Frequently Asked Questions

The purpose of the Settlement Notice is to inform potential Class Members of the terms of the proposed Settlement, and of a hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement, the proposed Plan of Allocation, and the motion by Class Counsel for attorneys’ fees and Litigation Expenses (the “Settlement Hearing”). See FAQ #11 for details about the Settlement Hearing, including the date and time of the hearing.
 

The issuance of the Settlement Notice is not an expression of any opinion by the Court concerning the merits of any claim in the Action, and the Court still has to decide whether to approve the Settlement.  If the Court approves the Settlement and a plan of allocation, then payments to Authorized Claimants will be made after any appeals are resolved and after the completion of all claims processing.  Please be patient, as this process can take some time to complete.
 

ChemoCentryx is a biopharmaceutical company incorporated under the laws of the State of Delaware, with its corporate headquarters and principal place of business in California. Until October 19, 2022, ChemoCentryx’s common stock traded on the NASDAQ stock exchange under the ticker symbol “CCXI.”  In the Action, Class Representative alleged that Defendants made misstatements to investors during the Class Period about the safety and efficacy of ChemoCentryx’s vasculitis drug called avacopan, and the Company’s application for FDA approval of avacopan.

The initial complaint in this action was filed on May 5, 2021.  On January 28, 2022, the Honorable Jon S. Tigar appointed Indiana Public Retirement System as Lead Plaintiff and Bernstein Litowitz Berger & Grossmann LLP as Lead Counsel for the potential Class. 

On March 28, 2022, Lead Plaintiff filed the Amended Consolidated Class Action Complaint for Violations of Federal Securities Laws (the “Complaint”). In the Complaint, Lead Plaintiff alleged that Defendants ChemoCentryx and Schall violated Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) and Securities and Exchange Commission Rule 10b-5, by making alleged misrepresentations concerning ChemoCentryx’s ADVOCATE study, the Company’s Phase 3 clinical trial of avacopan, and the Company’s communications with the FDA related to the approval of avacopan.  Lead Plaintiff alleged that these misstatements and omissions caused the price of ChemoCentryx common stock to be artificially inflated during the Class Period and caused damages to investors when the market later allegedly learned the truth allegedly concealed by Defendants’ misleading statements.  Lead Plaintiff further alleged claims under Sections 20(a) and 20A of the Exchange Act against Defendant Schall, alleging that Schall controlled ChemoCentryx when the Company made the alleged misstatements concerning avacopan in violation of Section 20(a); and that Schall sold ChemoCentryx stock while in possession of material non-public information about avacopan, and that Lead Plaintiff and other Class Members purchased ChemoCentryx stock contemporaneously with those sales, in violation of Section 20A.
 

Defendants moved to dismiss the Complaint on May 19, 2022.  On February 23, 2023, the Court issued an order granting in part and denying in part Defendants’ motion to dismiss.  Defendants filed their Answer to the Complaint on April 27, 2023. 
 

On August 25, 2023, Lead Plaintiff filed a motion for class certification. After full briefing and a hearing, on March 6, 2024, Judge Tigar issued an Order granting the motion and certifying the Class as defined in FAQ #3, appointing Lead Plaintiff as Class Representative for the Class, and appointing Lead Counsel as Class Counsel.  On May 23, 2024, the United States Court of Appeals for the Ninth Circuit denied Defendants’ petition for leave to take an immediate appeal of the Court’s order certifying the Class pursuant to Rule 23(f) of the Federal Rules of Civil Procedure. 
 

The Parties conducted a private mediation in February 2024.  No settlement was reached at that time.

On September 25, 2024, Class Representative filed an unopposed motion for Court approval of the Parties’ agreed form and manner of providing notice to the Class of pendency of the class action. On October 17, 2024, the Court entered an Order granting that motion (the “Class Notice Order”). 

Pursuant to the Class Notice Order, the Class Notice provided Class Members with the opportunity to request exclusion from the Class, explained that right, and set forth the deadline and procedures for doing so. The Class Notice informed Class Members that if they chose to remain a member of the Class, they would “be legally bound by all determinations, orders, and judgments that the Court makes in the Action, whether favorable or unfavorable.” 

The Class Notice was mailed to 35,220 potential Class Members beginning on November 13, 2024. The deadline for requesting exclusion from the Class pursuant to the Class Notice was January 14, 2025. A list of the persons and entities who requested exclusion from the Class pursuant to the Class Notice is available here. 

During discovery, Defendants produced approximately 7.8 million pages of documents and dozens of third parties (including the FDA, Amgen, and ChemoCentryx’s consultants, bankers, and former employees) produced tens of thousands of additional pages of documents. The Parties conducted 21 depositions of fact witnesses and 17 depositions of expert witnesses; and prepared and exchanged 24 expert reports.

On February 13, 2025, Class Representative and Defendants filed a total of 11 motions to exclude portions of expert testimony offered by the adverse party.  The Court heard oral argument on April 10, 2025 and decided those motions on May 21, 2025.

Class Representative filed a motion for partial summary judgment on May 8, 2025, and Defendants filed a motion for summary judgment on May 29, 2025. The Court heard oral argument on those motions on August 7, 2025.

On August 15, 2025, the Court issued an Order granting Defendants’ motion for summary judgment and denying Class Representative’s motion as moot. On the same day, the Court issued its Judgment.

On September 12, 2025, Class Representative appealed the Court’s Order Granting Defendants’ Motion for Summary Judgment and the Judgment to the Ninth Circuit Court of Appeals. On January 5, 2026, Class Representative filed its opening brief in support of its appeal. 

 On January 26, 2026, while Class Representative’s appeal was pending, the Parties executed a Memorandum of Understanding (“MOU”) reflecting an agreement in principle to settle all claims in this Action against Defendants and Defendants’ Releasees (defined below) in return for a cash payment of $35,000,000 for the benefit of the Class, subject to the execution of a customary “long form” stipulation and agreement of settlement and related papers.

 The Parties entered into a Settlement and Agreement of Settlement dated March 9, 2026 (the “Original Settlement Stipulation”) setting forth the terms and conditions of the proposed $35,000,000 settlement (the “Original Settlement”), and on March 13, 2026, Class Representative filed a motion for preliminary approval of the Original Settlement.

On April 27, 2026, after the filing of Class Representative’s motion for preliminary approval of the Original Settlement, the Center for Drug Evaluation and Research (“CDER”) of the Food and Drug Administration (“FDA”) filed a public notice proposing the withdrawal of TAVNEOS (avacopan). Following CDER’s announcement, the Parties engaged in further negotiations culminating in a revised agreement to settle all claims in this Action against Defendants and Defendants’ Releasees in return for a cash payment of $69,000,000 for the benefit of the Class. On May 15, 2026, the Parties entered into the Revised Stipulation and Agreement of Settlement (the “Stipulation”), which sets forth the full terms and conditions of the $69,000,000 Settlement and supersedes and voids the Original Settlement Stipulation and the Original Settlement. The Stipulation can be viewed here. 

On June 12, 2026, the Court preliminarily approved the Settlement, authorized notice of the Settlement to be disseminated to potential Class Members, and scheduled the Settlement Hearing to consider whether to grant final approval to the Settlement.
 

If you are a member of the Class, you are subject to the Settlement, unless you previously requested to be excluded from the Class.  The Class was certified by the Court’s Order dated March 6, 2024 and consists of:  
 

all persons who purchased or otherwise acquired the common stock of ChemoCentryx between November 26, 2019 and May 6, 2021, inclusive, and were damaged thereby

Excluded from the Class are: (a) Defendants; (b) their respective successors and assigns; (c) the past and current executive officers and directors of Defendants; (d) the Immediate Family Members of Defendant Thomas J. Schall; and (e) the legal representatives, heirs, successors, or assigns of any excluded person, and any entity in which any of the above excluded persons have or had a direct or controlling ownership interest, and the legal representatives, heirs, successors-in-interest or assigns of any such excluded persons or entities.  Also excluded from the Class are persons and entities who excluded themselves from the Class pursuant to the Class Notice. However, those persons or entities may choose to participate in the Settlement by following the instructions in FAQ #11. 

Please Note:  Receipt of this Notice does not mean that you are a Class Member or that you will be entitled to receive proceeds from the Settlement.  

If you are a Class Member and you wish to be eligible to participate in the distribution of proceeds from the Settlement, you are required to submit a Claim Form and the required supporting documentation as set forth therein postmarked (or submitted online) no later than October 1, 2026. The Claim Form is available here, and an online claim can be submitted here.
 

At the time the Settlement was reached, all claims asserted by Class Representative had been dismissed by the District Court when it entered its Order granting Defendants’ motion for summary judgment.  The Court found that all of Class Representative’s alleged misrepresentations were inactionable either because they were statements of opinion or were not misleading.  Therefore, any recovery for the Class through litigation could only be obtained if (a) Class Representative obtained a reversal of the Court’s order granting Defendants’ motion for summary judgment through its pending appeal, and (b) thereafter succeeded at trial on remand.  There were very significant risks presented by the current appeal that could have led to no recovery at all, and—even if Class Representative had succeeded on appeal and proceeded to trial—it would have faced a number of substantial arguments regarding liability and damages from Defendants. 
   

First, there was a significant risk that Class Representative might not prevail on its pending appeal.  While Class Representative believed that it had meritorious arguments for reversal, there was a substantial risk that the Court of Appeals might affirm the District Court’s order granting summary judgment.  Moreover, even if Class Representative prevailed on the appeal, the District Court could still potentially grant summary judgment again to Defendants on other grounds that the Court did not reach the first time.  Finally, even if Class Representative was able to bring its claims to trial, it would still face significant challenges at trial in proving that the alleged misstatements were false and misleading and in proving damages.
 

In light of these and other risks, the amount of the Settlement, and the immediacy of recovery to the Class, Class Representative and Class Counsel believe that the proposed Settlement is fair, reasonable, and adequate, and in the best interests of the Class.  The Settlement provides a substantial benefit to the Class, namely $69,000,000 in cash (less the various deductions described in this Notice), as compared to the risk that the claims in the Action would produce a smaller recovery, or no recovery at all, after further pretrial proceedings, at trial, and on any appeals, possibly years in the future.
   

Defendants expressly deny that Class Representative has asserted any valid claims as to any of them, and expressly deny any and all allegations of fault, liability, or wrongdoing whatsoever.  Defendants further deny that Class Members were harmed or suffered any damages as a result of the conduct alleged in the Action.  Defendants have agreed to the Settlement solely to eliminate the risks, burdens, and expense of continued litigation.  Accordingly, the Settlement may not be construed as an admission of any wrongdoing by Defendants.
 

If there were no Settlement and Class Representative did not obtain a reversal of the District Court’s Order Granting Defendants’ Motion for Summary Judgment on its pending appeal, then neither Class Representative nor the other Class Members would recover anything from Defendants.  Likewise, if the appeal was successful, but Class Representative failed to establish any essential legal or factual element of its claims against Defendants at trial, Class Members would recover nothing from Defendants.  Also, if Defendants were successful in proving any of their defenses, either at trial or on a subsequent appeal, the Class could recover less than the amount provided in the Settlement, or nothing at all.

As a Class Member, you are represented by Class Representative and Class Counsel, unless you enter an appearance through counsel of your own choice at your own expense.  You are not required to retain your own counsel, but if you choose to do so, such counsel must file a notice of appearance on your behalf and must serve copies of his or her appearance on the attorneys listed in the section entitled, “When And Where Will The Court Decide Whether To Approve The Settlement?,” FAQ #11.
 

If you are a Class Member and you wish to object to the Settlement, the Plan of Allocation, or Class Counsel’s application for attorneys’ fees and Litigation Expenses, you may present your objections by following the instructions in the section entitled, “When And Where Will The Court Decide Whether To Approve The Settlement?,” FAQ #11.
 

If you are a Class Member, you will be bound by any orders issued by the Court.  If the Settlement is approved, the Court will enter a judgment (the “Judgment”).  The Judgment will dismiss with prejudice the claims against Defendants and will provide that, upon the Effective Date of the Settlement, Class Representative and each of the other Class Members, on behalf of themselves, and their respective heirs, executors, administrators, predecessors, successors, assigns, parents, affiliates, representatives, attorneys, and agents, in their capacities as such, shall be deemed to have, and by operation of law and of the Judgment or the Alternate Judgment, if applicable, shall have fully, finally, and forever compromised, settled, released, resolved, relinquished, waived, and discharged each and every Released Plaintiff’s Claim (as defined below) against Defendants and the other Defendants’ Releasees (as defined below), and shall forever be barred and enjoined from prosecuting any or all of the Released Plaintiff’s Claims directly or indirectly against any of the Defendants and the other Defendants’ Releasees.
 

“Released Plaintiff’s Claims” means all claims (including “Unknown Claims” as defined below), disputes, demands, losses, liabilities, rights, damages, losses, actions or causes of action, obligations, sums of money due, judgments, suits, amounts, matters, issues and charges of any kind whatsoever (including, but not limited to, any claims for interest, attorneys’ fees, expert or consulting fees, and any other costs, expenses, amounts, or liabilities whatsoever) of every nature and description whatsoever, whether in law or in equity, that have been or could have been asserted in the Action or could in the future be asserted in any forum, whether foreign or domestic, whether arising under federal, state, common, or foreign law, by Class Representative, any member of the Class, or their respective successors, assigns, parents, affiliates, executors, administrators, representatives, attorneys, and agents, in their capacities as such, whether brought directly or indirectly against any of the Defendants’ Releasees, that (a) arise out of, are based on, or relate in any way to any of the allegations, claims, disclosures, acts, transactions, facts, events, circumstances, matters, occurrences, conduct, failures to act, statements, representations or omissions involved, set forth, alleged or referred to in the Action (or any complaint filed in the Action) or which could have been alleged or referred to in the Action, and (b) arise out of, are based on, or relate to the purchase or acquisition of ChemoCentryx common stock during the Class Period. “Released Plaintiff’s Claims” does not, however, include (i) any claims to enforce the settlement; or (ii) any claims of any person or entity who or which is excluded from the Class.  
 

“Defendants’ Releasees” means (i) Defendants, (ii) each of their respective past, present and future Immediate Family Members (for individuals) and each of their direct or indirect parent entities, subsidiaries, related entities and affiliates, any trust of which Defendant Thomas J. Schall is the settler or which is for the benefit of any Defendant and/or member(s) of his or his family, (iii) Amgen, Inc., and (iv) for any of the entities included in (i), (ii) or (iii), their respective past, present and future general partners, limited partners, principals, shareholders, joint venturers, parent entities, subsidiaries, related entities and affiliates, members, officers, directors, managers, managing directors, supervisors, employees, contractors, consultants, experts, auditors, accountants, financial advisors, professional advisors, investment bankers, representatives, insurers, trustees, trustors, agents, attorneys (including Defendants’ counsel and all other counsel who have represented any current or former Defendant in the Action), professionals, parents, predecessors, successors, assigns, heirs, executors, administrators, estates, beneficiaries, foundations and any controlling person thereof, in their capacities as such, and any entity in which a Defendant has a controlling interest.
 

“Unknown Claims” means any and all Released Plaintiff’s Claims against the Defendants’ Releasees that Class Representative, Class Counsel, or any Class Member does not know or suspect to exist in his, her, their, or its favor at the time of their release, and any and all Released Defendants’ Claims against the Plaintiff’s Releasees that any Defendant does not know or suspect to exist in his, her, their, or its favor at the time of their release, including without limitation those that, if known might have affected in any way his, her, their, or its decision(s) with respect to the settlement or the releases.  With respect to any and all Released Claims, the Parties agree that, upon the Effective Date of the Settlement, Class Representative and each Defendant shall expressly waive, and each Class Member shall be deemed to have waived, and by operation of the judgment shall have waived, any and all provisions, rights, and benefits conferred by any law of any state or territory of the United States, or principle of common law, which is similar, comparable, or equivalent to Cal. Civ. Code §1542, which provides:
 

A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party.

Class Representative, other Class Members, and Defendants may hereafter discover facts, legal theories, or authorities in addition to or different from those which any of them now knows or believes to be true with respect to the subject matter of the Released Claims, but Class Representative, each Class Member, and Defendants shall be deemed to have settled and released, and upon the Effective Date and by operation of the Judgment have settled and released, fully, finally, and forever, any and all Released Claims, as applicable, without regard to the subsequent discovery or existence of such different or additional facts, legal theories, or authorities. Class Representative and Defendants acknowledge, and each of the other Class Members shall be deemed by operation of law to have acknowledged, that the foregoing waiver was separately bargained for and a key element of the Settlement.
 

The Judgment will also provide that, upon the Effective Date of the Settlement, Defendants, on behalf of themselves, and their respective heirs, executors, administrators, predecessors, successors, assigns, parents, affiliates, representatives, attorneys, and agents, in their capacities as such, will have fully, finally, and forever compromised, settled, released, resolved, relinquished, waived, and discharged each and every Released Defendants’ Claim (as defined below) against Class Representative and the other Plaintiff’s Releasees (as defined below), and shall forever be barred and enjoined from prosecuting any or all of the Released Defendants’ Claims directly or indirectly against any of the Plaintiff’s Releasees.
 

“Released Defendants’ Claims” means all claims (including “Unknown Claims” as defined above), disputes, demands, liabilities, losses, rights, and causes of action of any nature whatsoever, obligations, sums of money due, judgments, suits, amounts, matters, issues and charges of any kind whatsoever (including, but not limited to, any claims for interest, attorneys’ fees, expert or consulting fees, and any other costs, expenses, amounts, or liabilities whatsoever) of every nature and description whatsoever, whether in law or in equity, that have been or could have been asserted in the Action or could in the future be asserted in any forum, whether foreign or domestic, whether arising under federal, state, common, or foreign law, by the Defendants’ Releasees or any of them against Class Representative, members of the Class, or Class Counsel (including, but not limited to, any of its current and former partners or employees), which: (a) arise out of or relate in any way to the institution, prosecution, assertion, settlement, or resolution of the Action (except for claims to enforce the settlement) or (b) relate to conduct of, or acts undertaken by, Class Counsel during the prosecution or investigation of the Action or any claims asserted in the Action; including without limitation any claims for defamation, slander, or libel.
 

"Plaintiff’s Releasees” means (i) Lead Plaintiff and the members of the Class, and (ii) each of their respective past, present and future family members, and their respective past, present and future general partners, limited partners, principals, shareholders, joint venturers, members, officers, directors, managers, managing directors, supervisors, employees, contractors, consultants, experts, auditors, accountants, financial advisors, professional advisors, investment bankers, representatives, insurers, trustees, trustors, agents, attorneys (including Lead Counsel and all other counsel who have represented any current or former plaintiff or proposed putative class in the Action), professionals, parents, predecessors, successors, assigns, heirs, executors, administrators, estates, beneficiaries, foundations and any controlling person thereof, in their capacities as such.
 

To be eligible for a payment from the Settlement, you must be a member of the Class and you must timely complete and return the Claim Form with adequate supporting documentation postmarked (if mailed), or submitted online no later than October 1, 2026.  You may obtain a Claim Form from the website maintained by the Claims Administrator for the case, here.  You may also request that a Claim Form be mailed to you by calling the Claims Administrator toll-free at 1-833-522-2606 or by emailing the Claims Administrator at [email protected].  Please retain all records of your ownership of and transactions in ChemoCentryx common stock, as they will be needed to document your Claim.  The Parties and Claims Administrator do not have information about your transactions and holdings in ChemoCentryx common stock.
 

If you do not submit a timely and valid Claim Form, you will not be eligible to share in the Net Settlement Fund.  
 

At this time, it is not possible to make any determination as to how much any individual Class Member may receive from the Settlement.
 

Pursuant to the Settlement, Defendants have agreed to cause $69,000,000 in cash (the “Settlement Amount”) to be paid into an escrow account.  The Settlement Amount plus any interest earned thereon is referred to as the “Settlement Fund.”  If the Settlement is approved by the Court and the Effective Date occurs, the “Net Settlement Fund” (that is, the Settlement Fund less (a) all federal, state and/or local taxes on any income earned by the Settlement Fund and the reasonable costs incurred in connection with determining the amount of and paying taxes owed by the Settlement Fund (including reasonable expenses of tax attorneys and accountants); (b) the reasonable costs and expenses incurred in connection with providing notices to Class Members and administering the Settlement on behalf of Class Members; (c) any attorneys’ fees and Litigation Expenses awarded by the Court; and (d) any other costs or fees approved by the Court) will be distributed to Class Members who submit valid Claim Forms, in accordance with the proposed Plan of Allocation or such other plan of allocation as the Court may approve. 
 

The Net Settlement Fund will not be distributed unless and until the Court has approved the Settlement and a plan of allocation, and the time for any petition for rehearing, appeal or review, whether by certiorari or otherwise, has expired.
 

Neither Defendants nor any other person or entity that paid any portion of the Settlement Amount on their behalf are entitled to get back any portion of the Settlement Fund once the Court’s order or judgment approving the Settlement becomes Final.  Defendants shall not have any liability, obligation, or responsibility for the administration of the Settlement, the disbursement of the Net Settlement Fund, or the plan of allocation.  
 

Approval of the Settlement is independent from approval of a plan of allocation.  Any determination with respect to a plan of allocation will not affect the Settlement, if approved.  
 

Unless the Court otherwise orders, any Class Member who fails to submit a Claim Form postmarked (or submitted online) on or before October 1, 2026 shall be fully and forever barred from receiving payments pursuant to the Settlement but will in all other respects remain a Class Member and be subject to the provisions of the Stipulation, including the terms of any Judgment entered and the releases given.  This means that each Class Member releases the Released Plaintiff’s Claims (as defined in ¶ 37 above) against the Defendants and other Defendants’ Releasees (as defined in FAQ #6) and will be barred and enjoined from prosecuting any or all of the Released Plaintiff’s Claims directly or indirectly against any of the Defendants and the other Defendants’ Releasees whether or not such Class Member submits a Claim Form.
 

Participants in and beneficiaries of any employee retirement and/or benefit plan covered by ERISA (“ERISA Plan”) should NOT include any information relating to shares of ChemoCentryx common stock purchased or held through the ERISA Plan in any Claim Form they submit in this Action.  They should include ONLY shares of ChemoCentryx common stock purchased or held outside of an ERISA Plan.  Claims based on any ERISA Plan’s purchases or holdings of ChemoCentryx common stock may be made by the plan’s trustees.
 

The Court has reserved jurisdiction to allow, disallow, or adjust on equitable grounds the claim of any Class Member.  
 

Each Claimant shall be deemed to have submitted to the jurisdiction of the Court with respect to his, her, or its Claim Form.
 

Only Class Members or persons authorized to submit a claim on their behalf will be eligible to share in the distribution of the Net Settlement Fund.  Persons and entities that are excluded from the Class by definition or that previously excluded themselves from the Class pursuant to request will not be eligible to receive a distribution from the Net Settlement Fund and should not submit Claim Forms. 
 

Appendix A to this Notice sets forth the Plan of Allocation for allocating the Net Settlement Fund among Authorized Claimants, as proposed by Class Representative.  At the Settlement Hearing, Class Representative will request that the Court approve the Plan of Allocation.  The Court may modify the Plan of Allocation, or approve a different plan of allocation, without further notice to the Class.
 

Class Counsel has not received any payment for its services in pursuing claims against the Defendants on behalf of the Class, and has not been reimbursed for its out-of-pocket expenses.  Before final approval of the Settlement, Class Counsel will apply to the Court for an award of attorneys’ fees in an amount not to exceed 22% of the Settlement Fund.  At the same time, Class Counsel also intends to apply for payment of Litigation Expenses in an amount not to exceed $5 million.  

Class Counsel’s motion for attorneys’ fees and Litigation Expenses will be filed by September 10, 2026.  A copy of Class Counsel’s motion will be available for review here.  The Court will determine the amount of any award of attorneys’ fees or Litigation Expenses.  Such sums as may be approved by the Court will be paid from the Settlement Fund.  Class Members are not personally liable for any such fees or expenses. 
 

As this Class was previously certified and Class Members had the opportunity to request exclusion from the Class in connection with class certification, the Court has exercised its discretion not to allow a second opportunity to request exclusion in connection with the Settlement proceedings.

However, if you previously submitted a request for exclusion from the Class in connection with the Class Notice, you may elect to opt back into the Class and be eligible to receive a payment from the Settlement.  In order to opt back into the Class, you, individually or through counsel, must submit a written Request to Opt Back Into the Class addressed as follows: ChemoCentryx Securities Litigation, c/o Kroll Settlement Administration P.O. Box 5013 New York, NY 10150-5013.  This request must be received no later than September 21, 2026.  Your Request to Opt Back Into the Class must (a) state the name, address and telephone number of the person or entity requesting to opt back into the Class; (b) state that such person or entity “requests to opt back into the Class in Homyk v. ChemoCentryx, Inc., Master File No. 4:21-cv-03343-JST” and (c) be signed by the person or entity requesting to opt back into the Class or an authorized representative.  If you opt back into the Class, you will be bound by the Judgment and the release discussed in FAQ #6 and you will not be able to bring or continue your own litigation concerning any of the Released Plaintiff’s Claims.

Please note:  Opting back into the Class in accordance with the requirements set forth above does not mean that you will automatically be entitled to receive proceeds from the Settlement.  If you opt back into the Class and you wish to be eligible to participate in the distribution of proceeds from the Settlement, you are also required to submit the Claim Form and the required supporting documentation as set forth therein by no later than October 1, 2026.
 

Class Members do not need to attend the Settlement Hearing.  The Court will consider any submission made in accordance with the provisions below even if a Class Member does not attend the hearing.  You can participate in the Settlement without attending the Settlement Hearing.  

Please Note:  The date and time of the Settlement Hearing may change without further written notice to Class Members.  In order to determine whether the date and time of the Settlement Hearing have changed, it is important that you monitor the Court’s docket in the Action through the Federal Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.cand.uscourts.gov or this website before making any plans to attend the Settlement Hearing.  Any updates regarding the Settlement Hearing, including any changes to the date or time of the hearing or updates regarding in-person or remote appearances at the hearing, will be posted to this website.

The Settlement Hearing will be held on October 29, 2026 at 2:00 p.m. Pacific time, before the Honorable Jon S. Tigar of the United States District Court for the Northern District of California, by Zoom videoconference.  At the Settlement Hearing, the Court will consider: (a) whether the proposed Settlement is fair, reasonable, and adequate to the Class, and should be finally approved; (b) whether a Judgment substantially in the form attached as Exhibit B to the Stipulation should be entered dismissing the Action with prejudice against Defendants; (c) whether the proposed Plan of Allocation for the proceeds of the Settlement is fair and reasonable and should be approved; (d) whether the motion by Class Counsel for attorneys’ fees and Litigation Expenses should be approved; and (e) other matters that may properly be brought before the Court in connection with the Settlement.  If you plan to attend the hearing, you should check this website, or with Class Counsel to obtain information about how to access the Settlement Hearing and to confirm that no change to the date or time of the hearing has been made.  The Court reserves the right to approve the Settlement, the Plan of Allocation, Class Counsel’s motion for attorneys’ fees and Litigation Expenses, and/or any other matter related to the Settlement at or after the Settlement Hearing without further notice to the members of the Class.

Any Class Member may file an objection.  You may object to the proposed Settlement, the Plan of Allocation or the requested fees and expenses.  If you wish to object, your objection must be made in writing and include the following: your full name, the basis for your belief that you are a member of the Class, the basis of your objection (including whether the objection applies only to the objector, to a specific subset of the Class, or to the entire Class), and your signature.  You can ask the Court to deny approval of the Settlement by filing an objection. You can’t ask the Court to order a different settlement; the Court can only approve or reject the Settlement.  If the Court denies approval, no settlement payments will be sent out, and the lawsuit will continue.  If that is what you want to happen, you should object.

Any objection must be in writing.  If you file a timely written objection, you may, but are not required to, appear at the Settlement Hearing, either in person or through your own attorney.  If you appear through your own attorney, you are responsible for hiring and paying that attorney.  All written objections and supporting papers must (a) clearly identify the case name and number Homyk v. ChemoCentryx, Inc., Master File No. 4:21-cv-03343-JST; (b) be submitted to the Court either by filing them electronically, by mailing them to the Clerk of the Court, United States District Court for the Northern District of California, 1301 Clay Street, Suite 400S, Oakland, CA 94612, or by filing them in person at any location of the United States District Court for the Northern District of California; and (c) be filed or postmarked on or before September 21, 2026.

You may not object to the Settlement, the Plan of Allocation, or Class Counsel’s motion for attorneys’ fees and Litigation Expenses if you are not a member of the Class.

You may file a written objection without having to appear at the Settlement Hearing.  You may not, however, appear at the Settlement Hearing to present your objection unless you first file and serve a written objection in accordance with the procedures described above, unless the Court orders otherwise.

If you wish to be heard orally at the hearing in opposition to the approval of the Settlement, the Plan of Allocation, or Class Counsel’s motion for attorneys’ fees and Litigation Expenses, and if you timely file and serve a written objection as described above, you must also file a notice of appearance with the Clerk’s Office so that it is received on or before September 21, 2026.  Such persons may be heard orally at the discretion of the Court.  

You are not required to hire an attorney to represent you in making written objections or in appearing at the Settlement Hearing.  However, if you decide to hire an attorney, it will be at your own expense, and that attorney must file a notice of appearance with the Court so that the notice is received on or before September 21, 2026.

The Settlement Hearing may be adjourned by the Court without further written notice to the Class, other than a posting of the adjournment on this website. If you plan to attend the Settlement Hearing, you should confirm the date and time with Class Counsel.

Unless the Court orders otherwise, any Class Member who does not object in the manner described above will be deemed to have waived any objection and shall be forever foreclosed from making any objection to the proposed Settlement, the proposed Plan of Allocation or Class Counsel’s motion for attorneys’ fees and Litigation Expenses.  Class Members do not need to appear at the Settlement Hearing or take any other action to indicate their approval.
 

In connection with the previously disseminated Class Notice, Nominees were advised that if they purchased or otherwise acquired ChemoCentryx common stock during the Class Period (from November 26, 2019 through May 6, 2021, inclusive) for the beneficial interest of persons or entities other than themselves. they must either (a) provide a list of the names, addresses, and, if available, email addresses of all such beneficial owners to Kroll Settlement Administration (“Kroll”); or (b) request from Kroll  sufficient copies of the Class Notice to forward to all such beneficial owners for whom email addresses were not available, and then forward those Class Notices to all such beneficial owners.

If you previously provided the names and addresses of such beneficial owners identified above in connection with the Class Notice, and (i) those names and addresses remain current and (ii) you have no additional names and addresses for potential Class Members to provide to the Claims Administrator, you need do nothing further at this time.  The Claims Administrator will mail the Postcard Notice of the Settlement (“Postcard Notice”) to the beneficial owners whose names and addresses were previously provided in connection with the Class Notice mailing.

If you elected to mail or email the Class Notice directly to beneficial owners, you were advised that you must retain the mailing records for use in connection with any further notices that may be provided in the Action. If you elected this option, the Claims Administrator will forward the same number of Postcard Notices to you to send to the beneficial owners, and you must mail and/or email the Postcard Notices to those beneficial owners by no later than seven (7) calendar days after receipt of the Settlement Notice Packets.  If you require more copies of the Postcard Notice than you previously requested in connection with the Class Notice mailing, please contact the Claims Administrator, Kroll, toll-free at 1‑833-522-2606, and let them know how many notices you require.

If you have not already provided the names and addresses for all persons and entities on whose behalf you purchased or acquired ChemoCentryx common stock from November 26, 2019 through May 6, 2021, inclusive; or if you have additional names or updated or changed information, then the Court has ordered that you must, WITHIN SEVEN (7) CALENDAR DAYS OF YOUR RECEIPT OF THIS SETTLEMENT NOTICE, either: (i) send a list of the names, addresses, and, if available, email addresses of such beneficial owners to the Claims Administrator at ChemoCentryx Securities Litigation, c/o Kroll Settlement Administration, P.O. Box 5013, New York, NY 10150-5013, in which event the Claims Administrator shall promptly mail the Postcard Notice to such beneficial owners, or (ii) request from Kroll sufficient copies of the Postcard Notice to forward to all such beneficial owners, and mail or email the Postcard Notice to the beneficial owners within seven (7) calendar days of receipt.  As stated above, if you have already provided this information in connection with the Class Notice, unless that information has changed (e.g., beneficial owner has changed address), it is unnecessary to provide such information again.

Nominees, and their agents shall forward the Postcard Notice to (or identify names, mailing addresses, and e-mail addresses of) all beneficial owners who purchased or otherwise acquired ChemoCentryx common stock during the Class Period, regardless of whether or not those beneficial owners have enrolled in a claim-filing program with their broker or financial institution. 

Upon full and timely compliance with these directions, nominees may seek reimbursement of their reasonable expenses actually incurred by providing the Claims Administrator with proper documentation supporting the expenses for which reimbursement is sought.  Reasonable expenses shall not exceed $0.05 plus postage at the pre-sort rate used by the Claims Administrator per Postcard Notice mailed; $0.05 per Postcard Notice emailed; or $0.05 per mailing record provided to the Claims Administrator.  Such properly documented expenses incurred by Nominees in compliance with these directions shall be paid from the Settlement Fund, with any disputes as to the reasonableness or documentation of expenses incurred subject to review by the Court. 

This Settlement Notice contains only a summary of the terms of the proposed Settlement.  For more detailed information about the matters involved in this Action, you are referred to the papers on file in the Action, including the Stipulation, which may be reviewed by accessing the Court docket in this case through the Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.cand.uscourts.gov, or by visiting the office of the Clerk of the Court for the United States District Court for the Northern District of California, Ronald V. Dellums Federal Building & United States Courthouse, 1301 Clay Street, Suite 400S, Oakland, CA 94612, between 9:00 a.m. and 4:00 p.m., Monday through Friday, excluding Court holidays.  Additionally, copies of the Stipulation and any related orders entered by the Court will be posted on the website maintained by the Claims Administrator.
 

            All inquiries concerning this Settlement Notice and the Claim Form should be directed to:

DO NOT CALL OR WRITE THE COURT, THE OFFICE OF THE CLERK OF THE COURT, DEFENDANTS OR THEIR COUNSEL REGARDING THIS NOTICE.