form online.

Notices have been sent to the class members, which will provide instructions on how to make a claim to receive compensation from the Settlement Agreement (certain class members will receive compensation automatically without the need to make a claim).

Direct Group

If you are a member of the Direct Group based on Apple’s records, you will receive a Short Form Notice by email confirming this. If this is the case, you will receive up to $175.00 per Device. This amount will be sent directly to you by cheque at the last known address that Apple has on record for you. (If Apple has your email address but no postal address, you will receive a different Short Form Notice explaining how you will receive your payment.)

No further action will be required on your part to receive the payment unless (i) you wish to modify the mailing address for the cheque or (ii) you wish to receive the funds electronically.

You may go onto the Direct Group online portal before October 01, 2021 in order to confirm your mailing address, modify your mailing address, or switch to electronic payment, using the individualised ID number and/or login credentials enclosed with the Short Form Notice you receive.

Reimbursement Group

You may also have a right to file an additional claim under the Reimbursement Group if you paid for repairs to your Device but did not receive a reimbursement from Apple, subject to the acceptance of your claim (the “Reimbursement Claim”) by the Claims Administrator. In order to make a valid Reimbursement Claim, you must submit a valid and timely Reimbursement Claim Form to the Claims Administrator via the online claim portal. In the Reimbursement Claim Form, you will have to include your full name and email address and attest that:

o The graphics issue affected your Device before January 1, 2017;

o You paid for a repair (including without limitation, changing or repairing the logic board or graphics chip of the Device, resoldering the chips or other Device components, bypassing a graphics chip);

o The repair was due to a graphics issue affecting your Device; and

o You were not reimbursed for the repair.

You will also have to provide a receipt for the repair dated December 31, 2017, or before.

The Reimbursement Claim Form must be submitted to the Claims Administrator online or postmarked on or before October 01, 2021 for the Claim to be deemed valid.

Remaining Group

You may have a right to file a claim under the Remaining Group if you experienced a graphics issue with your Device prior to January 1, 2017, subject to the acceptance of your claim (the “Remaining Claim”) by the Claims Administrator. To be in the Remaining Group, you must not already be in the Direct Group described above.

In order to make a valid Remaining Claim, you must submit a valid and timely Remaining Claim Form to the Claims Administrator via the online claim portal using the individualised ID number and/or login credentials enclosed with the Short Form Notice you receive.

In the Remaining Claim Form, you will have to include your full name and email address and attest to the following:

o You owned a Device;

o You experienced a graphics issue with your Device prior to January 1, 2017;

o You are not part of the Direct Group (the Service Group nor the Complaint Group).

The Remaining Claim Form must be submitted to the Claims Administrator online or postmarked on or before October 01, 2021 for the Claim to be deemed valid.

The attorneys representing the Class (“Class Counsel”) are the firm of Lex Group Inc. (c/o Mtre David Assor), which can be contacted at www.lexgroup.ca.

The parties have negotiated a settlement of the Class Action (the “Settlement Agreement”), which has been approved by the Superior Court of Quebec on May 11, 2021 as fair, reasonable and in the best interests of the Class. The Settlement Agreement provides that Apple agrees to pay $5,344,575.00 in settlement of the Class Action the “Total Settlement Fund”).

Class Members will receive or may claim up to $175 per Device (if there are more than one individual associated with the same Device, the compensation amount will be split evenly among them).

In addition, Class Members who paid for repairs relating to a graphics issue affecting their Device before January 1, 2017 may claim for a full reimbursement of the cost of such repairs, subject to certain conditions.