Baxter Securities Litigation
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Welcome to the Baxter International Inc. Securities Litigation Settlement Website

This website has been established to provide general information related to the proposed settlement of the Baxter International Inc. (“Baxter”) Securities Litigation. The capitalized terms used on this website, and not defined herein, shall have the same meanings ascribed to them in the Amended Settlement Agreement, dated August 27, 2015 (the “Settlement Agreement”), which can be found and downloaded by clicking on the Case Documents tab above. This is a securities class action that is pending before the Honorable John J. Tharp, Jr. at the United States District Court for the Northern District of Illinois (the “Court”), and the case is known as City of Lakeland Employees Pension Plan v. Baxter International Inc., et al., No. 1:10-cv-06016.

This litigation began on September 21, 2010, when a putative class action alleging violations of federal securities laws was filed in the Court. The Court appointed the law firm of Robbins Geller Rudman & Dowd LLP as Lead Counsel. On April 15, 2011, Lead Plaintiff filed the Amended Consolidated Class Action Complaint (the “Complaint”), that generally alleges, among other things, that during the Class Period, Defendants artificially inflate the Company’s stock price by misrepresenting and omitting material information concerning the true status of the remediation of the Company’s Colleague infusion pump devices and the state of and outlook of the Company’s plasma business. Lead Plaintiff avers that Defendants’ allegedly false and misleading statements and omissions artificially inflated the price of Baxter stock and when the truth was eventually disclosed, resulted in substantial damages to the Class.

The Complaint further alleges that Class Members purchased Baxter common stock during the Class Period at prices artificially inflated as a result of the Defendants’ dissemination of materially false and misleading statements, and asserts claims under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934, and Rule 10b-5 promulgated thereunder.Defendants deny each and all of the claims and contentions alleged by Lead Plaintiff in the litigation. Defendants contend that they did not make any false or misleading statement, that they disclosed all information required to be disclosed by the federal securities laws, and that any omitted or misstated information was not material. Defendants also contend that any losses suffered by members of the Class were not caused by any false or misleading statements by Defendants and/or were caused by intervening events.

The Class is defined as all persons who purchased or otherwise acquired Baxter common stock during the period from June 10, 2009 through and including May 3, 2010 (the “Class Period”).

In exchange for the Settlement and dismissal of the Action, Defendants have agreed that a payment of $42.5 million will be made by Defendants (or on their behalf) to be divided, after taxes, fees, and expenses, among all Class Members who send in a valid Proof of Claim Form.

The Court appointed the law firm of Robbins Geller Rudman & Dowd LLP represents the Class Members. These lawyers are called Lead Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense.

Although the information on this website is intended to assist you, it does not replace the information contained in the Notice of Pendency of Class Action and Proposed Settlement, Motion For Attorneys’ Fees and Settlement Fairness Hearing (the "Notice") and the Settlement Agreement, both of which can be found and downloaded from this website. We recommend that you read the Notice and other relevant case documents carefully.


SUBMIT A CLAIM FORM The only way to get a Payment. Proof of Claim Forms must be postmarked or submitted online on or before January 7, 2016.
EXCLUDE YOURSELF Get no payment. This is the only option that allows you to ever be part of any other lawsuit against the Defendants about the legal claims in this case. Exclusions must be postmarked on or before December 18, 2015.
OBJECT Write to the Court about why you do not like the Settlement. Objections must be sent to the Court and counsel postmarked on or before December 18, 2015.
GO TO A HEARING Ask to speak in Court about the fairness of the Settlement. Requests to speak must be sent to the Court and counsel postmarked on or before December 18, 2015.
DO NOTHING Get no payment. Give up your rights.


Submit a Claim Form: January 7, 2016
Request Exclusion: December 18, 2015
File an Objection: December 18, 2015
Court Hearing on Fairness of Settlement: January 22, 2016 at 1:00 p.m.