CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE

Daed June 10, 2025

Attached is a motion to approve a settlement in the Hernandez v. Radio Systems Corporation matter. The motion was filed last month. A hearing on the motion is set for one week from today.

We have been advised that a significant portion of the settlement will not be allocated to RSC customers.

The attorneys will seek attorneys’ fees up to 33-1/3% of the settlement, reimbursement of their costs and expenses (including expert witness fees), and a $10,000 “service award” for the plaintiff (Steven Hernandez).

After the costs of noticing class members by various means and administering the fund (preliminarily estimated at $150,000), the remainder will go toward class members who opt in to the settlement by submitting a valid claim form and proof of purchasing an RSC product in California between October 1, 2018 and October 31, 2022.

The settlement ostensibly provides payments as follows: “$30.00 for each Bark Collar Product, $35.00 for each Barrier Product, $90.00 for each In-Ground Fence Product, and $140.00 for each Wireless Fence Product purchased during the relevant period.”

However, if claims exceed the remaining funds, the awards will be reduced by a pro rata amount. If fewer customers make valid claims, the award will increase by a pro rata amount. No funds will be returned to RSC.