Frequently Asked Questions

  1. Why did I get the Notice?

    You or someone in your family may have purchased or otherwise acquired the ADSs of Dr. Reddy’s Laboratories Ltd. on the NYSE during the period from November 27, 2014 through September 15, 2017, inclusive.

    The Court directed that the Notice be sent to Class Members because they have a right to know about the proposed Settlement of this class action lawsuit, and about all of their options, before the Court decides whether to approve the Settlement.

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

    A copy of the Notice can be found here.

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  2. What is this case about and what has happened so far?

    On August 25, 2017, a securities class action complaint was filed in the U.S. District Court for the District of New Jersey (the “Court”) on behalf of investors in Dr. Reddy’s publicly traded securities, entitled Critchley v. Dr. Reddy’s Laboratories, Ltd. et al., Civil No. 3:17-cv-0643. On November 21, 2017, the Court issued an order appointing the Public Employees’ Retirement System of Mississippi as Lead Plaintiff; and appointing Labaton Sucharow LLP as Lead Counsel and Kaplan Fox & Kilsheimer LLP as Liaison Counsel. Lead Plaintiff, through Lead Counsel and Liaison Counsel, then thoroughly investigated the claims, defenses, and underlying events and transactions. Based on that investigation, Lead Plaintiff filed an Amended Consolidated Class Action Complaint (the “Complaint”) on March 5, 2018. The Complaint alleges violations of §§ 10(b) and 20(a) of the Securities and Exchange Act of 1934 (“Exchange Act”) and Rule 10b-5 promulgated thereunder, on behalf of a class consisting of all persons and entities who, during the period from November 27, 2014 through September 15, 2017, purchased or otherwise acquired Dr. Reddy’s publicly traded securities on the New York Stock Exchange.

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  3. Why is this a class action?

    In a class action, one or more persons or entities (in this case, Lead Plaintiff), sue on behalf of people and entities who have similar claims. Together, these people and entities are a “class,” and each is a “class member.” Class actions allow the adjudication of many individuals’ similar claims that might be too small economically to bring as individual actions. One court resolves the issues for all class members at the same time, except for those who exclude themselves, or “opt-out,” from the class.

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  4. What are the reasons for the Settlement?

    The Court did not finally decide in favor of Lead Plaintiff or Defendants. Instead, both sides agreed to a settlement. That way, they avoid the risks and cost of a trial. Lead Plaintiff and its attorneys think the Settlement is in the best interest of the Settlement Class.

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  5. How do I know if I am part of the Settlement Class?

    The Court directed, for the purposes of the proposed Settlement, that everyone who fits the following description is a Class Member and subject to the Settlement unless they are an excluded person or take steps to exclude themselves from the Settlement Class:

    All persons and entities that purchased or otherwise acquired Dr. Reddy’s ADSs on the NYSE during the period from November 27, 2014 through September 15, 2017, inclusive, and who were allegedly damaged thereby.

    If one of your mutual funds purchased Dr. Reddy’s ADSs during the Class Period, that does not make you a Class Member, although your mutual fund may be. You are a Class Member only if you individually purchased or acquired Dr. Reddy’s ADSs on the NYSE during the Class Period. Dr. Reddy’s ADSs may be referred to by the ticker symbol “RDY” in your trading documentation. Check your investment records or contact your broker to see if you have any eligible purchases or acquisitions.

    If you are still not sure whether you are included, you can ask for free help. You can call 1-855-917-3520 for more information, or you can fill out and return the Claim Form, or submit it online, to see if you qualify.

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  6. Are there exceptions to being included in the Settlement Class?

    Yes. There are some individuals and entities who are excluded from the Settlement Class by definition. Excluded from the Class are: (i) Defendants; (ii) any person who was an officer or director of the Company and/or Dr. Reddy’s Laboratories, Inc. during the Class Period; (iii) the Company’s and/or Dr. Reddy’s Laboratories, Inc.’s affiliates and subsidiaries; (iv) members of the immediate family of each Individual Defendant; (v) any entity in which any Defendant has or had a controlling interest during the Class Period; and (vi) the legal representatives, heirs, successors, or assigns of any excluded person or entity, in their capacities as such. Also excluded from the Settlement Class is anyone who timely and validly seeks exclusion from the Settlement Class in accordance with the procedures described in FAQ 11.

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  7. What does the Settlement provide?

    In exchange for the Settlement and the release of the Released Plaintiff’s Claims against the Released Defendant Parties (see FAQ 10), Dr. Reddy’s has agreed to pay $9,000,000 into an escrow account, which, along with any interest earned, will be distributed after deduction of Court-awarded attorneys’ fees and litigation expenses, Notice and Administration Expenses, Taxes (including Indian taxes, if any) and Tax Expenses, and any other fees or expenses approved by the Court (the “Net Settlement Fund”), to Class Members who send in valid and timely Claim Forms that are eligible for a payment. The Plan of Allocation is described in more detail in the Notice.

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  8. How can I receive a payment?

    To qualify for a payment from the Net Settlement Fund, you must submit a timely and valid Claim Form. The Claim Form is enclosed with the Notice. You can also download a copy of the Claim Form here.

    Please read the instructions contained in the Claim Form carefully, fill out the Claim Form, include all the documents the form requests, sign it, and mail it to the mailing address below or submit it online here. Claim Forms must be postmarked or received online no later than September 22, 2020.

    Mailing address for Claim Forms:

    In re Dr. Reddy’s Laboratories Ltd Sec. Litig.
    Claims Administrator
    P.O. Box 3747
    Portland, OR 97208-3747

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  9. When will I receive my payment?

    It is not possible at this time to determine when the Settlement proceeds will be distributed to eligible Class Members. The Court approved the Settlement at the hearing held on December 23, 2020. Even though the Settlement was approved, there may be appeals which can take time to resolve, perhaps more than a year. It also takes a long time for all the Claim Forms to be accurately reviewed and processed, and it may take a long time for the Authority for Advance Rulings in India (the “AAR”) to make a ruling about Taxes on the Settlement Amount. Please be patient.

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  10. What am I giving up to get a payment and by staying in the Settlement Class?

    Unless you exclude yourself, you will remain in the Settlement Class, which means that upon the “Effective Date” of the Settlement, you will release all “Released Plaintiff’s Claims” against the “Released Defendant Parties.” For additional information and a definition of these terms, please review Question 10 of the Notice.

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  11. How do I exclude myself from the Settlement Class?

    The deadline to submit requests for Exclusion was September 8, 2020.

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  12. If I do not exclude myself, can I sue Defendants or the other Released Defendant Parties for the same thing later?

    No. Unless you properly exclude yourself, you will give up any rights to sue Defendants and the other Released Defendant Parties for any and all Released Plaintiff’s 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 this Settlement Class to continue your own lawsuit. Remember, the exclusion deadline is September 8, 2020.

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  13. If I exclude myself, can I get money from the proposed Settlement?

    No, only Class Members are eligible to recover money from the Settlement.

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  14. Do I have a lawyer in this case?

    Labaton Sucharow LLP, Lead Counsel, and Kaplan Fox & Kilsheimer LLP, Liaison Counsel, represent all Class Members in this Action. You will not be separately charged for these lawyers. The Court will determine the amount of attorneys’ fees and expenses, which will be paid from the Settlement Amount. If you want to be represented by your own lawyer, you may hire one at your own expense.

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  15. How will the lawyers be paid?

    Lead Counsel and Liaison Counsel have been prosecuting the Action on a contingent basis and have not been paid for any of their work. Lead Counsel and Liaison Counsel will apply to the Court for an award of attorneys’ fees of no more than 25% of the Settlement Amount, plus any accrued interest. Lead Counsel and Liaison Counsel will also seek payment of litigation expenses incurred in the prosecution and settlement of the Action of no more than $600,000, plus accrued interest, which may include an application pursuant to the PSLRA for the reasonable costs and expenses (including lost wages) of Lead Plaintiff directly related to its representation of the Settlement Class. As explained above, any attorneys’ fees and litigation expenses awarded by the Court will be paid from the Settlement Amount. Class Members are not personally liable for any such fees or expenses.

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  16. How do I tell the Court that I do not like something about the Settlement?

    The deadline to submit Objections was September 8, 2020.

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  17. What is the difference between objecting and seeking exclusion?

    Objecting is telling the Court that you do not like something about the proposed Settlement, Plan of Allocation, or Lead Counsel’s Fee and Expense Application. You can still recover money from the Settlement. You can object only if you stay in the Settlement Class. Excluding yourself is telling the Court that you do not want to be part of the Settlement Class. If you exclude yourself from the Settlement Class, you have no basis to object because the Settlement and the Action no longer affect you.

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  18. When and where will the Court decide whether to approve the Settlement?

    The Court approved the Settlement at the hearing held on December 23, 2020.

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  19. What happens if I do nothing at all?

    If you do nothing and you are a member of the Settlement Class, you will receive no money from this Settlement and you will be precluded from starting a lawsuit, continuing with a lawsuit, or being part of any other lawsuit against Defendants and the other Released Defendant Parties concerning the Released Plaintiff’s Claims. To share in the Net Settlement Fund, you must submit a Claim Form. To start, continue, or be a part of any other lawsuit against Defendants and the other Released Defendant Parties concerning the Released Plaintiff’s Claims, you must exclude yourself from the Settlement Class.

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  20. Are there more details about the Settlement?

    This website summarizes the proposes Settlement. More detail are contained in the Stipulation, which can be viewed here. You may also review other documents in the case during business hours at the Office of the Clerk of the United States District Court, District of New Jersey, Clarkson S. Fisher Building & U.S. Courthouse, 402 East State Street, Trenton, New Jersey 08608. Subscribers to PACER, a fee-based service, can also view the papers filed publicly in the Action through the Court’s online Case Management/Electronic Case Files System at https://www.pacer.gov.

    You may also call the Claims Administrator toll-free at 1-855-917-3520 or write to the Claims Administrator at In re Dr. Reddy’s Laboratories Ltd. Sec. Litig., PO Box 3747, Portland, OR 97208-3747. Please do not call the Court with questions about the Settlement.

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  21. How will my claim be calculated?

    The Settlement Amount, plus any accrued interest, and minus Court-approved attorneys’ fees and litigation expenses, Notice and Administration Expenses, Taxes and Tax Expenses, and any other fees or expenses approved by the Court is the “Net Settlement Fund.” The Net Settlement Fund will be distributed to members of the Settlement Class who timely submit valid Claim Forms that show a Recognized Claim according to the Plan of Allocation (described in the Notice) approved by the Court. Class Members who do not timely submit valid Claim Forms will not share in the Net Settlement Fund, but will otherwise be bound by the terms of the Settlement and what happens in the Action. The Court may approve the Plan of Allocation or modify it without additional notice to the Settlement Class.

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  22. What is the ticker symbol/CUSIP?

    The CUSIP for the Class Period is 256135203. The ticker symbol from November 27, 2017 through September 15, 2020 was RDY.

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