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Goodyear

GOODYEAR SETTLEMENT WEBSITE

www.goodyearERISAsettlement.com

Welcome to the Goodyear ERISA Settlement website. This website has been established to keep class members informed about the Class Action Settlement reached in In re The Goodyear Tire & Rubber Company ERISA Litigation, U.S. District Court, Northern District of Ohio Case No. 5:03-cv-2182.

Background

As described in more detail in the Consolidated Amended Complaint filed in the ERISA litigation, this lawsuit concerns allegations that Defendants breached fiduciary duties they purportedly owed to participants and beneficiaries in the Plan during the Class Period. The Defendants deny the allegations. Copies of Plaintiffs’ Consolidated Amended Complaint and other documents filed in the lawsuit are available via the Document Links on this website.

The Class

The Court has conditionally certified the following Settlement Class:

All persons who were participants in or beneficiaries of (a) The Goodyear Tire & Rubber Company Employee Savings Plan for Salaried Employees, or (b) The Goodyear Tire & Rubber Company Employee Savings Plan for Bargaining Unit Employees at any time between January 1, 1998 and December 12, 2007, and whose accounts included investments in Goodyear stock, excluding any Defendants or their immediate family members.

The Settlement

On December 12, 2007, the Court issued an order granting preliminary approval of the Settlement. At the Fairness Hearing, to be held on October 16, 2008 at 2:00 p.m. ET, the Court will decide, among other things: whether to approve the Settlement; whether to dismiss with prejudice the litigation against the Defendants pursuant to the Settlement Agreement; whether the notices and the means of dissemination of same complied with all applicable law; whether to approve the Plan of Allocation; whether to approve the applications for attorneys’ fees and expenses and compensation for Lead Plaintiffs.

As part of the Settlement, the Defendants agreed to pay the sum of $8,375,000 (Eight Million Three Hundred Seventy-Five Thousand Dollars) in cash from available insurance policies. After payment of and/or establishment of reserves for taxes, Court-approved costs, attorneys’ fees, and expenses (including any Court-approved compensation to be paid to Lead Plaintiffs), the Settlement proceeds will be paid to a Commingled Trust for the Plan. Once implementation expenses have been paid, the remaining amount will be allocated to the plan accounts of members of the Settlement Class according to a Plan of Allocation to be approved by the Court. If necessary, a subtrust will be created for those members of the Settlement Class who no longer have Plan accounts. In addition, the Settlement contains several non-monetary settlement terms relating to current and future plan participants.

For more information about the Settlement and the Fairness Hearing, see the Notice of Class Action Settlement.

You do not need to submit a claim form or any documentation. For inquiries on the settlement or to update your address, please send an email to the Settlement Plan Administrator at: claimsadministrator@goodyearerisa.com or call toll-free 1-888-299-1179.

Please DO NOT contact the Court or Goodyear Tire & Rubber Company regarding the Settlement. If you have any questions, please use the email address or toll-free number provided above.

Document Links
- Motion for Attorneys' Fees
- Notice of Class Action Settlement
- Summary Notice of Class Action Settlement
- Joint Status Report Regarding Settlement Administration
- Order Approving Amendment to Settlement Agreement
- Joint Motion to Amend Settlement Agreement
- Amendment to Class Action Settlement Agreement
- Preliminary Approval Order
- Plaintiffs’ Motion for Preliminary Approval of Proposed Settlement
- Class Action Settlement Agreement
- Consolidated Amended Complaint
- Motion for Final Approval of Settlement
- Proposed Order Approving Plan of Allocation