BASIC INFORMATION

1. What is the lawsuit about?(top)

Bextra was approved for marketing and sale in the United States on November 16, 2001, and was withdrawn from the market on April 7, 2005. Celebrex was approved for marketing and sale on December 31, 1998 and remains on the market. On July 29, 2005, the Celebrex label was amended to add a black box warning that the federal Food & Drug ("FDA") Administration determined should be added to the labels for all NSAIDs regarding gastrointestinal and cardiovascular risks.

The lawsuit claims:

Pfizer denies any wrongdoing. It asserts that its marketing practices were truthful and not misleading, and conformed to the FDA-approved label that described benefits of Bextra and Celebrex not offered by other, and less expensive, pain medications. Pfizer is settling this lawsuit to avoid the costs and distraction of continued litigation.

2. Why is this a class action? (top)

In a class action lawsuit, one or more people called"class representatives" sue on behalf of people who have similar claims. The people together are a"class" or "class members." A court must determine if a lawsuit should proceed as a class action. If it does, a trial then decides the lawsuit for everyone in the class.

Sometimes, the parties may settle without a trial. The Parties here have agreed to a Settlement that includes a national Class of consumers who paid towards the purchase of these drugs.

3. Why is there asettlement?(top)

A settlement is an agreement between a plaintiff and a defendant following extended negotiation. Settlements conclude litigation but this does not mean that the court has ruled in favor of the plaintiff or the defendant. A settlement allows both parties to avoid the cost and risk of a trial and permits both parties to establish a just, fair and final resolution that is best for all involved. The class representatives and their attorneys decide that a settlement is the best result for all class members and the court is asked to approve the settlement as fair, reasonable and adequate.

The Court approved the Settlement and Pfizer is no longer legally responsible for the claims made in this lawsuit. The lawyers representing the Class (“Class Counsel") and Pfizer have engaged in extensive, arms-length negotiations regarding the issues presented in this lawsuit and the possible terms of a settlement. The Parties want to settle the claims in this lawsuit and Class Counsel believes the Settlement is fair, reasonable and adequate and in the best interests of the Class.

4. Who is a Class Member? (top)

Generally speaking, you are a member of the Class if, on or before July 29, 2005, you paid (or are obligated to pay) for Bextra and/or Celebrex.

The Class contains three Subclasses:

This Notice involves the Settlement for consumers (Bextra Subclass and Celebrex Subclass). The Notice for the TPP Subclass is available from the Claims Administrator.

There are a number of people who are not included in the Class. These people include:

5. How do I know if I am included in the settlement?(top)

Unless you excluded yourself, you are a Class Member and you are included in the Settlement if you paid for all or part of the price of Bextra and/or Celebrex on or before July 29, 2005.

BENEFITS OF THE SETTLEMENT – WHAT YOU GET

6. What does the settlement provide?(top)

Pfizer will pay $89 million to settle the lawsuit. All costs associated with notice and administration, attorneys’ fees and litigation costs, and compensation to the named class representatives for time spent providing documents and testimony in connection with this case will be paid from the Settlement Amount. All aspects of this Settlement, including payment of these fees and costs, are subject to approval by the Court.

Under the Agreement, 70% of the net Settlement Amount will be designated to satisfy the claims of TPPs. This division was negotiated between attorneys representing TPPs and attorneys representing consumers. The remaining 30% of the net Settlement Amount will be designated for the purpose of paying consumer claims.

Bextra Subclass

The Bextra Subclass includes consumers that paid for either Bextra prescriptions only or both Bextra and Celebrex prescriptions. Bextra Subclass Members must be willing to accept a settlement award based on their payments for Bextra in exchange for release of all claims for both Bextra and Celebrex.

Celebrex Subclass

The Celebrex Subclass includes consumers who paid for prescriptions of Celebrex, but not Bextra, on or before July 29, 2005. The Celebrex claims include substantial additional obstacles above the obstacles faced by Bextra claims. These obstacles include that Celebrex is still on the market and many consumers continue to pay for it. These factors and others make the potential for recovery for Celebrex claims significantly less than the Bextra claims.

Division of Settlement Amount Among Subclasses

Attorneys representing the different consumer Subclasses estimated that the relative strength of Bextra claims versus Celebrex claims is 4 to 1 respectively. To reach this number, the attorneys compared what they believed were Bextra and Celebrex claims’ chances of success as compared to each other. The major issues that were considered were:

The consumer attorneys selected these as the major issues and determined their comparative impacts on the potential recovery for each claim without input from the Court or from Pfizer. Based on this analysis, of the 30% consumer share of the total Settlement Amount, Bextra Subclass members will receive 24% and Celebrex Subclass members will receive 6%.

7. How do I file a claim?(top)

**Even though the deadline to file claims has passed we still urge consumer to file claims even past the deadline**

You can submit a Claim Form online by clicking here now. If submitting the Claim Form online, it must be submitted by December 18, 2009.

Or you can submit a paper Claim Form. You must fill out the Claim Form and submit it to the Claims Administrator, postmarked by December 18, 2009, and addressed to:

8. How much will I get?(top)

How much you receive from this Settlement depends on the volume and amount of claims submitted by other Class Members. You will receive your pro rata share of the total available for distribution to your respective consumer Subclass, but no more than the amount of your claim.

REMAINING IN THE CLASS

9. What claims am I giving up?(top)

The Settlement is approved, generally speaking you gave up any right you may otherwise have to sue Pfizer related to any claims made or that could have been made in this lawsuit.

Specifically, you release any claim relating to the purchase, price, payment, reimbursement, use, prescription, marketing, manufacture, distribution, sale, promotion, research, design, development, supply and/or ingestion of Celebrex and/or Bextra during the Class Period that Class Members ever had, currently have, or may subsequently have in any capacity against Pfizer and/or Pfizer’s associated or affiliated companies.

This means that you cannot sue Pfizer for money damages or other relief of any nature whatsoever arising out of any conduct, events or transactions concerning Bextra or Celebrex that have been alleged or that could have been alleged in any litigation. This includes claims whether known or unknown, suspected or unsuspected, contingent or non-contingent. All claims will be released forever whether or not the facts were concealed or hidden, without regard to the subsequent discovery or existence of such different or additional facts.

10. What entities am I releasing?(top)

The Released Entities include: Pfizer Inc., its parent companies, subsidiaries, and affiliates, and their past, present and future officers, directors, trustees, employees, agents, attorneys, shareholders, predecessors, successors and assigns.

EXCLUSION FROM THE SETTLEMENT

11. Is it possible to exclude myself from the Settlement? (top)

**The exclusion deadline has passed therefore you may longer exclude yourself**

OBJECTING TO OR COMMENTING ON THE SETTLEMENT

12. May I object to, or comment on, the Settlement?(top)

**The Deadline has passed therefore you may no longer object or comment on the settlement**

13. What is the difference between objecting to the Settlement and excluding myself from the Settlement?(top)

An objection to the Settlement is made when you wish to remain a Class Member and be subject to the Settlement but disagree with some aspect of the Settlement. An objection allows your views to be heard in Court. In contrast, exclusion means that you are no longer a Class Member and ultimately do not want to be subject to the Settlement’s terms and conditions. Once excluded, you lose any right to object to the Settlement or to the attorneys’ fees because the case no longer affects you.

THE LAWYERS REPRESENTING YOU

14. Do I have a lawyer representing my interests in this case?(top)

Yes. The Court has appointed the following law firm to represent you and other Class Members:

15. How will the lawyers be compensated?(top)

The lawyers who were appointed by the Court to represent you in this lawsuit are called Class Counsel. You will not be charged personally for these lawyers, but they will ask the Court to award them a fee of up to 30 % of the Settlement Amount. In addition, Class Counsel will request reimbursement of the expenses and costs associated with litigation of this case. The fee will be paid out of the $89 million Settlement Amount as will any reimbursement of litigation costs and expenses awarded by the Court. This may also include incentive awards to the plaintiffs. More information about Class Counsel and their experience is available at the website listed above.

16. Should I get my own lawyer?(top)

You don’t need to hire your own lawyer. However, if you want your own lawyer to speak for you or appear in Court, you must file a Notice of Appearance. (See Question 19.) If you hire a lawyer to appear for you in this case, that will be at your own expense.

THE COURT’S FINAL APPROVAL HEARING

17. When and where will the Court decide on whether to grant final approval of the settlement?(top)

**The Court Granted Final Approval of the Settlement on October 9, 2009.**

18. Must I attend the Final Approval Hearing?(top)

The Final Approval Hearing took place on October 9, 2009

19. May I speak at the Final Approval Hearing?(top)

The Final Approval Hearing took place on October 9, 2009

GETTING MORE INFORMATION

20. Where do I obtain more information?(top)

More details are in the Complaints filed by Class Counsel, the Answers filed by Defendants, and the other legal documents that have been filed with the Court in this lawsuit. These documents include the Settlement Agreement and Release, which sets forth in great detail the Settlement’s provisions. You can look at and copy these legal documents at any time during regular office hours at the Office of the Clerk of Court, United States District Court, Northern District of California, San Francisco Division, 450 Golden Gate Avenue, 16th Floor, San Francisco, CA 94102.

In addition, if you have any questions about the lawsuit or this Notice, you may: