The Court has directed the issuance of the Notice to inform potential Class Members about the Litigation and the proposed Settlement and their options in connection therewith before the Court rules on the Settlement.  Additionally, Class Members have the rights to understand how this class action lawsuit may generally affect their legal rights.

The Notice explains the class action lawsuit, the Settlement, Class Members’ legal rights in connection with the Settlement, what benefits are available, who is eligible for them, and how to get them.

The Court in charge of the Litigation is the United States District Court for the Southern District of Texas, and the case is known as Delaware County Employees Retirement System v. Cabot Oil & Gas Corporation, et al., No. 4:21-cv-02045.  The case has been assigned to the Honorable Lee H. Rosenthal.  The entities representing the Class are the “Plaintiffs,” and the individuals and entity they sued and who have now settled are called the “Defendants.”

The Litigation is currently pending before the Honorable Lee H. Rosenthal in the United States District Court for the Southern District of Texas.  The initial complaint in the Litigation was filed in the United States District Court for the Middle District of Pennsylvania (the “Pennsylvania Court”) on October 5, 2020.  On February 3, 2021, the Pennsylvania Court appointed Delaware County Employees Retirement System as Lead Plaintiff and Robbins Geller Rudman & Dowd LLP as Lead Counsel.

On April 12, 2021, Iron Workers District Counsel (Philadelphia and Vicinity) Retirement and Pension Plan, represented by Kessler Topaz Meltzer & Check, LLP, joined the Litigation as an additional plaintiff, and together Plaintiffs filed the Consolidated Complaint for Violation of the Federal Securities Laws (“Complaint”) alleging violations of §§10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”).  On June 11, 2021, Defendants moved to dismiss the Complaint.  On June 22, 2021, upon Defendants’ motion, the Pennsylvania Court transferred the Litigation to the Court.

Plaintiffs filed their opposition to Defendants’ motion to dismiss on August 10, 2021, and Defendants filed their reply on September 6, 2021.  The Court held oral argument on Defendants’ motion to dismiss on November 29, 2021, and on January 12, 2022, the Court granted Defendants’ motion to dismiss with leave to amend with respect to certain allegations.

On December 15, 2021, Plaintiffs moved for partial relief from the PSLRA discovery stay.  Defendants filed their opposition on December 28, 2021, and Plaintiffs filed their reply on January 4, 2022.  On January 12, 2022, the Court denied as moot Plaintiffs’ motion.

On February 11, 2022, Plaintiffs filed the First Amended Consolidated Complaint for Violation of the Federal Securities Laws (the “Amended Complaint”).  Defendants moved to dismiss the Amended Complaint on March 10, 2022.  Plaintiffs filed their opposition on April 13, 2022, and Defendants filed their reply on May 10, 2022.  Plaintiffs filed their sur-reply in further opposition to the motion to dismiss on May 31, 2022.  On August 10, 2022, the Court issued a Memorandum and Opinion granting in part and denying in part Defendants’ motion to dismiss.  Defendants answered the Amended Complaint on September 14, 2022.

On December 5, 2022, Plaintiffs moved to certify a class.  Defendants filed their opposition on January 21, 2023.  Plaintiffs filed their reply on May 8, 2023.  Oral argument on Plaintiffs’ class certification motion was held on July 7, 2023.  On September 27, 2023, the Court granted Plaintiffs’ motion, certifying a class consisting of all persons or entities who purchased or otherwise acquired Cabot common stock between February 22, 2016, and June 12, 2020, inclusive, and were damaged thereby.  The Court also appointed Plaintiffs as class representatives and Robbins Geller Rudman & Dowd LLP and Kessler Topaz Meltzer & Check, LLP as class counsel.  On October 11, 2023, Defendants filed a petition to the Fifth Circuit for leave to appeal the class certification order pursuant to Rule 23(f).  Plaintiffs filed their opposition on October 23, 2023, and on November 17, 2023, the Fifth Circuit denied Defendants’ Rule 23(f) petition.  On December 1, 2023, Defendants filed a petition for panel and en banc rehearing of the Rule 23(f) petition, which was denied by the Fifth Circuit on December 18, 2023.

The parties conducted extensive fact and expert discovery, including litigating various discovery disputes, and class certification-related expert discovery.  In all, Defendants and third parties produced more than 4.4 million pages of documents, and the parties conducted 19 fact and expert depositions.

On October 20, 2023, Plaintiffs moved to amend the Amended Complaint.  Defendants filed their opposition to the motion on November 13, 2023, and Plaintiffs filed their reply on November 20, 2023.  On January 8, 2024, the Court granted in part and denied in part the motion to amend.  Thereafter, Plaintiffs filed the Second Amended Consolidated Complaint for Violation of the Federal Securities Laws (the “Second Amended Complaint”) on January 9, 2024.  Defendants answered the Second Amended Complaint on January 22, 2024.

Plaintiffs and Defendants participated in a voluntary confidential mediation session with David M. Murphy (of Phillips ADR), an experienced mediator, on May 11, 2023.  The mediation session was preceded by submission of mediation statements by both Plaintiffs and Defendants (i.e., the Settling Parties).  The Settling Parties engaged in good faith negotiations but did not reach a settlement at the mediation session, and litigation continued.  The Settling Parties participated in a second mediation session with Mr. Murphy on April 18, 2024.  This second mediation session was preceded once again by the submission and exchange of supplemental mediation briefs and exhibits.  The Settling Parties engaged in good-faith negotiations but did not reach an agreement at the second mediation session.  Following additional settlement discussions, on April 29, 2024, the Settling Parties accepted a mediator’s proposal to settle the Litigation in return for a cash payment of $40 million to be paid by Defendants and/or their insurers on behalf of Defendants for the benefit of the Class, subject to the negotiation of the terms of a Stipulation of Settlement and approval by the Court.  The Stipulation (together with the Exhibits thereto) reflects the final and binding agreement among the Settling Parties.

Defendants deny each and all of the claims and contentions of wrongdoing alleged by Plaintiffs in the Litigation.  Defendants contend that they did not make any materially false or misleading statements, that they disclosed all material information required by the federal securities laws, and that they at all times acted in good faith.  Defendants also contend that any losses allegedly suffered by Members of the Class were not caused by any false or misleading statements by them and/or were caused by intervening events.  Defendants also maintain that they have meritorious defenses to all claims that were raised or could have been raised in the Litigation.

The Court has not decided in favor of Defendants or Plaintiffs.  Instead, both sides agreed to the Settlement to avoid the distraction, costs, and risks of further litigation, and Plaintiffs agreed to the Settlement in order to ensure that Class Members will receive compensation.

The Court directed that everyone who fits the description is a Class Member: All persons or entities who purchased or otherwise acquired Cabot common stock between February 22, 2016, and June 12, 2020, inclusive, and were damaged thereby.  Excluded from the Class are: (1) Defendants; (2) any directors and officers of Cabot during the Class Period and members of their immediate families; (3) the subsidiaries, parents, and affiliates of Cabot; (4) any firm, trust, corporation, or other entity in which Defendants have or had a controlling interest; and (5) the legal representatives, heirs, successors, and assigns of any such excluded party  Also excluded from the Class is any Person who properly excludes himself, herself, itself, or themselves from the Class by submitting a valid and timely request for exclusion.  To the extent any Cabot employee benefit plan receives a distribution from the Net Settlement Fund, no portion shall be allocated to any person or entity who is excluded from the Class by definition.

Please Note:  Receipt of the Notice or the Postcard Notice does not mean that you are a Class Member or that you will be entitled to receive a payment from the Settlement.  If you are a Class Member and you wish to be eligible to participate in the distribution of proceeds from the Settlement, you are required to submit a Proof of Claim and the required supporting documentation as set forth therein postmarked or submitted online on or before October 16, 2024.

If you are still not sure whether you are included in the Class, you can ask for free help.  You can contact the Claims Administrator toll-free at 877-495-5094, or you can fill out and return the Proof of Claim to see if you qualify.

The Settlement provides that, in exchange for the release of the Released Claims (defined below) and dismissal of the Litigation, Defendants and/or their insurance carriers on behalf of Defendants have agreed to pay or cause to be paid $40 million in cash to be distributed after taxes, tax expenses, notice and claims administration expenses, and Court approved attorneys’ fees and expenses, pro rata, to Class Members who send in a valid Proof of Claim pursuant to the Court-approved Plan of Allocation.  The Plan of Allocation is described in more detail at the end of the Notice.

Your share of the Net Settlement Fund will depend on several things, including the total dollar amount of claims represented by the valid Proofs of Claim that Class Members submit, compared to the dollar amount of your claim, all as calculated under the Plan of Allocation discussed on pages 14-19 of the Notice.

To be eligible to receive a payment from the Settlement, you must submit a Proof of Claim.  A Proof of Claim may be downloaded from the File a Claim page of this website. Read the instructions contained in the Proof of Claim carefully, fill out the Proof of Claim, include all the documents the form asks for, sign it, and mail it to the Claims Administrator at the address provided in the Proof of Claim or submit it online under the File a Claim page of this website so that it is postmarked or received no later than October 16, 2024.

The Court will hold a Settlement Hearing on October 28, 2024, at 2:00 p.m., to decide whether to approve the Settlement.  If the Court approves the Settlement, there might be appeals.  It is always uncertain whether appeals can be resolved, and if so, how long it will take to resolve them.  It also takes time for all the Proofs of Claim to be processed.  Please be patient.

If you are a Class Member, unless you timely and validly exclude yourself from the Class, you will remain a Class Member, and that means you cannot sue, continue to sue, or be part of any other lawsuit against Defendants or the other Released Defendant Parties about the Released Claims (as defined below) in this Litigation.  It also means that all of the Court’s orders will apply to you and legally bind you.  If you remain a Class Member, and if the Settlement is approved, you will give up all “Released Claims” (as defined below), including “Unknown Claims” (as defined below), against the “Defendants’ Released Persons” (as defined below):

• “Released Claims” means any and all claims and causes of action of every nature and description, whether known or unknown, asserted or unasserted, accrued or unaccrued, fixed or contingent, liquidated or unliquidated, whether arising under federal, state, local, common or foreign law, or any other law, rule or regulation, whether class or individual in nature, based on, arising out of, or in connection with both: (i) the purchase or acquisition of Cabot common stock during the period between February 22, 2016, and June 12, 2020, inclusive, and (ii) the allegations, acts, facts, matters, occurrences, disclosures, filings, representations, statements, or omissions that were or could have been alleged by Plaintiffs and other members of the Class in the Litigation.  “Released Claims” does not include claims to enforce the Settlement, or any derivative or ERISA claims, or the claims of any Person who submits a request for exclusion from the Class in connection with this Settlement that is accepted by the Court.  “Released Claims” includes “Unknown Claims” as defined below.
• “Released Defendants’ Claims” means any and all claims and causes of action of every nature and description whatsoever, including both known claims and Unknown Claims, against Plaintiffs, Plaintiffs’ Counsel, or any Class Member that arise out of or relate in any way to the institution, prosecution, or settlement of the claims against Defendants in the Litigation, except for claims relating to the enforcement of the Settlement.
• “Released Defendant Party” or “Released Defendant Parties” or “Defendants’ Released Persons” mean any or all of Defendants, and/or any or all of their related parties, including, without limitation, any and all of their current or former parents, subsidiaries, affiliates, predecessors, successors, divisions, funds, joint ventures, and general or limited partnerships, and each of their respective current or former officers, directors, trustees, partners, members, contractors, auditors, principals, agents, managing agents, employees, attorneys, accountants, investment bankers, commercial bankers, financial or investment advisors, consultants, advisors, underwriters, insurers in their capacities as such, as well as each of the Individual Defendants’ immediate family members, heirs, executors, personal or legal representatives, estates, beneficiaries, predecessors, successors, legatees, devisees, administrators, spouses, receivers and trustees, settlors, auditors, accountants, and assigns, as well as any trust of which any of the Defendants is the settlor or which is for the benefit of any of the Defendants and/or member(s) of his family, and any person, firm, trust, corporation, officer, director or other individual or entity in which any of the Defendants has a controlling interest or which is related to or affiliated with any of the Defendants.
• “Unknown Claims” means (a) any and all Released Claims which any of the Releasing Plaintiff Parties do not know or suspect to exist in his, her, or its favor at the time of the release of the Released Defendant Parties, which, if known by him, her, or it, might have affected his, her, or its settlement with and release of the Released Defendant Parties, or might have affected his, her, or its decision(s) with respect to the Settlement, including, but not limited to, whether or not to object to this Settlement or seek exclusion from the Class; and (b) any and all Released Defendants’ Claims that any of the Released Defendant Parties do not know or suspect to exist in his, her, or its favor at the time of the release of Plaintiffs, the Class, and Plaintiffs’ Counsel, which, if known by him, her, or it, might have affected his, her, or its settlement and release of Plaintiffs, the Class, and Plaintiffs’ Counsel.  With respect to (a) any and all Released Claims against the Released Defendant Parties, and (b) any and all Released Defendants’ Claims against Plaintiffs, the Class, and Plaintiffs’ Counsel, the Settling Parties stipulate and agree that, upon the Effective Date, the Settling Parties shall expressly waive, and each Releasing Plaintiff Party and Released Defendant Party shall be deemed to have, and by operation of the Judgment shall have expressly waived, the provisions, rights, and benefits of California Civil Code §1542, which provides:

A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party.

The Settling Parties shall expressly waive, and each Releasing Plaintiff Party and Released Defendant Party shall be deemed to have, and by operation of the Judgment shall have, expressly waived any and all provisions, rights, and benefits conferred by any law of any state or territory of the United States, or principle of common law, which is similar, comparable, or equivalent to California Civil Code §1542.  The Releasing Plaintiff Parties and Released Defendant Parties acknowledge that they may hereafter discover facts, legal theories, or authorities in addition to or different from those which he, she, it, or their counsel now knows or believes to be true with respect to the subject matter of the Released Claims or Released Defendants’ Claims, but (a) the Releasing Plaintiff Parties shall expressly fully, finally, and forever waive, compromise, settle, discharge, extinguish, and release, and each Releasing Plaintiff Party shall be deemed to have waived, compromised, settled, discharged, extinguished, and released, and upon the Effective Date, and by operation of the Judgment shall have waived, compromised, settled, discharged, extinguished, and released, fully, finally, and forever, any and all Released Claims against the Released Defendant Parties, known or unknown, suspected or unsuspected, contingent or non-contingent, accrued or unaccrued, whether or not concealed or hidden, which now exist, or heretofore have existed, or may hereafter exist, upon any theory of law or equity now existing or coming into existence in the future, including, but not limited to, conduct which is negligent, intentional, with or without malice, or a breach of any duty, law, or rule, without regard to the subsequent discovery or existence of such different or additional facts, legal theories, or authorities, and (b) the Released Defendant Parties shall expressly fully, finally, and forever waive, compromise, settle, discharge, extinguish, and release, and each Released Defendant Party shall be deemed to have waived, compromised, settled, discharged, extinguished, and released, and upon the Effective Date, and by operation of the Judgment shall have waived, compromised, settled, discharged, extinguished, and released, fully, finally, and forever, any and all Released Defendants’ Claims against Plaintiffs, the Class, and Plaintiffs’ Counsel, known or unknown, suspected or unsuspected, contingent or non-contingent, whether or not concealed or hidden, which now exist, or heretofore have existed, upon any theory of law or equity now existing or coming into existence in the future, including, but not limited to, conduct which is negligent, intentional, with or without malice, or a breach of any duty, law or rule, without regard to the subsequent discovery or existence of such different or additional facts, legal theories, or authorities.  The Settling Parties acknowledge, and the Releasing Plaintiff Parties and Released Defendant Parties shall be deemed by operation of the Judgment to have acknowledged, that the foregoing waiver was separately bargained for and is an essential element of the Settlement of which the release is a part.

If you do not want to participate in this Settlement, and you want to keep the right to potentially sue Defendants and the other Released Defendant Parties, on your own, about the claims being released by the Settlement, then you must take steps to remove yourself from the Class.  This is called excluding yourself – or is sometimes referred to as “opting out.”  If you are requesting exclusion from the Class because you want to bring your own lawsuit based on the matters alleged in this Litigation, you may want to consult an attorney and discuss whether any individual claim that you may wish to pursue would be time-barred by the applicable statutes of limitation or repose.  If requests for exclusion exceed a certain amount, as set forth in a separate confidential agreement between the Settling Parties, Defendants shall have, in their discretion, the option to terminate the Settlement in accordance with the procedures set forth in the Supplemental Agreement.

To exclude yourself from the Class and the Settlement, you must send a letter by First-Class Mail stating that you “request exclusion from the Class in the Cabot Oil Securities Litigation.”  Your letter must include your purchases or other acquisitions of Cabot common stock during the Class Period, including the dates and number of shares of Cabot common stock purchased, acquired, or sold, and price paid for each such purchase or acquisition and received for each such sale.  In addition, you must include your name, address, email address, telephone number, and your signature.  You must mail your exclusion request so that it is postmarked no later than October 3, 2024 to:

Cabot Oil Securities Litigation
Claims Administrator
c/o JND Legal Administration
EXCLUSIONS
P.O. Box 91217
Seattle, WA 98111

If you ask to be excluded, you will not get any payment from the Settlement, and you cannot object to the Settlement.  You will not be legally bound by anything that happens in this lawsuit, and you may be able to sue Defendants and the other Released Defendant Parties about the Released Claims in the future, if such claims are not time-barred.

No.  Unless you exclude yourself from the Class, you give up any rights you may potentially have to sue Defendants and the other Released Defendant Parties for any and all Released Claims.  If you have a pending lawsuit against any of the Released Defendant Parties, speak to your lawyer in that case immediately.  You must exclude yourself from the Class in this Litigation to continue your own lawsuit.  Remember, the exclusion deadline is October 3, 2024.

No.  If you exclude yourself from the Class, you should not send in a Proof of Claim to ask for any money from the Settlement.  But you may have the right to potentially sue or be part of a different lawsuit against Defendants and/or the other Released Defendant Parties.

The Court ordered that the law firms of Robbins Geller Rudman & Dowd LLP and Kessler Topaz Meltzer & Check, LLP represent the Class Members, including you.  These lawyers are called Class Counsel.  If you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel, on behalf of Plaintiffs’ Counsel, will apply to the Court for an award of attorneys’ fees not to exceed 33-1/3% of the Settlement Amount and for expenses, costs and charges in an amount not to exceed $1,750,000 in connection with the Litigation, plus interest on such fees and expenses at the same rate as earned by the Settlement Fund.  In addition, Plaintiffs may seek reimbursement for their time and expenses incurred in representing the Class.  Such sums as may be approved by the Court will be paid from the Settlement Fund.

You can tell the Court that you do not agree with the Settlement or any part of it.

If you are a Class Member, you can comment on or object to the proposed Settlement, the proposed Plan of Allocation and/or Class Counsel’s fee and expense application.  You can write to the Court setting out your comment or objection.  The Court will consider your views.  To comment or object, you must send a signed letter saying that you wish to comment on or object to the proposed Settlement in the Cabot Oil Securities Litigation.  Include your name, address, email address, telephone number, and your signature (even if you are represented by counsel), identify the date(s), price(s), and number of shares of Cabot common stock purchased, acquired, or sold during the Class Period, and state with specificity your comments or the reasons why you object to the Settlement, Plan of Allocation and/or fee and expense application, including any legal and evidentiary support for such objection.  Any objection must state whether it applies only to the objector, to a specific subset of the Class, or to the entire Class.  In addition, the objector must identify all class action settlements to which the objector or his, her, or its counsel have previously objected.  You must also include copies of documents demonstrating your purchases, other acquisitions, and/or sales of Cabot common stock during the Class Period.  Your comments or objection must be filed with the Court and mailed or delivered to each of the following addresses such that it is received no later than October 3, 2024:

Objecting is simply telling the Court that you do not like something about the Settlement.  You can object only if you stay in the Class.

Excluding yourself is telling the Court that you do not want to be paid and do not want to release any claims you think you may have against Defendants and the other Released Defendant Parties.  If you exclude yourself from the Class, you cannot object to the Settlement because it does not affect you.

The Court will hold a Settlement Hearing at 2:00 p.m., on October 28, 2024, in Courtroom 11B of the Honorable Lee H. Rosenthal, at the United States District Court for the Southern District of Texas, Bob Casey United States Courthouse, 515 Rusk Street, Houston, TX 77002.  At the hearing, the Court will consider whether the Settlement and the Plan of Allocation are fair, reasonable, and adequate.  If there are objections, the Court will consider them, even if the objectors do not ask to speak at the hearing.  The Court will listen to people who have asked to speak at the hearing.  The Court may also decide the amount of attorneys’ fees and expenses to award Class Counsel and Plaintiffs.  At or after the Settlement Hearing, the Court will decide whether to approve the Settlement and the Plan of Allocation.  We do not know how long these decisions will take.  You should be aware that the Court may change the date, time, and location of the Settlement Hearing without another notice being sent to Class Members.

There exists the possibility that the Court may decide to conduct the Settlement Hearing by video or telephonic conference, or otherwise allow Class Members to appear at the hearing by phone or video conference, without further written notice to the Class.  In order to determine whether the date and time of the Settlement Hearing have changed, or whether Class Members (who wish to attend the hearing) must or may participate by phone or video, it is important that you monitor the Court’s docket or this website before making any plans to attend the Settlement Hearing.  Any updates regarding the Settlement Hearing, including any changes to the date and time of the hearing or updates regarding in-person or remote appearances at the hearing, will be posted to this website.  Also, if the Court requires or allows Class Members to participate in the Settlement Hearing by telephone or video conference, the information for accessing the hearing will be posted to this website.  Accordingly, please continue to check this website for important updates.

No.  Class Counsel will answer any questions the Court may have.  But, you are welcome to come at your own expense.  If you are a Class Member and send an objection, you do not have to come to Court to talk about it.  As long as you are a Class Member and mailed your complete written objection on time, the Court will consider it.  You may also pay your own lawyer to attend the hearing, but it is not necessary.  Class Members do not need to appear at the hearing or take any other action to indicate their approval.

If you object to the Settlement, the Plan of Allocation, and/or the fee and expense application, you may ask the Court for permission to speak at the Settlement Hearing.  To do so, you must include with your objection (see “How do I tell the Court that I object to the proposed Settlement?” above) a statement saying that it is your “Notice of Intention to Appear in the Cabot Oil Securities Litigation.”  Persons who intend to object to the Settlement, the Plan of Allocation, and/or any attorneys’ fees and expenses to be awarded to Plaintiffs’ Counsel or Plaintiffs and desire to present evidence at the Settlement Hearing must include in their written objections the identity of any witnesses they may call to testify and exhibits they intend to introduce into evidence at the Settlement Hearing.  Your notice of intention to appear must be received no later than October 3, 2024, and addressed to the Clerk of Court, Class Counsel, and Defendants’ Counsel, at the addresses listed above under “How do I tell the Court that I object to the proposed Settlement?”

You cannot speak at the hearing if you exclude yourself from the Class.

If you do nothing, you will not receive any money from this Settlement.  In addition, unless you exclude yourself from the Class, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendants and the other Released Defendant Parties about the Released Claims in this case.

For even more detailed information concerning the matters involved in this Litigation, you can obtain answers to common questions regarding the proposed Settlement by contacting the Claims Administrator toll-free at 877-495-5094 or by email at info@CabotOilSecuritesLitigation.com.  Reference is also made to the Stipulation, to the pleadings in support of the Settlement, to the Orders entered by the Court and to the other settlement related papers filed in the Litigation, which are posted on the Important Documents page of this website, and which may be inspected at the Office of the Clerk of the United States District Court for the Southern District of Texas, during regular business hours.  For a fee, all papers filed in this Litigation are available at www.pacer.gov.

The Settlement provides $40 million in cash for the benefit of the Class.  The Settlement Amount and any interest it earns constitute the “Settlement Fund.”  The Settlement Fund, after deduction of Court-approved attorneys’ fees and expenses, Notice and Administration Expenses, Taxes, and any other fees or expenses approved by the Court, is the “Net Settlement Fund.”  If the Settlement is approved by the Court, the Net Settlement Fund will be distributed to eligible Authorized Claimants – i.e., Members of the Class who timely submit valid Proofs of Claim that are accepted for payment by the Court – in accordance with this proposed Plan of Allocation (“Plan of Allocation” or “Plan”) or such other plan of allocation as the Court may approve.  Class Members who do not timely submit valid Proofs of Claim will not share in the Net Settlement Fund but will otherwise be bound by the Settlement.  The Court may approve this proposed Plan of Allocation, or modify it, without additional notice to the Class.  Any order modifying the Plan of Allocation will be posted on the Important Documents page of this website.

The objective of the Plan of Allocation is to distribute the Settlement proceeds equitably among those Class Members who allegedly suffered economic losses as a proximate result of the alleged wrongdoing.  The Plan is not a formal damage analysis, and the calculations made in accordance with the Plan are not necessarily intended to be estimates of, or indicative of, the amounts that Class Members might have been able to recover after a trial.  Nor are the calculations in accordance with the Plan intended to be estimates of the amounts that will be paid to Authorized Claimants under the Settlement.  The computations under the Plan of Allocation are only a method to weigh, in a fair and equitable manner, the claims of Authorized Claimants against one another for the purpose of making pro rata allocations of the Net Settlement Fund.

The Plan of Allocation was developed in consultation with Plaintiffs’ damages expert.  In developing the Plan, the expert calculated the estimated amount of alleged artificial inflation in the per share prices of Cabot common stock that was allegedly proximately caused by Defendants’ alleged materially false and misleading statements and omissions during the Class Period.

In calculating the estimated artificial inflation allegedly caused by the misrepresentations and omissions, Plaintiffs’ damages expert considered price changes in Cabot common stock in reaction to the public disclosures that allegedly corrected the respective alleged misrepresentations and omissions, adjusting the price changes for factors that were attributable to market or industry forces, and for non‑fraud related, Cabot‑specific information.

In order to have recoverable damages in connection with purchases and/or acquisitions of Cabot common stock during the Class Period, disclosure of the alleged misrepresentations or omissions must be the cause of the decline in the price of the Cabot common stock.  In this case, Plaintiffs allege that Defendants made false statements and omitted material facts during the period from February 22, 2016, through and including the close of trading on June 12, 2020, which had the effect of artificially inflating the prices of Cabot common stock.  As a result of the alleged corrective disclosures, artificial inflation was removed from the price of Cabot stock on July 26, 2019 and June 15, 2020.  In order to have a “Recognized Claim Amount” under the Plan of Allocation, shares of Cabot common stock must have been purchased or otherwise acquired during the Class Period and held through a corrective disclosure.  Any transactions in Cabot common stock executed outside of regular trading hours for the U.S. financial markets shall be deemed to have occurred during the next regular trading session. 

For more details, please see the Plan of Allocation on pages 14-19 of the Notice.

Nominees who purchased or otherwise acquired Cabot common stock during the Class Period for beneficial owners who are Class Members are directed to: (i) request within seven (7) calendar days of receipt of the Notice sufficient copies of the Postcard Notice from the Claims Administrator to forward to all such beneficial owners; or (ii) send a list of the names and addresses (including email addresses if available) of such beneficial owners to the Claims Administrator within seven (7) calendar days after receipt of the Notice.  If a nominee elects to send the Postcard Notice to beneficial owners, such nominee is directed to email or mail (where an email is unavailable) the Postcard Notice within seven (7) calendar days of receipt of those documents from the Claims Administrator, and upon such emailing or mailing, the nominee shall send a statement to the Claims Administrator confirming that the emailing or mailing was made as directed, and the nominee shall retain the list of names and addresses for use in connection with any possible future notice to the Class.  Upon full compliance with these instructions, including the timely emailing or mailing of the Postcard Notice to beneficial owners, such nominees may seek reimbursement of their reasonable expenses actually incurred in complying with these instructions by providing the Claims Administrator with proper documentation supporting the expenses for which reimbursement is sought and reflecting compliance with these instructions.  Reasonable out of-pocket expenses actually incurred in connection with the foregoing includes up to $0.03 for providing names, addresses, and email addresses to the Claims Administrator per record; up to a maximum of $0.03 per Postcard Notice mailed by you, plus postage at the rate used by the Claims Administrator; or $0.03 per Postcard Notice sent by email.  Such properly documented expenses incurred by nominees in compliance with the terms of these instructions will be paid from the Settlement Fund.  Copies of the Notice may also be obtained by calling toll-free 877-495-5094, and may be downloaded from the Important Documents page of this website.

Cabot Oil Securities Litigation
Claims Administrator
c/o JND Legal Administration
P.O. Box 91217
Seattle, WA  98111