(a) “Class A Members”, being Dennis and all other residents of Ontario and the United States, or their estates, who: (i) suffered from compulsive gambling at any time after December 1, 1999 (ii) signed the Self-Exclusion Contract (as defined in paragraph 39 of the Statement of Claim) at any time during the period from December 1, 1999 to February 10, 2005; and (iii) were nonetheless permitted entry to one or more of the Gambling Venues (as defined in paragraph 14 of the Statement of Claim) after signing the Self-Exclusion Contract.

(b) “Class B Members”, being Noble and all other living parents, grandparents, children, grandchildren, siblings and spouses of the Class A Members entitled to claim damages arising from the fault or neglect of the OLGC under section 61 of the Family Law Act.