1. 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 “ Plaintiff”, “Plaintiffs”, “Class Members” or the “Class”, which words are intended hereafter to include all of the following individuals, defined as follows:

Saskatchewan Class Members

The Plaintiffs are representatives of a class of persons, resident or situated in Saskatchewan, more particularly described as follows:

(a) Any person in Saskatchewan, who is taking or has taken Avandia, suffered or will suffer from one or more of the medical problems, including, but not limited to, heart failure or adverse cardiovascular events that may lead to death, heart attack or myocardial infarction (MI), renal or kidney failure, hepatitis, edema, anemia, frozen shoulder, weight gain or obesity, blindness or vision problems; or any person in Canada, who suffered or will suffer from one or more of the above-mentioned medical problems between March 21, 2000 to Jul 31, 2007.

Non-Resident Class Members

The Plaintiffs are representatives of a class of persons, not resident or situated in the Province of Saskatchewan, but who are resident or situated in another Canadian province or territory, more particularly described as follows:

(a) Any person in Canada but not in the Province of Saskatchewan, who is taking or has taken Avandia, suffered or will suffer from one or more of the medical problems, including, but not limited to, heart failure or adverse cardiovascular events that may lead to death, heart attack or myocardial infarction (MI), renal or kidney failure, hepatitis, edema, anemia, frozen shoulder, weight gain or obesity, blindness or vision problems; or who suffered or will suffer from one or more of the above-mentioned medical problems between March 21, 2000 to Jul 31, 2007.

Class Members of Deceased Relatives

The Plaintiffs are representatives of a Class of persons in Canada, whose relatives including, but not limited to, spouses, children, parents and/or sisters and brothers have died after ingesting Avandia. more particularly, the Relatives include the following:

“Spouses” mean:

(a) the wife or husband of the deceased; or

(b) a person with whom the deceased co-habitated as spouses:

(i) continuously for a period of not less than two years; or

(ii) in a relationship of some permanence, if they are the parents of a child.

“Parents” include father, mother, grandfather, grandmother, step-father, step-mother, a person who adopted a child, and a person who stood in loco parentis to the deceased; and

“Children” include son, daughter, grandson, grand-daughter, step-son, step-daughter, adopted child a person to whom the deceased stood in loco parentis.