Compressors Ltd., Danfoss Scroll Technologies, LLC, Danfoss Turbocor Compressors,

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1 iupkmfesusf OF BRITISH COLUMBIA VfiNCOUVtR REGISTRY MAR ENTEHED No. S Vancouver Registry m the Supreme Court of British Columbia Between: DAMON GREEN Plaintiff and: TECUMSEH PRODUCTS OF CANADA LIMITED; TECUMSEH PRODUCTS CO.; TECUMSEH COMPRESSOR COMPANY; DANFOSS A/S; DANFOSS, INC.; DANFOSS COMMERCIAL COMPRESSORS LTD.; DANFOSS SCROLL TECHNOLOGIES, LLC.; DANFOSS TURBOCOR COMPRESSORS, INC.; DANFOSS COMPRESSOR, LLC; DANFOSS FLENSBURG GMBH; ACC USA LLC; APPLIANCES COMPONENTS COMPANIES Sp.A.; PANASONIC CORPORATION, PANASONIC CANADA INC.; WHIRLPOOL CANADA LP; EMBRACO NORTH AMERICA; and WHIRLPOOL CORPORATION Defendants BROUGHT UNDER THE CLASS PROCEEDINGS ACT, R.S.B.C. 1996, c. 50 ORDER MADE AFTER APPLICATION BEFORE THE HONOURABLE MADAM JUSTICE GROPPER ) 22/Jan/2016 M ON THE APPLICATION of the plaintiff, Damon Green coming on for hearing at the Courthouse, 800 Smithe Street, Vancouver, BC, on 22/Jan/2016 and on hearing David G.A. Jones and Julie Facchin counsel for the BC plaintiff, Damon Green, Jonathan Foreman, Kerry McGladdery Dent and Michela Gregory for the Ontario Plaintiff, Ontario Inc. operating as Zero Zone Mechanical, Brian A. Garneau and Maxime Blanchard for the Quebec Plaintiff, Emilien Chasse, William McNamara and Genevieve Bertrand for the defendants Tecumseh Products of Canada Limited, Tecumseh Products Co. and Tecumseh Compressor Company, Chris Naudie and Elizabeth Meloche for the defendants Danfoss A/S, Danfoss Inc., Danfoss Commercial Compressors Ltd., Danfoss Scroll Technologies, LLC, Danfoss Turbocor Compressors, { / } (h

2 -2- Inc., Danfoss Compressor, LLC, and Danfoss Flensburg GmbH, Emrys Davis and Vincent de i'etoiie for the defendants Panasonic Corporation and Panasonic Canada Inc., and Sandra Forbes and Nick Rodrigo for the defendants Whirlpool Canada LP, Embrace North America and Whirlpool Corporation and on reading the materials filed including the Distribution Protocol attached to this Order as Schedule "A"; and on judgement being reserved to February 12, THIS COURT ORDERS that: 1. For the purposes of this order, the definitions set out in the Distribution Protocol apply to and are incorporated into this order; 2. RicePoint Administration Inc. is appointed as Claims Administrator; 3. the Distribution Protocol shall govern the administration of the Settlement Agreements entered into with Danfoss Flensburg GmBH, dated June 18, 2015; Embrace North America, Inc., dated August 19, 2015; Panasonic Corporation and Panasonic Canada Inc., dated July 29, 2015; and Tecumseh Products of Canada Limited, Tecumseh Products Co., and Tecumseh Compressor Company, dated August 19, 2015 (collectively, the "Settlement Agreements"); 4. the settlement amount paid in accordance with the Settlement Agreements shall be distributed by the Claims Administrator in accordance with the Distribution Protocol; 5. the' publication, short-form and long-form notice of settlement approval and claims process (the "Approval and Claims Notice") are approved substantially in the forms attached hereto as Schedules "B" "0" and "D"; 6. the method of dissemination of the Approval and Claims Notice is hereby approved in the form attached hereto as Schedule "E"; 7. the claim form is approved substantially in the form attached hereto as Schedule "F"; 8. all information received from the Defendants or the Settlement Class Members is collected, used, and retained by the Claims Administrator pursuant to the Personal Information Protection and Electronic Documents Act, SC 2000 c 5 and may be used by the Claims Administrator for the sole purpose of administering the Settlement Agreements, including evaluating a Settlement Class Member's eligibility status under the Settlement Agreements and this distribution protocol. The sales information provided by Defendants and the information provided by Settlement Class Members is strictly private and confidential. Any identifying information about Settlement Class Members will be kept confidential and redacted from any materials filed with the Court as part of the settlement administration process, unless otherwise directed by the Court. Within a year of settlement benefits being paid to Settlement Class Members pursuant to this distribution protocol, the Claims Administrator will return or destroy the information received from Defendants or Settlement Class Members. Prior to being { / }

3 -3- appointed as Claims Administrator, the Claims Administrator will undertaking to abide by the obligations set out in this paragraph; execute an 9. subject to further orders of the Ontario Court, to be eligible for settlement benefits. Settlement Class Members must submit a complete and timely claim form to the Claims Administrator on or before the Claims Filing Deadline and any Settlement Class Member who fails to do so shall not share in any distribution made in accordance with the Distribution Protocol; 10. the Claims Administrator's decision will be final and binding and shall not be subject to any right of appeal or review; 11. this order is contingent upon parallel orders being made by the Ontario Court and the Quebec Court, and the terms of this order shall not be effective unless and until such orders are made by the Ontario Court and the Quebec Court; and 12. endorsement of this order by counsel for the defendants is dispensed with. THE FOLLOWING PARTIES APPROVE THE FORM OF THIS ORDER AND CONSENT TO EACH OF THE ORDERS, IF ANY, THAT ARE INDICATED ABOVE AS BEING BY CONSENT: ^ 'ML f^hature of lawyer for the Plaintiff )amon Green David G.A. Jones By the Court Registrar { / }

4 Schedule "A" DISTRIBUTION PROTOCOL IN THE MATTER OF THE COMPRESSOR AND COMPRESSOR PRODUCTS CLASS ACTION SETTLEMENTS INDEX GENERAL PRINCIPLES OF THE ADMINISTRATION 2 DEFINITIONS THE CLAIMS ADMINISTRATOR'S DUTIES AND RESPONSIBILITIES 5 SETTLEMENT BENEFITS AVAILABLE TO SETTLEMENT CLASS MEMBERS 7 THE CLAIMS PROCESS 12 The Claim The Online Claim Portal 13 The Claims Filing Process 14 Audits 15 Deficiencies 16 Claims Administrator's Decision 16 THE CLAIMS DISTRIBUTION PROCESS 17 CONFIDENTIALITY 18

5 -2- GENERAL PRINCIPLES OF THE ADMINISTRATION 1. The procedures set forth herein are intended to govern the administration of the settlement agreements entered into with the following Defendants: (a) Danfoss Flensburg GmBH on its behalf and on behalf of Danfoss A/S, Danfoss, Inc., Danfoss Commercial Compressors Ltd., Danfoss Scroll Technologies, LLC, Danfoss Turbocor Compressors, Inc., and Danfoss Compressor, LLC, dated January 22, 2015; (b) Tecumseh Products of Canada Limited, Tecumseh Products Co., and Tecumseh Compressor Company, dated August 19, 2015; (c) Panasonic Corporation and Panasonic Canada Inc., dated July 29, 2015; and, (d) Embraco North America, Inc. dated August 19, 2015 (collectively, the "Settlement Agreements")- 2. The definitions set out in the Settlement Agreements apply to and are incorporated herein. Where a term is defined in both the Settlement Agreements and in this Distribution Protocol, the definition in this Distribution Protocol shall govern. 3. The administration shall: (a) implement and conform to the Settlement Agreements, orders of the Court and this Distribution Protocol; (b) include the establishment and maintenance of the Settlement Website;

6 (c) employ secure, paperless, web-based systems with electronic registration and record keeping wherever possible; (d) rely on the Compressor and Compressor Products sales information provided by the Defendants wherever possible; and (e) be bilingual in all respects. 4. Excluded Persons as defined in the Settlement Agreements are not entitled to the payment of settlement benefits under this Distribution Protocol. 5. Settlement Class Members seeking compensation must disclose and give credit for any compensation received through other proceedings or private out-of-class settlements in relation to their Compressor and Compressor Product Purchases, unless by such proceedings or private out-of-class settlements the Settlement Class Member's claim was released in its entirety, in which case the Settlement Class Member shall be deemed ineligible for any further compensation. DEFINITIONS 6. For the purpose of this Distribution Protocol: (a) Claim means the paper or electronic form that a Settlement Class Member must complete and submit before the Claims Filing Deadline in order to be considered for settlement benefits under this Distribution Protocol. (b) Claims Filing Deadline means, subject to further order of the Court, the date by which Claims (and any required supporting documentation) must be postmarked

7 or electronically submitted in order for Settlement Class Members to be considered for settlement benefits under this Distribution Protocol. (c) Compressors and Compressor Product Purchases means the aggregate amount actually paid by Settlement Class Members for Compressors and Compressor Products purchased in Canada between January 1,2004 and December 31,2008. (d) Court means the Ontario Superior Court of Justice which shall have ongoing authority and supervision with respect to the Distribution Protocol. (e) Eligible Compressor Unit Purchases shall have the meaning attributed to it in paragraph 35(c). (f) Fonds Levy means the amounts payable to the Ponds d'aide aux recours collectifs pursuant to section 42 of An Act respecting the Class Action, R.S.Q., c. R-2.1 and calculated in accordance with the governing regulations. (g) Net Settiement Amounts mean the aggregate of the Settlement Amounts recovered pursuant to the Settlement Agreements and accrued interest after payment of court-approved Class Counsel Fees and after deduction of the Administration Expenses and all taxes (including interest and penalties) accruable with respect to the income earned by the Settlement Agreements. (h) Online Claim Portai means a web-based portal created and maintained by the Claims Administrator in accordance with paragraphs 21 to 24 of this Distribution Protocol. (i) Settlement Agreements has the meaning attributed to it in paragraph 1.

8 -5-0) Settlement Website means the website maintained by or on behalf of the Claims Administrator for the purposes of providing Settlement Class Members with information on the Settlement Agreements, the Distribution Protocol, and the claims process, and access to the Online Claim Portal. THE CLAIMS ADMINISTRATOR'S DUTIES AND RESPONSIBILITIES 7. The Claims Administrator shall administer the Settlement Agreements and this Distribution Protocol under the ongoing authority and supervision of the Court. 8. The Settlement Amounts shall be held in an interest bearing trust account at a Canadian Schedule 1 bank in Canada and all payments from the Settlement Amounts shall be made from that account. 9. The Claims Administrator's duties and responsibilities shall include the following: (a) providing notices to the Settlement Class Members as required pursuant to this Distribution Protocol; (b) receiving the Defendants' customer information, including names, addresses and sales information; (c) developing, implementing and operating electronic web-based systems and procedures for receiving and adjudicating Claims. The Claims Administrator shall encourage Settlement Class Members to claim via the Online Claim Portal where possible and shall facilitate this process;

9 -6- (d) developing and implementing processes to detect possible fraudulent conduct, including monitoring claims for unusual activity and multiple claims being filed from the same address, and using the same serial number; (e) making timely decisions in respect of Claims and notifying the Settlement Class Members of the decision promptly thereafter; (f) arranging payment to Settlement Class Members in a timely fashion after the Claims Filing Deadline; (g) dedicating sufficient personnel to respond to Settlement Class Members inquiries in English or French, as the Settlement Class Member elects; (h) submitting required materials for appeals; (i) remitting the Fonds Levy to the Fonds d'aide aux recours collectifs; G) arranging payments of Administration Expenses; (k) maintaining, in an easy to understand format, the information being recorded pursuant to paragraph 24 as well as information about Settlement Class Members' Eligible Compressor Unit Purchases and proposed distribution, so as to permit Class Counsel to audit the administration at the discretion of Class Counsel or if ordered by the Court; (1) reporting to Class Counsel respecting Claims received and administered, and Administration Expenses; (m) cash management and audit control;

10 -7- (n) preparing and submitting such financial statements, reports and records as directed by Class Counsel and/or the Court; and (o) fulfilling any tax reporting and arranging payments required arising from the Settlement Amounts, including any obligation to report taxable income and make tax payments. All taxes (including interest and penalties) due with respect to the income earned by the Settlement Amounts shall be paid from the Settlement Amounts. SETTLEMENT BENEFITS AVAILABLE TO SETTLEMENT CLASS MEMBERS 10. The Net Settlement Amounts will be available to provide settlement benefits to eligible Settlement Class Members pursuant to this Distribution Protocol. Settlement benefits payable to members of the Quebec Settlement Class will be subject to deductions in respect of the Fonds Levy. 11. Class Members shall prove their Compressors and/or Compressor Product Purchases in the following manner: (a) With reference to documentation in connection with their purchases of Compressors and/or Compressor Products: (i) sales information as provided by the Defendants where applicable; (ii) invoices; (iii) receipts; (iv) purchase records; (v) historical accounting records; or

11 (vi) comparable verification that is acceptable to the Claims Administrator; (b) By alternative proof, including a declaration together with documentation that evidences their purchases of Compressors and/or Compressor Products: (i) delivery or packing slips; (ii) credit card statements; (iii) bank statements; (iv) cancelled cheques; (v) wire transfer confirmations; (vi) proof of product registration; (vii) rebate documents; (viii) warranty documents; (ix) serial numbers; (x) repair invoices; or (xi) comparable verification that is acceptable to the Claims Administrator. 12. For the purpose of calculating payment of settlement benefits, each Compressor will be deemed to be one "Compressor Unit" and each Compressor Product will be deemed, unless a Settlement Class Member provides documentation to prove otherwise, to contain one Compressor Unit.

12 Eligible Compressors Unit Purchases will be valued as follows: (a) 100% of the price of the Compressors where the Settlement Class Member provides proof of purchase in accordance with paragraph 11(a); (b) 100% of the price of the Compressor component of the Compressor Product where the Settlement Class Member provides proof of purchase in accordance with paragraph 11(a) and the value of the Compressor component is specified in the documentation provided; and (c) $50 as a default unless the Settlement Class Member can otherwise demonstrate an acceptable basis for a higher value, where: (i) the Settlement Class Member provides proof of purchase in accordance with paragraph 11(a) and the value of the Compressor component is not specified; ^ (ii) where the Settlement Class Member provides proof of purchase in accordance with paragraph 11 (b). 14. Subject to paragraphs and 15-19, qualifying Settlement Class Members shall be entitled to a distribution calculated in the following manner:

13 - 10- Compressors Compressor Products Direct Purchasers (purchased directly from a Defendant or an entity related to a Defendant) 1. Purchased for own use and not for commercial resale Calculated by multiplying Eligible Compressor Unit Purchases by 3% Calculated by multiplying Eligible Compressor Unit Purchases by 2.5% 2. Purchased for straight resale Calculated by multiplying Eligible Compressor Unit Purchases by 0.8% Calculated by multiplying Eligible Compressor Unit Purchases by 0.6% 3. Purchased for use in providing repair services 4. Purchased to build into another product Calculated by multiplying Eligible Compressor Unit Purchases by 0.8% Calculated by multiplying Eligible Compressor Unit Purchases by 2.75% Calculated by multiplying Eligible Compressor Unit Purchases by 0.6% Calculated by multiplying Eligible Compressor Unit Purchases by 2.25% Indirect Purchasers (purchased from an entity other than a Defendant or an entity related to a Defendant) 5. Purchased for own use and not for commercial resale Calculated by multiplying Eligible Compressor Unit Purchases by 2.75% Calculated by multiplying Eligible Compressor Unit Purchases by 2.25% 6. Purchased for straight resale Calculated by multiplying Eligible Compressor Unit Purchases by 0.7% Calculated by multiplying Eligible Compressor Unit Purchases by 0.5% 7. Purchased for use in providing repair services 8. Purchased to build into another product Calculated by multiplying Eligible Compressor Unit Purchases by 0.7% Calculated by multiplying Eligible Compressor Unit Purchases by 2.5% Calculated by multiplying Eligible Compressor Unit Purchases by 0.5% Calculated by multiplying Eligible Compressor Unit Purchases by 2.1%

14 Should a Settlement Class Member's purchases of Compressors or Compressor Products not fit within one of the categories set out in paragraph 14, the Settlement Class Member shall be permitted to explain their Compressor and Compressor Product purchases and the Claims Administrator shall have the necessary discretion to evaluate and adjudicate compensation with respect to such potential claims. 16. If there is not sufficient Net Settlement Funds available to pay eligible Settlement Class Members in the percentages specified in paragraph 14, the settlement benefits payable to eligible Settlement Class Members shall be reduced pro-rata (i.e. proportionally) based on the value of the Settlement Class Member's Claim as a proportion of the value of all valid Claims. 17. If there are surplus Net Settlement Funds available after all eligible Settlement Class Members have been assigned the percentages specified in paragraph 14, the settlement benefits payable to eligible Settlement Class Members shall be increased pro-rata (i.e. proportionally) based on the value of the Settlement Class Member's Claim as a proportion of the value of all valid Claims. 18. Notwithstanding any other provision in this distribution protocol, subject to further order of the Court following the adjudication of all claims, no valid Settlement Class Member Claims will be paid less than $20. The $20 valuation target is not an estimate of any damages suffered. It is a minimum administrative threshold designed to maintain a feasible economic and administrative platform for the settlement distribution. If for any reason the $20 minimum payment cannot be feasibly made due to proration or other factors, Class Counsel will seek direction from the Ontario Court.

15 Notwithstanding any other provision in this distribution protocol, if the distribution would result in eligible Settlement Class Members receiving an amount that is beyond any reasonable estimate of expected damages or would otheiwise result in an unjust distribution, Class Counsel will seek further directions from the Court with respect to the distribution of the Net Settlement Funds. THE CLAIMS PROCESS The Claim 20. The Claim shall require the following: (a) information regarding the value of the Settlement Class Member's Compressor and Compressor Products Purchases. The Settlement Class Member can rely on defendant data (where available) or rely on its own purchase records; (b) information that will allow the Claims Administrator to determine the categorization of Compressor and Compressor Products Purchases pursuant to paragraph 14; (c) disclosure of whether the Settlement Class Member or any entity related to the Settlement Class Member has received compensation through other proceedings or private out-of-class settlements and/or provided a release in respect of any of the Settlement Class Member's Compressor and Compressor Product Purchases, and provide details of the compensation received and the claims released; (d) authorization to the Claims Administrator to contact the Settlement Class Member or its representative, as the Claims Administrator deems appropriate for more information and/or to audit the Claim;

16 - 13- (e) a declaration that the information submitted in the Claim is true and conect; and (f) such further and other infomiation as the Claims Administrator may require to process Claims. The Online Claim Portal 21. The Claims Administrator shall create an Online Claim Portal that Settlement Class Members can access in order to file a Claim and shall provide the necessary administrative support to enable Settlement Class Members to do so. 22. The Online Claim Portal shall be accessible from the Settlement Website. 23. The Online Claim Portal shall contain fields that require the Settlement Class Member to provide all applicable information required as part of the Claim, in accordance with paragraph 20 above. 24. The Claims Administrator shall develop procedures for tracking and recording in an electronic format the following information, as it is entered into the Online Claim Portal or provided by Settlement Class Members who file hardcopy Claims in accordance with paragraph 27 below: (a) names, addresses, and purchase data of the Settlement Class Members; (b) names and addresses, purchase data and supporting documents provided by Settlement Class Members as part of the claims and/or audit process; and (c) any other information that might be useful in the claims administration process.

17 - 14- The Claims Filing Process 25. Settlement Class Member will be encouraged to complete and submit a Claim (together with any required supporting documents) electronically using the Online Claim Portal. Subject to further order of the Court, Claims must be submitted on the Online Claim Portal on or before the Claim Filing Deadline. 26. Where a Settlement Class Member has been identified by the Defendants, the Claims Administrator shall provide to the Settlement Class Member, in writing, by or by regular mail, his, her or its personal user name and password to permit that Settlement Class Member access to the Online Claim Portal. Where the Defendants have also provided sales information in respect of the Settlement Class Member, the fields in the Online Claim Portal requiring the Settlement Class Member to provide the value of the Settlement Class Member's Compressor or Compressor Product Purchases shall be automatically populated with the sales information provided by the Defendants. 27. If a Settlement Class Member does not have internet access or is otherwise unable to submit a Claim using the Online Claim Portal, the Settlement Class Member can register over the telephone with the Claims Administrator and the Claims Administrator shall send the Settlement Class Member a hardcopy claim form by mail. Subject to further order of the Court, the completed and executed hardcopy Claim (together with any required supporting proof of purchase) must be submitted to the Claims Administrator postmarked no later than the Claims Filing Deadline. 28. At its sole discretion, the Claims Administrator can elect to audit any Claim and can reject a Claim, in whole or in part, where, in the Claims Administrator's view, the

18 - 15- Settlement Class Member has submitted insufficient or false information or has otherwise engaged in fraudulent conduct. Audits 29. The Claims Administrator shall audit all Claims where the Settlement Class Member has relied in whole or in part on its own purchase records, and the value of that portion of the Settlement Class Member's Eligible Compressor Unit Purchases exceeds $10,000 or such other amount as may be determined by the Claims Administrator. 30. The Claims Administrator shall conduct a random audit of at least 10% of Claims where the Settlement Class Member has relied in whole or in part on its own purchase records and where the value of that portion of the Eligible Compressor Unit Purchases is less than $10,000. At its sole discretion, the Claims Administrator can elect to audit additional Claims. 31. If a Settlement Class Member's Claim is audited, the Settlement Class Member must provide documentary proof of the Settlement Class Member's Compressor Unit Purchases, in accordance with paragraph The Claims Administrator shall notify the Settlement Class Member, by or by regular mail, that the Settlement Class Member's Claim is the subject of an audit and the requirement to provide documentary proof in accordance with paragraph 11. The Claims Administrator shall allow the Settlement Class Member thirty (30) days from the date of such notice to provide documentary proof. If documentary proof is not provided within the thirty (30) day period, the Claims Administrator shall reject the Claim, subject to the deficiency process identified in paragraph 33.

19 - 16- Deflciencies 33. If, during claims processing, the Claims Administrator finds that deficiencies exist in a Claim or other required information, the Claims Administrator shall notify the Settlement Class Member, by or regular mail, of the deficiencies. The Claims Administrator shall allow the Settlement Class Member thirty (30) days from the date of such notice to correct the deficiencies. If the deficiencies are not corrected within the thirty (30) day period, the Claims Administrator shall reject the Claim without prejudice to the right of the Settlement Class Member to cure the deficiencies, provided the Settlement Class Member is able to meet the Claims Filing Deadline and other requirements set forth herein. The Online Claim Portal shall be designed so as to minimize the possibility of deficient claims. 34. A deficiency shall not include missing the Claims Filing Deadline. Subject to further order of the Court, the Claims Administrator shall not accept Claims postmarked or electronically submitted after the Claims Filing Deadline. Claims Administrator's Decision 35. In respect of each Settlement Class Member who has filed a Claim in accordance with this Distribution Protocol, the Claims Administrator shall: (a) decide whether the Settlement Class Member is eligible to receive settlement benefits payable out of the Net Settlement Amounts in accordance with the Settlement Agreements, orders of the Court and this Distribution Protocol; (b) verify the Settlement Class Member's Compressor or Compressor Product Purchases;

20 -17- (c) make a determination of the value of the Settlement Class Member's Compressor Units in respect of which the Settlement Class Member is entitled to settlement benefits in accordance with the Settlement Agreements, orders of the Court and this Distribution Protocol ("Eligible Compressor Unit Purchases"); and (d) make a determination of the appropriate categorization of the Eligible Compressor Unit Purchases pursuant to paragraph The Claims Administrator shall send to the Settlement Class Member, by or regular mail, a decision as to the approval or rejection of the Claim and the determination of the Eligible Compressor Unit Purchases and their categorization. Where the Claims Administrator has rejected all or part of the Claim of the Settlement Class Member, the Claims Administrator shall include its grounds for rejecting all or part of the Claim. 37. The Claims Administrator's decision shall be final and binding upon the Settlement Class Member. THE CLAIMS DISTRIBUTION PROCESS 38. As soon as practicable after the claims evaluations, the Claims Administrator shall make arrangements to pay approved Claims as expeditiously as possible. Payments of settlement benefits to Settlement Class Members will be made by cheque. 39. To the extent that the full Net Settlement Amounts is not paid out due to uncashed cheques, residual interest or otherwise, such monies shall be paid to the Homestart Foundation for the general benefit of Settlement Class Members if the amount is equal to or less than $10,000. For distribution of any amount above $10,000, further direction of the Court shall be sought.

21 - 18- CONFIDENTIALITY 40. All information received from the Defendants or the Settlement Class Members is collected, used, and retained by the Claims Administrator pursuant to the Personal Information Protection and Electronic Documents Act, SC 2000 c 5 and may be used by the Claims Administrator for the sole purpose of administering the Settlement Agreements, including evaluating a Settlement Class Member's eligibility status under the Settlement Agreements and this distribution protocol. The sales information provided by Defendants and the information provided by Settlement Class Members is strictly private and confidential. Any identifying information about Settlement Class Members will be kept confidential and redacted from any materials filed with the Court as part of the settlement administration process, unless otherwise directed by the Court. Within a year of settlement benefits being paid to Settlement Class Members pursuant to this distribution protocol, the Claims Administrator will return or destroy the infonnation received from Defendants or Settlement Class Members. Prior to being appointed as Claims Administrator, the Claims Administrator will execute an undertaking to abide by the obligations set out in this paragraph.

22 DID YOU PURCHASE A COOLING COMPRESSOR, FREEZER OR FRIDGE? Schedule "B" Did you purchase cooling compressors or products containing cooling compressors (including household refrigerators If so, you could be entitled to compensation as part ot class action settlements. To receive compensation, apply online at no later than Weekday, Month DD, YYYY SISKINDS T H E LAW nsm For more information visit or call

23 DID YOU PURCHASE A COOLING COMPRESSOR, FREEZER OR REFRIGERATOR BETWEEN 2004 AND 2008? Schedule "C IF SO, APPLY NOW TO RECEIVE MONEY FROM CLASS ACTION SETTLEMENTS WHAT IS A CLASS ACTION? A class action is a lawsuit filed by one person on behalf of a large group of people. have settled for more than $4.6 million. The settlements are a compromise of disputed claims and are not an admission of liability. AM I ELIGIBLE TO RECEIVE MONEY? You are eligible to receive money if, between 2004 and 2008, you purchased; a cooling compressor (defined as a hermetically sealed cooling compressor of less than one horse power). Cooling compressors used in air conditioners are excluded; and/or a product that contains a cooling compressor (including household and some light commercial refrigerators and freezers). You can claim for any brand of cooling compressor product. HOW MUCH MONEY WILL I RECEIVE? Payments wi l l be based on a number of factors including: (i) the value of the compressor; (ii) who the compressor was purchased from; and (iii) purpose of the compressor purchase. See [website] for more information. It is expected that a minimum administrative payment of $20 will be made to all Settlement Class Members who submit a valid request for payment. DO I NEED PROOF OF PURCHASE? Proof of purchase is not required unless your request for payment is selected for an audit. If your request for payment is chosen for audit, you wi l l be required WHAT IS THIS CUSS ACTION ABOUT?. to provide proof of purchase. A cooling compressor is a component in many household and some light commercial refrigerators and freezers that provides the cooling function. Class action lawsuits were commenced in Ontario, British Columbia, and Quebec alleging that the defendants conspired to fix the price of cooling compressors (excluding cooling HOW DO I REQUEST A PAYMENT? compressors used in air conditioners). The class actions Requests can be submitted online at DOES IT COST ANYTHING TO REQUEST A PAYMENT? No, does not cost anything to request a payment. Counsel fees will be paid out of the settlement funds. If you do not have internet access, call the claims administrator at xxx-xxx-xxxx. WHAT DATE MUST I REQUEST MY PAYMENT BY? Requests for payments must be made no later than month, day, WHEN WILL I RECEIVE MY MONEY? Accurate processing takes time. Depending on the number of applications filed it could be up to one year before you receive compensation. Please check for regular updates. YOU ARE REPRESENTED BY: Siskinds LLP and Harrison Pensa LLP London, ON Camp Fiorante Matthews Mogerman Vancouver, BC Bouchard Page Tremblay Avocats Quebec City, QC HAVE MORE QUESTIONS? Visit us at address@domain.com or call XXX.XXXX xxxxx

24 Schedule "D" DID YOU PURCHASE A COOLING COMPRESSOR, FREEZER PLEASE READ THIS NOTICE CAREFULLY. IT MAY AFFECT YOUR LEGAL RIGHTS. IMPORTANT DEADLINE: Settlement Class members who wish to apply for compensation must submit claims by. See page 3 for more details. WHO IS AFFECTED BY THIS NOTICE? This notice applies to all persons in Canada who between January 1, 2004 and December 31, 2008 purchased hermetically sealed cooling compressors of less than one horsepower, excluding those used in air conditioners ("Cooling Compressors") and products containing Cooling Compressors, excluding air conditioners ("Cooling Compressor Products") in Canada, except the Defendants and certain parties related to the Defendants ("Settlement Class"). WHAT IS A CLASS ACTION? A class action is a lawsuit filed by one person on behalf of a large group of people. WHAT IS THIS CLASS ACTION ABOUT? Class action lawsuits were commenced in Ontario, British Columbia, and Quebec alleging that the Defendants conspired to fix prices in the market for Cooling Compressors (collectively, the "Class Actions"). Cooling Compressors means hermetically sealed cooling compressors of less than one. horsepower. Cooling Compressor Products means products containing Cooling Compressors. A Cooling Compressor is the component in many household and some light commercial refrigerators and freezers that provides the cooling function. Air conditioners, as well as cooling compressors used in them, are excluded. The following entities were named as Defendants in one or more provinces in the Class Actions: Tecumseh Products of Canada Limited, Tecumseh Products Co., Tecumseh Compressors Company, Danfoss A/S, Danfoss Inc., Danfoss Commercial Compressors Ltd., Danfoss Scroll Technologies, LLC, Danfoss Turbocor Compressors, Inc., Danfoss Compressors LLC, Appliances Components Companies S.p.A., ACC USA LLC, Panasonic Corporation, Panasonic Canada Inc., Whirlpool Canada LP, Embraco North America, Inc. and Whirlpool Corporation. The Defendants are manufacturers of Cooling Compressors or Cooling Compressor Products. WHAT ARE THE DETAILS ABOUT THE SETTLEMENTS THAT HAVE BEEN REACHED? Settlements have been reached with Appliances Components Companies S.p.A., ACC USA LLC, (collectively "ACC"), Danfoss Flensburg GmbH ("Danfoss Flensburg") (who at the time of settlement was not a party to the proceedings), Embraco North America, Inc. ("Embraco"), Panasonic Questions? Go to [ ] or call toll-free [number]

25 Corporation and Panasonic Canada Inc. (collectively "Panasonic"), and Tecumseh Products of Canada Limited, Tecumseh Products Co., and Tecumseh Compressor Company (collectively "Tecumseh") (collectively the "Settling Defendants"). The settlements have resolved the litigation in its entirety. Under the terms of the settlements, the following amounts have been paid in exchange for a release against the Settling Defendants and their related entities; Defendant Group ACC Danfoss Flensburg Settlement Amount $50,000, plus up to $50,000 towards the cost of notice $300,000, plus $100,000 towards the cost of notice and administration Embraco $1,400,000 Panasonic $2,350,000 Tecumseh $620,000 The settlements were approved by the Ontario, British Columbia and Quebec Courts. The settlements represent a resolution of disputed claims. The Settling Defendants do not admit, and expressly deny, any wrongdoing or liability. The Class Actions were certified against the Settling Defendants for settlement purposes. The Danfoss Flensburg, Embraco, Panasonic and Tecumseh settlement amounts (less court approved counsel fees and disbursements) are being held in an interest bearing account for the benefit of settlement class members. The ACC settlement funds were used to fund out-of-pocket costs incurred by class counsel in the litigation. HOW WILL THE SETTLEMENT MONIES BE PAID OUT? The Danfoss Flensburg, Embraco, Panasonic and Tecumseh settlement amounts total $4,770,000. The aggregate settlement amounts, plus interest and less court approved legal fees, disbursements, administration expenses, and applicable taxes (the "Net Settlement Amount"), are available for compensation to settlement class members. The Net Settlement Amount equals approximately $3.2 million. The Ontario, British Columbia and Quebec Courts approved a protocol for distributing the Net Settlement Amount. A copy of the distribution protocol is available at [settlement website]. The protocol is designed to compensate direct and indirect purchasers of Cooling Compressors and Cooling Compressor Products in a manner that generally reflects the Plaintiffs anticipated impact of the alleged price-fixing. For the purposes of the distribution protocol, where the Settlement Class Member is able to provide documentation establishing the price of the compressor (whether as a standalone product or a component of another product), the compressor will be valued at that price. In all other circumstances, the compressor will be valued at $50. Questions? Go to [ ] or call toll-free [number]

26 -3- After the value of the compressor is established, settlement benefits will be distributed based on a percentage of that value. The applicable percentage varies between 0.5% to 3%. The applicable percentages are set out on page 9 of the distribution protocol and depend on the following factors: 1. whether the Settlement Class Members: a. purchased directly from a Defendant or an entity related to a Defendant; or b. purchased from some other entity 2. the purpose of the purchase: a. purchased for a Settlement Class Member's own use and not for commercial resale; b. purchased for straight resale; c. purchased for use in providing repair services; or d. purchased to build into another product. Notwithstanding the foregoing, subject to further order of the Ontario Court, all valid claims will be assigned a minimum administrative value of $20. This includes end consumers who submit a claim for the purchase of a household refrigerator or freezer. If there is not sufficient funds to pay eligible Settlement Class Members the percentages specified on page 9 of the distribution protocol, the settlement benefits payable to eligible Settlement Class Members will be reduced pro-rata (i.e. proportionally) based on the value of the Settlement Class Member's claim as a proportion of the value of all valid claims. Similarly, if there are surplus funds available after all eligible Settlement Class Members have been paid the percentages specified on page 9 of the distribution protocol, the settlement benefits payable to eligible Settlement Class Members will be increased pro-rata (i.e. proportionally) based on the value of the Settlement Class Member's claim as a proportion of the value of all valid claims. Payments to Quebec Settlement Class Members are subject to deductions payable to the Fonds d'aide aux recours collectifs, calculated in accordance with the governing regulations. If the distribution would result in an unfair result to some or all settlement class members, further directions will be sought from the Ontario Court. If there are remaining settlement funds after all valid claims are paid, the excess (up to $10,000) will be paid to the HomeStart Foundation. HomeStart is a furniture bank that provides essential home furnishings to people in need in the metro Vancouver area. HomeStart will use the funds to purchase and deliver compact refrigerators to clients including women and children escaping domestic violence, children aging out of foster care and people with physical and mental health disabilities. For distribution of any amount above $10,000, further direction of the Ontario Court shall be sought. HOW DO I APPLY TO RECEIVE SETTLEMENT FUNDS? Settlement Class Members who wish to apply for compensation under the settlements must file a clairn. no later than #. Subject to further order of the Ontario Court, claims that are not made within the deadline will not be eligible for compensation. Claims must be filed using the online claims process at [website]. If you do not have Internet access, but wish to file a claim, please contact the claims administrator at [phone number]. Questions? Go to [ ] or call toll-free [number]

27 -4- Some claims will be selected for audit, if your claim is chosen for audit, you must provide proof of purchase. WHO ARE THE LAWYERS WORKING ON THE CLASS ACTION AND HOW ARE THEY PAID? The law firms of Harrison Pensa and Siskinds represent Settlement Class Members in Ontario and in all provinces other than British Columbia and Quebec, as well as corporations of more than 50 employees in Quebec. Siskinds can be reached at ext or Harrison Pensa can be reached at ext.775 or The law firm of Camp Fiorante Matthews Mogerman ("CRM") represents Settlement Class Members in British Columbia. CRM can be reached at or The law firm of Bouchard Pag6 Tremblay Avocats represents individuals and corporations of 50 or less employees who are Settlement Class Members in Quebec. Quebec class counsel can be reached at or You do not need to pay out-of-pocket for the lawyers working on the class action. The lawyers will be paid from the settlement funds in an amount approved by the court. INTERPRETATION This notice contains a summary of some of the terms of the settlement agreements. If there is a conflict between the provisions of this notice and the settlement agreements, the terms of the settlement agreements shall prevail. This notice has been authorized by the Ontario, British Columbia, and Quebec courts. QUESTIONS? Visit [website], [ ] or call [phone number! Questions? Go to [ ] or call toil-free [number]

28 Schedule "E" PLAN OF DISSEMINATION NOTICE OF APPROVAL AND CLAIMS PROCESS IN THE MATTER OF COOLING COMPRESSORS CLASS ACTION LITIGATION The Notice of Approval and Claims Process will be distributed in the following manner: Publication Notice: 1. Published once in the following newspapers, no larger than 1/8 newsprint page, in either English or French, as is appropriate for each newspaper, subject to each having reasonable publication deadlines and costs: (a) (b) The Globe and Mail (National Edition); and Le Journal de Montreal. Short-Form Notice 2. Sent to the following industry associations, in English and French, requesting voluntary distribution to their membership and/or that a copy of the notice or information about the actions be posted on their website: (a) (b) (c) (d) (e) (f) (g) (h) (i) Association of Independent Compressor Distributors ("AICD"); Heating, Refrigeration and Air Conditioning Institute of Canada ("HRAI"); Installation, Maintenance & Repair Sector Council and Trade Association ("IMR"); Mechanical Contractors Association of Canada ("MCA Canada"); Refrigeration Service Engineers Society Canada ("RSES"); Electro-Federation Canada ("EFC"); Retail Council of Canada; Conseil quebecois du commerce de detail (Quebec Council of Retail Trade); and Industry associations servicing condominium or apartment building developers, as identified in Schedule "A" hereto.

29 -2-3. Sent by direct mail or , within seven days of the first publication of the Publication Notice, to anyone who has inquired with class counsel regarding the class action, to the extent that class counsel has their name and address information. Where the person is located in Quebec, the notice will be sent in English and French. 4. Sent by direct mail, within seven days of the first publication of the Publication Notice, to the direct purchaser customers in Canada (where applicable) of Appliances Components Companies S.p.A. and ACC USA LLC (collectively "ACC"); Danfoss Flensburg GmbH ("Danfoss") and Danfoss Inc. (Canada); Embraco North America, Inc. ("Embraco"); Panasonic Corporation and Panasonic Canada Inc. (collectively "Panasonic"); Tecumseh Products of Canada Limited, Tecumseh Products Co. and Tecumseh Compressor Company (collectively "Tecumseh") based on the customer information provided by these entities pursuant to the terms of ACC, Danfoss, Embraco, Panasonic and Tecumseh settlement agreements, provided that such information is provided in a timely manner. Where the person is located in Quebec, the notice will be sent in English and French. 5. Sent by direct mail, within seven days of the first publication of the Publication Notice, to the: (a) (b) (c) (d) retailers identified in Schedule "B" hereto; refrigerator repair shops identified in Schedule "C" hereto; distributors of household refrigerators identified in Schedule "D" hereto; and hotel chains identified in Schedule "E" hereto. Long-Form Notice: 6. Posted in English and French by class counsel on class counsel's respective websites and on the website created by the Claims Administrator for the purpose of this litigation. Digital Notice: 7. Notice will be posted online on 8. The Claims Administrator will create and monitor a forum on for one month.

30 Schedule "A" Industry Associations Servicing Condominium or Apartment Building Developers Canadian Condominium Institute Chapters CCI - Vancouver Chapter CCI Eastem Ontario Chapter CCI - North Alberta Chapter CCI - Golden Horseshoe Chapter CCI - South Alberta Chapter CCI - Huronia Chapter CCI - N Saskatchewan Chapter CCI Windsor-Essex County Chapter CCI - S Saskatchewan Chapter CCI - Northwestern Ontario Chapter CCI - Manitoba Chapter CCI - Nova Scotia Chapter CCI - Toronto and Area Chapter CCI - Newfoundland & Labrador Chapter CCI - London & Area Chapter CCI - New Brunswick Chapter CCI - National Canadian Home Builders' Associations CHBA National Office Manitoba HBA British Columbia CHBA - BC CHBA - Fraser Valley CHBA - Central Interior CHBA - Central Okanagan CHBA - Vancouver Island CHBA - Northern BC CHBA - Rocky Mountain CHBA - Sea to Sky CHBA - South Okanagan Greater Vancouver HBA

31 2- Alberta CHBA - Alberta CHBA - Calgary Region CHBA - Central Alberta CHBA - Edmonton Region CHBA - Grand Prairie Region CHBA - Lethbridge Region CHBA - Medicine Hat Region Saskatchewan CHBA - Saskatchewan Regina & Region HBA Saskatoon & Region HBA Ontario Ontario Home Builders' Association Brantford HBA BILD (Greater Toronto Area) Bluewater Builders' Association Chatham-Kent HBA Durham Region HBA Greater Dufferin HBA Greater Ottawa HBA Grey-Bruce Home Builders & Trades Association Guelph & District HBA Hamilton-Halton HBA Lanark-Leeds HBA Kingston Frontenac HBA London HBA Niagara HBA North Bay & District HBA Oxford Country Builders' Association Peterborough & The Kawarthas HBA Quinte HBA Renfrew County HBA Samia-Lambton HBA Saugeen Home Builders Trade Association

32 -3 Simcoe County HBA St. Thomas & Elgin HBA Stratford & Area Builders' Association (SABA) Sudbury & District HBA Thunder Bay HBA Waterloo Region HBA Greater Windsor HBA Nova Scotia Nova Scotia Home Builders' Association Annapolis Valley HBA Cape Breton HBA CHBA of Central Nova CHBA - South Shore New Brunswick CHBA - New Brunswick CHBA - Greater Fredericton Greater Moncton HBA CHBA - Saint John Region CHBA - Sussex CHBA - Prince Edward Island CHBA - Newfoundland and Labrador Other Associations Canadian Federation of Apartment Associations Greater Toronto Apartment Association The Federation of Rental Housing Providers of Ontario Association of Condominium Managers of Ontario Ontario Condominium Owners Association Condo Owners Association Toronto The Condominium Home Owners Association of B.C. National Association of Condominium Managers Association of Condominium Managers of Alberta Building Industry and Land Development Association Eastern Ontario Landlord Organization Hamilton and District Apartment Association London Property Managers Association

33 4- Saskatchewan Landlord Association Ottawa Region Landlords Waterloo Regional Apartment Management Association Investment Property Owners Association of Nova Scotia Professional Property Managers Association BC Apartment Owners and Managers Association Rental Owners and Managers Society of BC Calgary Residential Rental Association Edmonton Apartment Association Alberta Residential Landlord Association New Brunswick Apartment Owners Association Modular Housing Association Prairie Provinces Canadian Urban Institute Real Property Association of Canada Ontario Real Estate Association Building Owners and Managers Association of Canada Building Owners and Managers Association of BC Building Owners and Managers Association of Calgary Building Owners and Managers Association of Edmonton Building Owners and Managers Association of Quebec British Columbia Real Estate Association Urban Development Institute Calgary Pacific Region Edmonton

34 Schedule "B" Retailers Company Address Suite Number City Province Postal Code Phone Number Fax Number Hudson's Bay Company 401 Bay Street 500 Toronto ON M5H 2Y4 Sears 290 Yonge Street 700 Toronto ON M5B 2C Canadian Tire 2180 Yonge Street P.O. Box 770, Station K Toronto ON M4P 2V Home Hardware 34 Heniy Street West St. Jacob's ON NOB 2N Leon's Furniture Limited 45 Gordon Mackay Road Toronto ON M9N 3X Home Depot 1 Concorde Gate 900 North Yoric ON M3C 4H Rona Inc. 220 chemin du Tremblay Boucherville QC J4B8H Lowe's 5160 Yonge Street 200, Box 25 North York ON M2N6L Costco 415 West Hunt Club Road Ottawa ON K2E1C Best Buy / Future Shop Ltd Glenlyon Parkway Bumaby BC V5J 5K Walmart 1940 Argentia Road Mississauga ON L5N 1P

35 Schedule "C" Page 1 Refrigerator Repair Shops Suite Postal Company Name Address Number City Province Code Phone Number Fax Number AAA Ok Trading & Repairs 185 Highway 33 E Kelowna BC V1X2A1 (250) Not Available Act Inc 121 Garden Grove Rd Lincoln NB E3B7G8 (506) Not Available Air Medic Climate Control 263 Corless Cres Prince George BC V2M5X7 (250) Not Available Air Wise Inc 486 Main St Stonewall MB R0C2Z0 (204) (204) Air Wise Inc 332 Keewatin St Winnipeg MB R2X2R9 (204) Not Available Alliance Enterprises Ltd 35 Boulder Bivd 30 Stony Plain AB T7Z1V6 (780) (780) Amre Supply Co Ltd 6080 Russ Baker Way 115 Richmond BC V7B1B4 (604) (604) Archie Johnstone PIbg & Htg 113 Gava PI Nanaimo BC V9T0H9 (250) Not Available Archie Johnstone PIbg & Htg 734 Tyee Rd Victoria BC V9A6X3 (250) Not Available Asian Electrical Plumbing Gas Ave Vernon BC V1T7X8 (250) Not Available Awl Tec Heating Ac & Refrig 1921 Antonelli Rd Campbell River BC V9W4R6 (250) (250) B & C Refrigeration & Air Cond 46220b Yale Rd Chilliwack BC V2P2P3 (604) Not Available Benner's Refrigeration & Heat 8695th Ave Prince George BC V2L3K5 (250) (250) Braun Industrial 3835 Broadway Smithers BC V0J2N0 (250) (250) Brindamour Ventilation Dr 135 Rue D'Amsterdam D St-Augustin-Dsmr QC G3A2V5 (418) Not Available Buckhorn Heating & Air Cond 7029 Southridge Ave Prince George BC V2N4Y6 (250) (250) Budget Appliance Ltd Ave Surrey BC V3T2K2 (604) Not Available Canadian Refrigeration & Ac 5279 Still Creek Ave 3A Burnaby BC V5C5V1 (604) (604) Canadian Western Mechanical 884 Front St Quesnel BC V2J5Y3 (250) (250) Carmichael Fairchild Mayfield PI 130 Richmond BC V6V2G9 (604) (604) Carmichael Limited 3822 Av De Courtrai Montreal QC H3S1C1 (514) Not Available Chill-Air Conditioning Ltd Yale Rd Chilliwack BC V2R3Z9 (604) Not Available Cimco Refrigeration 1095 Cliveden Ave Delta BC V3M6G9 (604) (604) Cimco Refrigeration 64 Devonshire Dr New Hamburg ON N3A4J7 (519) Not Available City Wide Applaince Co Ltd 1040 Arlington St Winnipeg MB R3E2G2 (204) Not Available Coastal Energy Ltd 1810 Fremont Rd B Nanaimo BC V9S3H4 (250) Not Available Combined Appliance Ctr 1395 Pemberton Ave North Vancouver BC V7P2R6 (604) Not Available Coppertec Refrigeration Htg 134 Estabrook Ave Penticton BC V2A1G3 (250) Not Available Coral Environments Ltd 2300 Hunter Rd Kelowna BC V1X6C1 (250) Not Available

36 Page 2 Company Name Address Refrigerator Repair Shops Suite Number City Province Postal Code Phone Number Fax Number Custom Air Conditioning 1835 Broadway St Port Coquitlam BC V3C4Z1 (604) Not Available Duke Refrigeration & Hvac Ltd b St 102 Langley BC V1M3G3 (604) Not Available Dynamic Refrigeration 1475 Fairview Rd 106 Penticton BC V2A7W5 (250) Not Available Emerald Green Mechanical Ltd a Ave Surrey BC V4P1N7 (604) Not Available Enviro Tech Mechanical Svc 3700 North Fraser Way 182 Burnaby BC V5J5H4 (604) (604) Evenflow Refrigeration & Ac a Ave 503 Surrey BC V3S2A7 (604) (604) Fairmont Refrigeration & Htg St E Calgary AB T2X2X7 (403) Not Available Falcon Refrigeration & Ac 1556 Klein Rd West Kelowna BC V1Z3H5 (250) Not Available Fehling's Sheet Metal Ltd 560 Okanagan Ave E Penticton BC V2A3K5 (250) (250) Fraser Valley Refrigeration Fraser Hwy Aldergrove BC V4W2W8 (604) (604) Future Climates Refrigeration b St 213 Langley BC V1M3G3 (604) (604) G Cantin Inc 1468 Rue Graham-Bell 101 Boucherville QC J4B6H5 (450) (450) Gateway Mechanical Svc St 206 Surrey BC V4N3N2 (250) (604) Giddens Services 1613 Valleyview Dr Kamloops BC V2C4B4 (250) (250) Glacier Industries 425 Stanford Ave E 104 Parksville BC V9P2N4 (250) (250) Great West Refrigeration Ltd 1698 Gary Rd 3 Kelowna BC V1X2B9 (250) (250) Halliday Refrigeration Ltd 2020h Falcon Rd Kamloops BC V2C4J3 (250) Not Available Handy Appliances Ltd th Ave E Vancouver BC V5V1B8 (604) Not Available Hegyi Refrigeration & Mechcl 1335 Dalhousie Dr 2 Kamloops BC V2C5P6 (250) (250) Heli Cool Hacr Ltd 10 Manitou Rd A Fernie BC V0B1M5 (250) Not Available Horizon Climate Controls Ltd 385 Mackenzie Ave N D Williams Lake BC V2G1N4 (250) Not Available Hunt Refrigeration Inc 110 West Mall Etobicoke ON M9C1C1 (416) (416) Ics Refrigeration Ltd a Ave 403 Surrey BC V3S2A7 (604) (604) Igloo Refrigeration Ltd 9379 Rte Transcanadienne Saint-Laurent QC H4S1V3 (514) (514) Mac Appliance & Vacuum Ltd 1825 Lonsdale Ave North Vancouver BC V7M2J8 (604) Not Available Independent Supply Co Inc 2808 Ingleton Ave Burnaby BC V5C6G7 (604) (604) Intercity Refrigeration & Ac St Langley BC V2Y1T3 (604) (604)

37 Page 3 Refrigerator Repair Shops Suite Postal Company Name Address Number City Province Code Phone Number Fax Number Interior Plumbing & Htg Ltd 782 Laval Cres Kamloops BC V2C5P3 (250) Not Available Interior Refrigeration Ltd 36 Broadway Ave N Williams Lake BC V2G1B9 (250) Not Available John Clarke Refrigeration 862 Devonshire Rd Victoria BC V9A4T4 (250) (250) Jones Food Store Equipment Ltd 2896 Norland Ave Burnaby BC V5B3A6 (604) (604) Jones Refrigeration 2896 Norland Ave Burnaby BC V5B3A6 (604) Not Available K L Bulmer Enterprises Ltd 2524 Manotick Stn Rd Osgoode ON K0A2W0 (613) (613) Key Food Equipment Svc 2740 Bridge St 105 Victoria BC V8T5C5 (250) (250) Kirk's Heating & Refrigeration 3840 Schubert Rd Armstrong BC V0E1B4 (250) Not Available L D Heating & Plumbing 810 Esplanade Ave Ladysmith BC V9G1B3 (250) Not Available Ladysmith Heating & Plumbing 810 Esplanade Hwy Tch Ladysmith BC V9G1B3 (250) (250) Le Groupe Protec Inc 9601 Rue Colbert Anjou QC HU1Z9 (514) (514) M & K Plumbing & Heating Co 405 Slater Rd NW Cranbrook BC V1C4Y5 (250) Not Available Mac Kay Electric Ltd 2554 Estes PI Prince George BC V2N3Z9 (250) Not Available Martell Refrigeration Ltd 4396 Boban Dr 4 Nanaimo BC V9T5V9 (250) (250) Mayfair Gas Plumbing & Elec 505 4th Ave Prince George BC V2L3H2 (250) (250) Mission Possible Appliance 416b Puntledge Rd Courtenay BC V9N3R1 (250) (250) Moore Appliance Ltd 350 Queensway Prince George BC V2L5C3 (250) (250) Norm's Mobiles Svc Ltd 3365 Durnin Rd Nanaimo BC V9R6V6 (250) Not Available Polar Industries Ltd 901 Tupper Ave Coquitlam BC V3K1A4 (604) Not Available Polar Industries Ltd Ave 104 Surrey BC V4N3R1 (604) (604) Polar Refrigeration Sales-Svc 910 3rd Ave Prince George BC V2L3C9 (250) (250) Pope & Sons Refrigeration Ltd 1139 Franklin's Gull Rd Parksville BC V9P2W8 (250) (250) Priority Appliance Svc Ltd 4611 No. 6 Rd 220 Richmond BC V6V2L3 (604) Not Available Quality Refrigeration Ltd Ave NW 54 Edmonton AB T6E6M9 (780) Not Available R F Appliance 550 Osborne St Winnipeg MB R3L2B1 (204) (204) Ram Appliance Svc Ltd 460 Whistler St Duncan BC V9L3P6 (250) (250) Refrigeration Amesse Inc 17 Rue Peladeau Beauharnois QC J6N3J2 (450) Not Available Refrigerative Supply 3958 Myrtle St Burnaby BC V5C4G2 (604) (604) Refrlgerative Supply 2394 Canoe Ave Coquitlam BC V3K6C2 (604) (604)

38 Page 4 Refrigerator Repair Shops Company Name Address Suite Number City Province Postal Code Phone Number Fax Number Refrigerative Supply Ave Langley BC V2Y3G9 (604) (604) Refrigerative Supply 1322nd Ave W Vancouver BC V5Y1C2 (604) (604) Reliable Heating & Cooling Ltd 100 Armour Rd Regina SK S4P3C7 (306) (306) Reliable Parts Ltd 85 North Bend St Coquitlam BC V3K6N1 (604) (604) Riverside Refrigeration Ltd 1235 Georgia St E Vancouver BC V6A2A9 (604) (604) Rogair Mechanical Ltd 2543 Juliann Rd 4 West Kelowna BC V1Z2M3 (250) (250) Rpr Heating & Air Cond 154 Ellis St Penticton BC V2A4L5 (250) (250) Ruhl Refrigeration 200 Rexdale Blvd Etoblcoke ON M9W1R2 (416) Not Available S K Refrigeration & Air Cond 890 Hastings St E Vancouver BC V6A1R6 (604) (604) Service Plus 1339 Mcgiil Rd 111 Kamloops BC V2C6K7 (250) (250) Service Today 5 Stacey Cres Thornhill ON L3T6Z4 (905) Not Available Service Today 465 St Mary's Rd Winnipeg MB R2M3K9 (204) (204) Shawn Robinson Refrigeration 3907 Rockdale Rd Navan ON K4B1H9 (613) Not Available Sumit Products Inc 8500 Keele St Concord ON L4K2A6 (905) (905) Sunset Systems 849 Fairweather PI Vernon BC V1T9B5 (250) (250) Superior Appliance Svc Ltd 729 Wall St Winnipeg MB R3G2T6 (204) (204) Surefreeze Refrigeration & Ac 709 Bowler St New Westminster BC V3M4V6 (604) (604) Taylor Refrigeration Ltd Ave Vernon BC V1T7X8 (250) Not Available Tempco Refrigeration & Ac Ltd 4493 Marine Ave F Powell River BC V8A2K3 (604) Not Available Thermo Tec Mechanical Ltd 911 Mcphee Ave Courtenay BC V9N3A1 (250) (250) Thermo-Trans Refrigeration 112 Rue Clement Vars ON K0A3H0 (613) Not Available Totem Appliance 5950 Imperial St Burnaby BC V5J4M2 (604) Not Available Tri-City Refrigeration Inc 5040 Graham Ave Terrace BC V8G1B4 (250) (250) Tri-Rom Industries Ltd th St 9 Kamloops BC V2B3C8 (250) (250) Triway Services Ltd St NE 8 Calgary AB T2A7W6 (403) (403) Tycor Climate Control Inc 1270 Columbia Ave Trail BC V1RU4 (250) Not Available Uptown Air Conditioning & Rfrg 3592 Calumet Ave Victoria BC V8X1V5 (250) Not Available Van Isle Food Equipment 4970 Polkey Rd G1 Duncan BC V9L6W3 (250) (250) Vector Industries Inc Ave NW Edmonton AB T5L2M7 (780) (780)

39 Schedule "D" Page 1 Company Name Address Refrigerator Distributors Suite Number City Province Postal Code Phone Number Fax Number A & A Appliance Repair 695 George St Saint John NB E2M3T5 (506) (506) A Plus Heating Air-Appliances 855 Almond St 3 17 Concord ON (905) Not Available AAA Global Appliance Svc 33 Pinecone Dr Etobicoke ON M9W7B5 (416) Not Available Albany Tetrau It Inc 845 Av Cremazie Saint-Hyacinthe QC J2S8R4 (450) (450) Alkan Refrigeration Air Cond 475 The West Mall Etobicoke ON M9C4Z3 (416) Not Available All Discount Appliances 2060 Broad St B Regina SK S4P1Y3 (306) (306) Andre Bedard Svc Inc 72 Rue De Liege St-Jn-S-Richlieu QC J3B3T1 (450) Not Available Appareils Electromenagers Mrtn Boul Perras Montreal QC H1C2H8 (514) (514) Appco Appliance 4971 Walker Rd Windsor ON N9A6J3 (519) Not Available Appliance Doctor 149 Tecumseh Rd W Windsor ON N8X1E8 (519) Not Available Appliance Maritimes Sales-Svc 55 Macdonald Ave A Dartmouth NS B3B1T9 (902) (902) Appliance Scratch & Dent Otit 407 Gage Ave 4 Kitchener ON N2M5E1 (519) (519) Appliance Service People 3663 Mavis Rd Mississauga ON L5C2Z2 (905) Not Available Appliance Solutions Ltd 117 Ropewalk Lane St. John's NL A1E4P1 (709) Not Available Appliance World 22111st Ave N Saskatoon SK S7K2A4 (306) Not Available Arva Appliances Inc Richmond St N Arva ON NOMICO (519) (519) Au Electro Fredette Enr'g 4229 Boul Bourque 200 Sherbrooke QC J1L1N7 (819) (819) Au Service De L'Estrie Inc 385 Rue Dufferin Granby QC J2G4Y3 (450) (450) B-Line Appliance Recycling 776 Kingsway Vancouver BC V5V3C1 (604) (604) Baywest Appliance Svc Inc 738 1st AveN Saskatoon SK S7K1Y1 (306) (306) Bennett's Home Furnishings 13 Hoard's Church Rd Campbellford ON KOLILO (705) (705) Big Pines Trailer Sales Ltd 344 Cumberland St N Thunder Bay ON P7A4P2 (807) Not Available Brisco Furniture & Appliances 43 Victoria St W Alliston ON L9R1T1 (705) (705) C & K Refrigeration Ltd 1138 Louis Ave Windsor ON N9A1Y2 (519) Not Available Centre De Pieces Et Svc Expert 6855 Boul Jean-Xxiii 23 Trois-Rivieres QC G9A5C9 (819) Not Available Champagne Pieces Electro Inc 6855 Boul Jean-Xxiii Trois-Rivieres QC G9A5C9 (819) Not Available Coast Wholesale Appliances 4151 Mostar Rd 10 Nanaimo BC V9T6A6 (250) (250) Corbeil Electromenagers 633 Rue Dufferin Granby QC J2H0Y7 (450) (450)

40 Page 2 Company Name Address Refrigerator Distributors Suite Number City Province Postal Code Phone Number Fax Number Corbeil Electromenagers 390 Rue Lamontagne Saint-Jerome QC J7Y0E1 (450) Not Available Corbell Electromenagers 600 Rue Gait 0 Sherbrooke QC J1H1Y9 (819) (819) Corbeil Electromenagers 100 Rue Moreau St-Jn-S-Richlieu QC J2W2M4 (450) Not Available Corbeil Electromenagers Corbeil Electromenagers Corbeil Electromenagers 294 Montee Des Pionniers Terrebonne QC J6V1S6 (450) (450) Soul Des Recollets Trois-Rivieres QC G8Z3X6 (819) (819) Boul De La Cite-Des- Jeunes Vaudreuil-Dorion QC J7V9L5 (450) (450) Couture Electro 315 Ch Ozias-Leduc Otterburn Park QC J3H4A7 (514) (450) Daleys Brandsource Hm Furnsngs 1840 Lincoln Rd Fredericton NB E3B8K7 (506) Not Available Dave's Electric Appliance 1 Sandy Point Rd Saint John NB E2K3R6 (506) (506) Dextraze Service 320 Rue Saint-Jacques St-Jn-S-Richlieu QC J3B2L4 (450) Not Available Doug Swartz Appliance Svc 437 KillalyStE Port Colborne ON L3K1P7 (905) (905) Duval Meubles Usages Enr 3802e Av St-Jn-S-Richlieu QC J2X2B8 (450) (450) Earl E Austin & Son Ltd 40 Taylor Ave Chatham ON N7L2T6 (519) (?19) Electro-Menagers Rvs Inc 6061 Boul Bourque Sherbrooke QC J1N1H2 (819) Not Available Electrobec 415 Boul Lacombe Repentigny QC J5Z1N9 (450) Not Available Essex Appliance Ctr 76TalbotStS Essex ON N8M1A9 (519) Not Available Fast Eddie AppI Svc & Parts 380 Pine Cove Rd Burlington ON L7N1W5 (905) (905) Fast Eddie Appliance Svc 380 Pine Cove Rd Burlington ON L7N1W5 (905) Not Available 2880 Lake Shore Blvd Faulkner's Appliance Ctr W Etobicoke ON M8VU2 (416) (416) Frost Refrigeration & Air 1415 Tomiko Rd Crystal Falls ON POHILO (705) Not Available Future Climates Refrig Ltd Manufacturers Way 10 Abbotsford BC V2S7M1 (604) Not Available G &J Appliances 1623 Drouillard Rd 1 Windsor ON N8Y2S4 (519) Not Available G C Refrigeration Inc 9701 Rue Colbert Anjou QC H1J1Z9 (514) Not Available

41 Page 3 Company Name Address Refrigerator Distributors Suite Number City Province Postal Code Phone Number Fax Number G R Parts & Appliances 60 Boul Saint- Raymond Gatineau QC J8Y1S1 (819) Not Available General Appliance Ctr 145 Simpson St Thunder Bay ON P7C3H3 (807) (807) Gords Maytag Home AppI Ctr 948 Tranquille Rd Kamloops BC V2B3J5 (250) (250) Hensall Major Appliance Ctr 107 King St Hensall ON NOMIXO (519) (519) Highland Appliances Ltd 13 Industrial Park Rd Haliburton ON KOMISO (705) (705) Hurst Appliance Repair Ltd 18109th Ave N Regina SK S4R7T4 (306) (306) Jarmicos Ltee 495 Boul Saint-Rene E 3 Gatineau QC J8P8A5 (819) Not Available Joe Reis Appliance Ltd 52 Oak St E Leamington ON N8H2C2 (519) (519) Joice-Sweanor Appliances Ltd 336 Ward St Port Hope ON L1A4A6 (905) (905) Knapp's Gravenhurst Furniture 171 Muskoka Rd S Gravenhurst ON P1P1X3 (705) (705) Kondolas Furniture & Appis Ltd 4525 Lakelse Ave Terrace BC V8G1P3 (250) (250) L'Entrepot Du Meuble Gaetan 1095 Ch De La Canardiere Quebec QC GU2C2 (418) Not Available Leon's Furniture 970 Alison Blvd Fredericton NB E3C0C3 (506) Not Available Leon's Furniture 24 Norfolk St N Simcoe ON N3Y5C6 (519) (519) Lincoln Appliance Svc Ctr Inc 227 Bunting Rd G St Catharines ON L2M3Y2 (905) Not Available London Major Appliances 185 Hamilton Rd London ON N6B1N4 (519) (519) Long Last Appliance 107 King St Hensall ON NOMIXO (519) Not Available M G Refrigeration 7160 Ste Marguerite Ch Trois-Rivieres QC G9A5C9 (819) Not Available Mc Niece & Smith Inc 19 Grey St Sudbury ON P3E3L2 (705) (705) Mciver's Appliance Sales & Svc 610 Marine DrSE 105 Vancouver BC V5X2T4 (604) Not Available Meubles Jacob 560 Av Broadway Shawinigan QC G9N1M3 (819) (819) Meubles Mont-Laurier Ltee 580 Rue Hebert Mont-Laurier QC J9L2X2 (819) (819) North End Appliance 635 Cathcart Blvd Sarnia ON N7V2N1 (519) Not Available Oakville Appliance 476 KerrSt Oakville ON L6K3C5 (905) (905) Ohms Appliance Repairs 91 Anderson Ave 10 Markham ON L6E1A5 (905) Not Available Ohms Mechanical Repair 91 Anderson Ave 10 Markham ON L6E1A5 (905) Not Available

42 Page 4 Refrigerator Distributors Company Name Address Suite Number City Province Postal Code Phone Number Fax Number Paddy's Market 2212Taunton Rd Hampton ON LOBUO (905) (905) Parry Sound Furniture Plus 5 Mall Or Parry Sound ON P2A3A9 (705) (705) Pereira's Countrywide Furn 707 Commercial Ave Kitimat BC V8C2H4 (250) (250) Proud Refrigerators Inc 3108 Beta Ave Burnaby BC V5G4K4 (604) Not Available Refrigeration Gaetan Laberge 169 Rue Principale Chateauguay QC J6K1G2 (450) Not Available Refrigeration GrI Inc 220 Av Du Havre Rimouski QC G5M0B9 (418) (418) Reparateur 702 Rue Du Cure Sherbrooke QC J1N2N8 (819) (819) Richard Service 169 Rue Jalbert 0 Thetford Mines QC G6G7W1 (418) (418) SOS Refrigeration Inc 2440 Rue Cantin Jonquiere QC G7X8S6 (418) Not Available Salter & Newell Appliance 2267 Cousins Ave Courtenay BC V9N3N6 (250) (250) Saskatoon Appliance Distr Ltd 27208th St E 3 Saskatoon SK S7H0V8 (306) (306) Sercon Refrigeration Ltd Ave NW Edmonton AB T5S1W9 (780) (780) Service De L'Estrie Inc 455 Boul Saint-Joseph B Drummondville QC J2C7B5 (819) (819) Service Electromenagers 980 Boul De L'Universite E Chicoutimi QC G7H6H1 (418) (418) Service Plus 108 High St Moncton NB E1C6B5 (506) Not Available Service Today 3311 Bloor St W Etobicoke ON M8X1E7 (416) Not Available Shaughnessy Appliance Svc Ltd 311 Jessop Ave Saskatoon SK S7N1YS (306) Not Available Shuh's Appliance Ctr 397 Woodlawn Rd W Guelph ON N1H7M1 (519) (519) Sirois J Electrique Inc 2203 Rue Roussel Chicoutimi QC G7G1W4 (418) Not Available Smardt Inc Smardt Inc Specialistes-L'Electromenager 1800 Rte Transcanadienne Dorval QC H9P1H7 (514) Not Available 7800 Aut Transcanadienne Pointe-Claire QC H9R1C6 (514) Not Available 3380 Boul Laframboise Saint-Hyacinthe QC J2S4Z4 (450) Not Available Stryde Mechanical Rrl Mcdonalds Cors ON KOGIMO (613) Not Available Sussex Manufacturing Ltd 72 Leonard Dr Sussex NB E4E2R3 (506) Not Available

43 Page 5 Refrigerator Distributors Suite Company Name Address Number City Province Postal Code Phone Number Fax Number Sutton & Son Appliances 154 Gage Ave N Hamilton ON L8L7A4 (905) Not Available Trail Appliances Ltd 3150 Idylwyld Dr N Saskatoon SK S7L5Y6 (306) Not Available Tsi Refrigeration 2600 Boul Ford Chateauguay QC J6J4Z2 (450) Not Available Universal Appliances 1915 Bank St Ottawa ON K1V8A2 (613) (613) Valley Home Appliance Svc Inc 2212 Gladwin Cres B5 Ottawa ON K1B5N1 (613) Not Available Windsor Appliance & Refrig Svc 4971 Walker Rd Windsor ON N9A6J3 (519) Not Available Wosk's Limited 1777 ElliceAve Winnipeg MB R3H0B4 (204) Not Available Zoli Swartz Allan-Brian Svc 2 Minto St Port Colborne ON L3K3M9 (905) (905)

44 Schedule "E" Hotel Chains Suite Province / Postal / Zip Company Name Address Number City State Code Phone Number Fax Number Fairmont/Raffles 155 Wellington Street West 3300 Toronto ON M5V 0C Wyndham Hotels and Resorts 22 Sylvan Way Parsippany NJ Radisson Hotels 701 Carlson Parkway Minnetonka MN Preferred Hotel Group 311 South Wacker Dr Chicago IL Marriott International Femwood Road Bethesda MD Intercontinental Hotels & Resorts 225 Front Street W Toronto ON M5V 2X Hilton Worldwide 7930 Jones Branch Drive McLean VA Delta Hotels 77 King Street West 2300 Toronto ON M5K 1G Best Western 6557 Mississauga Rd. UnitD Mississauga ON L5N 1A Choice Hotels International 5090 Explorer Drive 500 Mississauga ON L4W4T Coast Hotels & Resorts 1090 West Georgia Street 900 Vancouver BC V6E 3 V Starwood Hotels and Resorts One StarPoint Stamford CT Days Inn/Realstar Hospitality 77 Bloor Street W 2000 Toronto ON M5S 1M Northland Properties Corp/Sandman Hotels 1755 West Broadway 310 Vancouver BC V6J 4S