Fragrance End-User Plaintiff Antitrust Settlement

An $11,000,000 settlement has been reached in a class action lawsuit that may affect you if you are a Person who, from January 1, 2018, through December 31, 2023, purchased in the United States consumer products or household goods, not for resale, which contained Fragrance Products that were manufactured or sold by Defendants or their subsidiaries or affiliates.

The Honorable William J. Martini of the United States District Court for the District of New Jersey is overseeing this class action. The lawsuit is known as In re Fragrance End-User Plaintiff Antitrust Litigation, Case No. 2:23-cv-16127-WJM-JSA (the “lawsuit”).

In the Notice, “Defendants” refers to International Flavors and Fragrances, Inc. (“IFF”) and Defendants Givaudan SA; Givaudan Fragrances Corporation; Ungerer & Company, Inc.; Custom Essence LLC; DSM-Firmenich AG; Firmenich International SA; Firmenich Inc.; Agilex Flavors & Fragrances, Inc.; Symrise AG; Symrise Inc.; and Symrise US LLC; and “Settling Defendant” refers to IFF.

End-User Plaintiffs have reached this Settlement with IFF. However, the End-User Plaintiffs’ lawsuit is continuing against other Defendants. There may be future, separate settlements, judgments, or orders for the other Defendants. If that happens, separate notice will be provided.

The End-User Plaintiffs allege Defendants engaged in an unlawful conspiracy to restrain trade, by, among other things, increasing and fixing the prices of Fragrance Products in violation of the Sherman Act, a federal antitrust law, various state antitrust and consumer protection laws, and state laws of unjust enrichment. End-User Plaintiffs allege Settlement Class Members purchased products containing Fragrance Products from one or more Defendants at artificially inflated prices.

IFF denies the legal claims and denies any wrongdoing or liability. No court has made any judgment or other decision of any wrongdoing by IFF or that any law has been violated.

In a class action, one or more people (called class representatives) sue on behalf of all people who have similar legal claims. Together, all these people are called a class or class members. One court resolves the issues for all class members, except for those class members who timely exclude themselves (opt out) from the class.

End-User Plaintiffs and IFF have agreed to settle the lawsuit. The Class Representatives, IFF, and their lawyers believe the Settlement is best for the Settlement Class versus the risks and uncertainty associated with continuing the lawsuit.

The Settlement Class includes all Persons who, from January 1, 2018, through December 31, 2023, purchased in the United States consumer products or household goods, not for resale, which contained Fragrance Products that were manufactured or sold by Defendants or their subsidiaries or affiliates.

So long as the purchase was made in the United States, it does not matter whether it was (i) from a seller located outside the United States, or (ii) from a seller in the United States that acquired Fragrance Products manufactured or sold by Defendants outside the United States from that seller’s foreign affiliate, or from Defendants or their subsidiaries or affiliates.

Yes. Excluded from the Settlement Class are purchasers who purchased Fragrance Products directly from Defendants; purchasers who purchased Fragrance Products manufactured by Defendants other than directly from Defendants for incorporation in finished consumer products or household goods, Defendants, IFF Released Parties, conspirators; the officers, directors, or employees of any Defendant or conspirator; any entity in which any Defendant or conspirator has a controlling interest; any affiliate, legal representative, heir, or assign of any Defendant or co-conspirator; and any Person acting on their behalf. Also excluded from the Class are any judicial officer presiding over the lawsuit and the members of their immediate family and judicial staff, and any juror assigned to the lawsuit, as well as any Person who or which submits a valid and timely request for exclusion in accordance with the requirements set forth in the Notice and whose request is accepted by the Court.

Fragrance Products means fragrance ingredients, fragrance formulas, and fragrance compounds, regardless of whether they are natural, synthetic or otherwise, and include related auxiliary technologies, including those intended to deliver the fragrance. Fragrance Products include, without limitation, consumer fragrances and fine fragrances.

A list of consumer products and household goods containing Fragrance Products included in the Settlement will be available at a future date on this website.

If you are still not sure whether you are included in the Settlement Class, you may review the detailed Notice by clicking here or call toll-free at 1-877-269-9876 (recorded information only).

If the Settlement is approved, IFF will pay $11,000,000 to resolve all Settlement Class Members’ legal claims against IFF for the Settlement Class Released Claims. In addition, IFF has agreed to certain non-monetary relief and to provide specified cooperation in the End-User Plaintiffs’ continued pursuit of the lawsuit.

No money will be distributed to Settlement Class Members at this time. Class Counsel will continue the lawsuit against the other non-settling defendants. Additional money may become available in the future because of a trial or future settlements. Alternatively, the lawsuit may be resolved in favor of the other non-settling defendants, and no additional money may become available. There is no guarantee as to what will happen. Settlement Class Members will be notified later, when there is an opportunity to submit a Claim Form to receive a payment.

Please register by clicking here, to receive future updates about the Settlement, such as an opportunity to submit a claim and to be notified about any future settlements.

If you are a Settlement Class Member and unless you exclude yourself (opt out), you will remain in the Settlement Class. If the Settlement is approved and becomes final, all Court orders and any judgments will apply to you and legally bind you. You will not be able to sue, continue to sue, or be part of any other lawsuit against the Released Parties about the Settlement Class Released Claims in this lawsuit. The specific rights you are giving up are called “Settlement Class Released Claims.”

By staying in the Settlement, you are not releasing your legal claims in this lawsuit against any Defendant other than IFF.

The Settlement Agreement, paragraphs 1.v, 1.kk, 1.oo and 4-11 describe the Releases, Settlement Class Released Claims, and IFF Released Parties, in necessary legal terminology, so please read this section carefully. The Settlement Agreement is available here. For questions regarding the Releases, Settlement Class Released Claims, or IFF Released Parties and what the language in the Settlement Agreement means, you can also contact Class Counsel listed in FAQ 20 below for free, or you can talk to your own lawyer at your own expense.

At this time, it is unknown how much each Settlement Class Member who submits a valid claim will receive when the claims process is available in the future. Payments will be determined on a pro rata basis (a legal term meaning equal share). This means payments will be based on the number of valid claims filed by all Settlement Class Members as well as on the number and type of consumer products or household goods containing Fragrance Products you purchased. It’s possible that any money remaining after claims are paid will be distributed to charities, governmental entities, or other beneficiaries approved by the Court. No matter how many claims are filed, no money will be returned to the settling defendant once the Court finally approves the Settlement. To receive a payment, you will need to file a valid claim form before the claims period ends. The claims period has not yet begun. A notice about the claims process will be provided later as ordered by the Court. If you want to receive a notice about the claims process or future settlements, you should register by clicking here.

No money will be paid yet. The lawyers for the Plaintiffs will continue to pursue the lawsuits against the non-settling Defendants. All Settlement Funds that remain after payment of the fees, costs, and expenses will be paid together at the conclusion of the lawsuit or as ordered by the Court.

The settling defendant has agreed to cooperate with the Plaintiffs in their ongoing lawsuit against the other non-settling defendants.

If you are a Settlement Class Member and do nothing, you will remain a member of the Settlement Class and may participate in the IFF Settlement and submit a Claim Form when that option is available later. You will also have the opportunity to participate in any future settlements or judgments obtained by End-User Plaintiffs against other Defendants in the lawsuit.

If you want to sue the IFF Released Parties on your own regarding the Settlement Class Released Claims or already have your own lawsuit against the IFF Released Parties regarding the Settlement Class Released Claims and you want to continue with it, you need to ask to be excluded from the Settlement Class. If you exclude or remove yourself from the Settlement Class—sometimes called “opting out” of the class—you will not get any money or benefits from this Settlement. However, you may be able to sue or continue to sue the IFF Released Parties on your own. If you exclude yourself, you will not be legally bound by the Court’s judgments in this Settlement.

If you start your own lawsuit or continue with an existing lawsuit against the IFF Released Parties regarding the Settlement Class Released Claims after you exclude yourself, you will have to hire your own lawyer(s) for that lawsuit, and you will have to prove your legal claims. If you exclude yourself so you can start or continue your own lawsuit against the IFF Released Parties, you should talk to your own lawyer soon, because your legal claims may be subject to a statute of limitations, meaning there is a deadline after which you cannot sue.

By staying in the Settlement, you are not releasing your legal claims in this lawsuit against any Defendant other than IFF.

To exclude yourself from the Settlement Class, you must mail a written request for exclusion, which includes the following:

1. Your name, address, and telephone number;
2. Proof of membership in the Settlement Class, including a declaration or documentation evidencing the purchase in the United States during the Class Period of consumer products or household goods, not for resale, which contained Fragrance Products that were manufactured or sold by Defendants;
3. Your personal physical signature; and
4. A statement that you want to be excluded from the Settlement Class, such as, “I hereby request that I be excluded from the Settlement Class in In re Fragrance End-User Plaintiff Antitrust Litigation.”

The exclusion request must be mailed to the Claims Administrator at the following address, and be postmarked by July 27, 2026:

In re Fragrance End-User Plaintiff Antitrust Litigation
Claims Administrator
P.O. Box 4676
Portland, OR 97208-4676

Please note per the United States Postal Service, mail may not be postmarked the day it is deposited in a mailbox or at a local post office. Postmarks occur when mail reaches a processing facility. To meet a postmark deadline, mail at least a week prior to a postmark deadline, get a manual postmark in-person at any post office, or send via Certified Mail.

You cannot opt out (exclude yourself) by telephone or by email.

You cannot exclude yourself by participating in a “mass” or “class” request for exclusion filed by a third party where the opt-out hasn’t been signed by each individual Settlement Class Member requesting exclusion.

No. If you exclude yourself you will no longer be a member of the Settlement Class and you will not be able to receive any money or benefits from this Settlement, which may happen later. You will not be legally bound by the Court’s judgments if you exclude yourself. You will be able to sue (or continue to sue) the IFF Released Parties on your own about the legal claims that are involved in this Settlement, now or in the future, assuming your legal claims are not time-barred or otherwise prohibited (you should consult your own lawyer to make such a determination).

No. Unless you exclude yourself, from the Settlement Class, you give up the right to sue IFF for the legal claims the Settlement involves. If you have a pending lawsuit against IFF, speak to your lawyer for that lawsuit immediately to determine whether you must exclude yourself from this lawsuit to continue your own lawsuit against IFF.

By staying in the Settlement, you are not releasing your legal claims in this lawsuit against any Defendant other than IFF.

If you are a Settlement Class Member, you can tell the Court you do not agree with all or any part of the Settlement and/or attorneys’ fees, costs, and service awards.

To object, you must file your timely written objection with the Court as provided below by August 17, 2026, and send by U.S. Mail to Class Counsel, and IFF’s Counsel postmarked by August 17, 2026, stating you object to the Settlement in In re Fragrance End-User Plaintiff Antitrust Litigation, Case No. 2:23-cv-16127-WJM-JSA.

To file an objection, you cannot exclude yourself from the Settlement Class. Your objection must include all the following information:

1. Your full name, mailing address, and telephone number;
2. Notice of intention to appear if you wish to speak at the Fairness Hearing;
3. Proof of membership in the Settlement Class, including a declaration or documentation evidencing the purchase of consumer products or household goods containing Fragrance Products during the Class Period;
4. The specific grounds for the objection and any reasons why you desire to appear and be heard, as well as documents or writings that you desire the Court to consider;
5. Identify whether your objection is to the Settlement in part or in whole;
6. State whether the objection applies only to you as the objector, a subset of the Settlement Class, or the entire Settlement Class;
7. A list of all lawsuits in which you have acted as an objector or lawyer for an objector within the last five (5) years; and
8. Your signature as the objector (a lawyer’s signature is not sufficient).
9. To object, you must file your timely written objection with the Court by August 17, 2026, and send it by U.S. Mail to Class Counsel, and IFF’s Counsel postmarked by August 17, 2026, at the following addresses:
   
   

   Court	Class Counsel	IFF's' Counsel
   Clerk U.S. District Court District of New Jersey Martin Luther King Building & U.S. Courthouse 50 Walnut Street Room 4015 Newark, NJ 07101	Kimberly A. Justice Freed Kanner London & Millen LLC 923 Fayette St. Conshohocken, PA 19428 Kellie Lerner Shinder Cantor Lerner LLP 14 Penn Plaza, 19th Floor New York, NY 10122	Boris Bershteyn Skadden, Arps, Slate, Meagher & Flom LLP One Manhattan West New York, NY 10001

   Please note per the United States Postal Service, mail may not be postmarked the day it is deposited in a mailbox or at a local post office. Postmarks occur when mail reaches a processing facility. To meet a postmark deadline, mail at least a week prior to a postmark deadline, get a manual postmark in-person at any post office, or send via Certified Mail.

Objecting is simply telling the Court that you do not like something about the Settlement. You can object only if you stay in the Settlement Class. Opting out is telling the Court that you do not want to be part of the Settlement Class. If you opt out, you cannot object because you are no longer part of the Settlement Class.

Yes, the Court has appointed Kellie Lerner of Shinder Cantor Lerner LLP, and Kimberly A. Justice of Freed Kanner London & Millen LLC as Class Counsel for the Settlement Class to represent you and the class for the purposes of this lawsuit. You may hire your own lawyer at your own cost and expense if you want someone other than Class Counsel to represent you in this lawsuit.

You do not need to hire your own lawyer because Class Counsel is working on your behalf. If you want your own lawyer, you can hire your own lawyer at your own expense. For example, you can ask them to appear in Court for you if you want someone other than Class Counsel to speak for you.

At the Fairness Hearing, Class Counsel will ask the Court to: (a) reimburse them for certain costs and expenses, (b) set aside up to $1,000,000 for future lawsuit costs and expenses as the lawsuit against the other Defendants continues. At the Fairness Hearing or at a later date, Class Counsel will ask the Court for attorneys’ fees based on their services in this lawsuit, not to exceed 33 1/3% of the Settlement Fund. Class Counsel may also ask the Court to approve service awards not to exceed $7,500 each for the Class Representatives for their efforts on behalf of the Class. Any payment to the attorneys and Class Representatives will be subject to Court approval, and the Court may award less than the requested amount. The fees, costs, expenses, and awards that the Court orders, plus the costs to administer the Settlement, will be paid out of the Settlement Fund. Class Counsel may request additional attorneys’ fees, costs, and expenses from any other settlements or money obtained in the future.

When Class Counsel’s motion for attorneys’ fees, costs, or service awards is filed, it will be available on this website. The motion will be posted on this website before the deadline for objecting to the Settlement. You will have an opportunity to object to this request. Register by clicking here to receive notice when the motion is filed.

The Court will hold a Fairness Hearing on September 15, 2026 at 10:00 a.m. before the Honorable William J. Martini at the Martin Luther King Building & U.S. Courthouse, 50 Walnut Street, Room 4015, Newark, NJ 07101. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate and decide whether to approve the Settlement, and any request by Class Counsel for reimbursement of costs and expenses, a set aside for future lawsuit costs and expenses, and/or an award of attorneys’ fees.

If there are objections that were filed by the deadline, the Court will consider them. If you file a timely objection, and you (or your lawyer) ask to speak at the hearing, the Court may hear objections at the hearing.

Note: The date and time of the Fairness Hearing are subject to change without further notice to the Settlement Class. The Court may also decide to hold the hearing via video conference or by telephone. You should check this website to confirm the date and time of the Fairness Hearing have not changed.

No. Class Counsel will answer any questions the Court may have. However, you are welcome to attend at your own expense. If you file an objection, you do not have to attend the Fairness Hearing to speak about it. If you file your written objection by the deadline, the Court will consider it.

If there are objections that were filed by the deadline, the Court will consider them. If you file a timely objection, and you (or your lawyer) ask to speak at the hearing, the Court may hear objections at the hearing

These frequently asked questions summarize the lawsuit and the proceedings. You can get additional information by reviewing the Long Form Notice and other court documents here, by calling 1-877-269-9876 (recorded information only) or by writing to:

In re Fragrance End-User Plaintiff Antitrust Litigation
Claims Administrator
P.O. Box 4676
Portland, OR 97208-4676

PLEASE DO NOT TELEPHONE THE COURT OR THE COURT CLERK’S OFFICE REGARDING THE NOTICE.