THE CLASS

I. The Plaintiffs bring this action on their behalf and on behalf of all others similarly affected as members of the proposed Class, hereinafter collectively referred to as the “Class Members” or the “Class” are intended to include the above mentioned individuals, as defined below.

ONTARIO CLASS MEMBERS

II. Persons resident or situated in Ontario, more particularly described as follows:

a) All persons in Ontario, who are taking or have taken Prexige, suffered, will suffer or are at risk of suffering from one or more of the medical problems or personal injuries, including but not limited to liver damage and kidney dysfunction.


NON RESIDENT CLASS MEMBERS

III. Persons not resident or situated in the Province of Ontario, however, resident or situated in another Canadian provinces or territories, more particularly described as follows:

a) All persons outside of Ontario but resident in Canada, who are taking or have taken Prexige, suffered, will suffer or are at risk of suffering from one or more of the medical problems or personal injuries, including but not limited to liver damage and kidney dysfunction.