1.  This action is brought on behalf of the classes of persons defined as follows (the “Classes”):

a)  All persons in Canada, by their litigation guardians or estate representatives, where applicable, who ingested the components and/or metabolic products of Tylenol 3 (as designed, developed, fabricated, manufactured, imported, distributed, marketed, sold or otherwise placed into the stream of commerce in Canada by all or any one of the Defendants), including codeine and/or morphine, through their mother’s breast milk (“Class 1 Members”)

b)  All persons including, but not limited to, executors, administrators, personal representatives, and relatives who on account of a personal relationship to any one or more of those persons described in Class 1 above, have a derivative claim for damages resulting from the ingestion of the components and/or metabolic products of Tylenol 3, including codeine and/or morphine. (“Class 2 members”)