Naji El-Mousfi v. Mattel Canada Inc., and Mattel Inc., and Fisher-Price Canada Inc., and Fisher-Price Inc.

All physical persons in Quebec and Canada;

i) who have purchased Respondents' toys subject to recall, that were manufactured, or caused to be manufactured, distributed, or ultimately offered for sale and sold to the public, by the Respondents or their retailers,

ii) who are parents of children who have Respondents' toys subject to recall, manufactured, distributed, or ultimately offered for sale and sold to the public, by the Respondents or their retailers, or,

iii) as next friend or litigation guardian of all children who a) have played with the Respondents' toys subject to recall, manufactured, distributed, or ultimately offered for sale and sold to the public, by the Respondents or their retailers, or b) mau suffer medical damage as a result of the use of the Respondents' toys subject to recall.