UNITED STATES BANKRUPTCY COURT FOR THE WESTERN … · Nielsen Company and is used for planning, buying and evaluating media audiences across various markets.! 7 Formerly known as

UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA

Charlotte Division

IN RE: ) ) Case No. 10-31607

GARLOCK SEALING TECHNOLOGIES ) LLC, et al., ) Chapter 11 )

Debtors1 ) )

AFFIDAVIT OF SHANNON R. WHEATMAN, PH.D. REGARDING IMPLEMENTATION OF PLAN NOTIFICATION PROGRAM

I, Shannon R. Wheatman, being duly sworn, hereby declare as follows:

1. I am president of Kinsella Media, LLC (“KM”), an advertising and legal notification

firm in Washington, D.C. specializing in the design and implementation of notification

programs to reach unidentified putative class members primarily in consumer and

antitrust class actions and claimants in bankruptcy and mass tort litigation. My

business address is 2101 L Street NW, Suite 800, Washington, D.C. 20037. My

telephone number is (202) 686-4111.

2. I submit this affidavit at the request of Counsel for Debtors in connection with In re

Garlock Sealing Technologies, LLC pending in the United States Bankruptcy Court for

the Western District of North Carolina, Charlotte Division.2

1 The debtors in these jointly administered cases are Garlock Sealing Technologies LLC; Garrison Litigation Management Group, Ltd.; The Anchor Packing Company; and OldCo, LLC. 2 KM implemented the Second Amended Plan Confirmation Procedures in the instant case in 2015.

Case 10-31607 Doc 5919 Filed 05/08/17 Entered 05/08/17 18:55:47 Desc Main Document Page 1 of 26

AFFIDAVIT OF SHANNON R. WHEATMAN 2

3. This affidavit is based upon my personal knowledge and upon information provided by

Debtors’ Counsel, my associates, and staff. The information is of a type reasonably

relied upon in the fields of advertising, media, and communications.

4. KM was retained to design and implement the Proposed Notice Program in connection

with the Joint Plan of Reorganization of Garlock Sealing Technologies LLC, et al. and

OldCo, LLC, Proposed Successor by Merger to Coltec Industries Inc (the “Plan”).

This affidavit outlines the implementation of that Notice Program and the measures

taken to provide the best notice of the Proposed Notice Program that was practicable

under the circumstances.

Notice Program

5. The objective of the Notice Program was to provide fair and adequate notice of the

Plan of Reorganization and the Claims Resolution Procedures and the date by which

votes for or against the Plan must be cast by Asbestos Personal Injury Claimants

(“Asbestos Claimants”) who may have claims against Garlock Sealing Technologies

LLC (“Garlock”) or Coltec Industries Inc (“Coltec”) and their affiliates, in the United

States, its territories, and its commonwealths, and Canada. The Notice Program also

provided information on a proposed Bar Date that pertains only to asbestos personal

injury claims against Coltec.

6. This Notice Program was similar in substantial respects to the one previously

developed by KM and approved by the Court in connection with the solicitation of the

Debtors Second Amended Plan of Reorganization (the “Second Amended Plan”) and

the entry of an Asbestos Claims Bar Date. The previous notice program is described in

the Affidavit of Katherine Kinsella Regarding Plan Notification Program (Doc. No.



4387-1) and in testimony by Ms. Kinsella before the Court on November 17, 2014 (See

Tr. 11/17/2014 at pp. 42-72).

7. Like the Notice Program for the solicitation of the Second Amended Plan, KM

designed a comprehensive Notice Program for the solicitation of the Plan to reach

Asbestos Claimants in the United States and Canada, which included:

a. Mailed notice directly or through attorneys to all identifiable Asbestos Claimants;

b. Broad national and local notice through the use of paid media and earned media;

and

c. Third-party outreach to labor unions in the U.S.

8. In total, Debtors expended $5,065,164.28 to implement the Notice Program described

herein.

Direct Notice

9. Direct Mail Notice consisted of the following:

a. A Notice Package, including the Plan, Disclosure Statement, and other documents

described in the Voting Procedures, was mailed to all readily identifiable Asbestos

Claimants with pending asbestos personal injury damage claims or their counsel of

record. Mailing commenced on August 22, 2016.

b. The Notice Package was sent to all callers to the toll-free information line who

requested it. The toll-free number for this information line appeared prominently

in the published forms of notice.



Paid Media Notice

United States

10. As detailed in my affidavit “Shannon R. Wheatman, Ph.D. Regarding Plan Notification

Program” (“Notification Affidavit”) (executed on June 21, 2016 and subsequently

relied upon by the Court on July 29, 2016), KM relied on historical claims data

provided by the Debtors to determine age and gender of current and potential Asbestos

Claimants. Based on this data as well as occupational, product usage, and geographic

information regarding workplace exposure to Garlock and Coltec products, KM

developed a demographic profile of likely Asbestos Claimants.

11. The primary target was Men 65 years of age and older (“Men 65+”). The secondary

target was Adults 65 years of age and older (“Adults 65+”), the tertiary target was

Adults 45 years of age and older (“Adults 45+”), and the quaternary target was Adults

35 years of age and older (“Adults 35+”).

12. The Notice Program included national television, consumer magazines, newspaper

supplements, local newspapers in the U.S. and its territories, asbestos legal

publications, and Internet networks and sites.

13. An Implementation Report for the Notice Program is attached as Exhibit 1 and

confirms that the Court-approved Notice Program was implemented. The report details

each advertisement and the date and page number upon which the advertisement

appeared. The report confirms that KM has received a true and correct copy of the

advertisement, or “tearsheet,” from each publication.3

3 Copies of the notices as they appeared in each publication are available to the Court upon request.



14. Thirty-second Television Spots, which prominently featured the toll-free number and

an informational website address for Asbestos Claimants, provided 362.37 Target

Rating Points (TRPs)4 against Men 65+. There were 606 television spots, which ran

from September 12, 2016 to October 9, 2016, and appeared on a variety of national and

cable and networks, including: ABC, CBS, CNN, Fox News, Headline News,

American Movie Classics, Independent Film Channel, and Sundance. KM confirmed

that the television spots ran as planned. The television post-buy analysis is attached as

Exhibit 2.

15. The Publication Notice appeared in the following:

a. Consumer magazines: one time each in AARP Bulletin, American Legion,

National Geographic, People, Reader’s Digest, Reader’s Digest - Large

Print Edition, and VFW.

b. Legal Publications: one time each in Harris Martin’s Asbestos Report and

Mealey's Litigation Report: Asbestos.

c. Newspaper supplements: one time each in American Profile and Parade.

d. Local newspapers in U.S. territories: one time each in El Nuevo Dia, El

Vocero, Pacific Daily News, Primera Hora, Samoa News, St. Croix Avis,

and two times in Virgin Islands Daily News.5

e. 141 local newspapers in 124 DMAs.6 The attached Implementation Report

includes a complete list of newspapers.

4 Target Rating Points (TRPs) represent the sum of all the ratings for a specific audience delivered by a given media vehicle in a schedule. A rating is the percentage of households or persons in the target who have been exposed to the media vehicles in the schedule. One TRP equals 1% of a given target population. 5 One of the newspapers reported in my Notification Affidavit, St. John's Trade Winds, no longer publishes. KM replaced this ad with a second insertion in Virgin Islands Daily News, which provided coverage in St. John. 6 Designated Market Area ("DMA") is a group of counties that form an exclusive geographic area in which



16. Banner ads appeared on the following online networks and sites for four weeks:

Advertising.com Network, Facebook.com, Viant,7 weather.com, Xaxis, and Yahoo!

Network. Attached as Exhibit 3 are true and correct copies of the banner ads and

examples of how they appeared on several websites.

17. For the purpose of evaluating the strength and efficiency of the media, the national

consumer magazines, national newspaper supplements, television, and Internet banner

advertising were measured against the target audiences to establish the estimated reach8

of the media program and the estimated frequency9 of exposure to the media vehicles.10

a. An estimated 95.4% of Men 65+ were reached with an average estimated frequency

of 5.4 times.

b. An estimated 95.1% of Adults 65+ were reached with an average estimated

frequency of 5.3 times.

c. An estimated 91.7% of Adults 45+ were reached with an average estimated


d. An estimated 90.0% of Adults 35+ were reached with an average estimated


Canada

18. KM determined that it was necessary to reach a primary target audience of Men 50

years of age and older (“Men 50+”) and a secondary target audience of Adults 50 years

the home market television stations hold a dominant share of total hours viewed. DMA is a trademark of The Nielsen Company and is used for planning, buying and evaluating media audiences across various markets. 7 Formerly known as Specific Media. 8 Reach is the estimated percentage of a target audience reached through a specific media vehicle or combination of media vehicles. 9 Frequency is the estimated average number of opportunities an audience member has to see the notice. 10 GfK MRI does not measure U.S. territories and possessions newspapers. Therefore, their contribution to the overall reach of the media is not calculated. Their inclusion in the Notice Program was still recommended, however, given the Claimants here.



of age or older (“Adults 50+”) in Canada. A broader demographic target was chosen

because Canadian television measurement is not available for Men 65+ or Adults 65+.

19. The Publication Notice appeared one time each in two national newspapers: National

Post and The Globe and Mail.

20. Thirty--second Television Spots in English and French Canadian, which prominently

featured the toll-free number and the website address for Asbestos Claimants, provided

259.07 TRPs against Men 50+. There were 670 television spots, which ran from

September 12, 2016 to October 2, 2016, and appeared on a variety of national and

cable and networks, including: CBC, CTV, RDI, Business News Network, and The

Sports Network. KM confirmed that the television spots ran as planned. The

television post-buy analysis is attached as Exhibit 2.

21. The estimated reach of the Canadian Media Program and the estimated frequency of

exposure to the media vehicles are as follows:

a. An estimated 73.8% of Men 50+ were reached with an average estimated frequency

of 2.9 times.

b. An estimated 75.8% of Adults 50+ were reached with an average estimated


Keyword Search Advertising

22. KM also sponsored keywords and phrases with all major search engines in the U.S. and

Canada, including: Google, Bing, and other search partners. When a user searched for

one of the specified search terms or phrases, sponsored links appeared on the results

page.



23. Each advertisement prominently featured a toll-free number and website address for

Asbestos Claimants to obtain more information in the form of the Notice Package.

Earned Media Notice

24. On August 29, 2016, a national multimedia news release blending text, audio, video,

photos, related documents, and social media tools into an interactive web platform was

distributed in the United States to 5,700 media points, more than 5,400 websites,

databases and online services, and journalist-only portal.

25. On August 29, 2016, a national press release on PR Newswire’s Canadian circuit was

distributed in English and French Canadian. The press release highlighted the toll-free

telephone number and the website address for Asbestos Claimants to obtain complete

information.

Third-Party Outreach

26. Third-party outreach was conducted to reach key officials in labor unions in the United

States to request their cooperation in the notice effort. Third-party outreach consisted

of mailing the Publication Notice with a cover letter to 33 trade unions whose

membership has been identified as historically having occupational exposure to

asbestos-containing products. Attached as Exhibit 4 is a complete list of the trade

unions.

27. The labor unions were asked to include information about the Plan in their union

publications that reach retirees.

Notice Website

28. An informational, interactive website is a critical component of the Notice Program. A

website is a constant information source instantly accessible to millions of claimants.



A website specifically designed for Asbestos Claimants (“Notice Website”) utilized the

Internet’s ability to serve as a key distribution channel and customer service bureau.

Internet banner and search engine advertising directed potential Asbestos Claimants to

the Notice Website.

29. The Notice website, www.GarlockNotice.com, was updated to enable potential

Asbestos Claimants to get information on the Plan.11 An overview of the Disclosure

Statement and the Plan (“Overview”) were available on the website.

30. Notice materials on the website appeared in English, French, and Spanish.

31. As of May 8, 2017, there have been a total of 89,317 unique visits to the website.

Toll-Free Telephone Support

32. A toll-free telephone number has been established to service Asbestos Claimants

calling as a result of the Notice Program. The telephone number was printed on all

Notice materials.

The Form and Content of the Notices

33. The Publication Notice was designed to capture the Asbestos Claimant’s attention with

a clear headline and plain language text. It provided important information regarding

the bankruptcy and the legal rights available to Asbestos Claimants and directed

readers to the Notice Website for the Plan and Disclosure Statement.

34. The Overview provided key information about the bankruptcy, the Plan, and

Disclosure Statement in an easy to use question and answer format that enabled

Asbestos Claimants to understand their legal rights, voting on the Plan, and how

asbestos claims will be treated.

11 The Notice Website, www.GarlockNotice.com, was first established in 2015 for the Second Amended Plan of Reorganization. The Notice Website was updated to reflect the information for this Plan.



Conclusion

35. It is my opinion that the reach of the target audiences and the number of exposure

opportunities to the notice information through significant actual notice and paid media

is the best notice practicable under the circumstances, and it is consistent with the

standards employed by KM in notification programs designed to reach both identified

and unidentified Asbestos Claimants.

I declare under penalty of perjury that the foregoing is true and correct. Executed in

Souderton, PA this 8th day of May 2017.

_________________________________

Shannon R. Wheatman, Ph.D.


EXHIBIT 1


Page 1 of 3

Issue Date

Page #of Ad

October 2016 34October 2016 47October 2015 29

September 26, 2016 96October 2016 142-143October 2016 171October 2016 48

September 2016 2September 28, 2016 5

October 2, 2016 14September 25, 2016 18

September 18, 2016 A6September 18, 2016 A4September 18, 2016 A6September 18, 2016 B5

Amarillo Globe-News September 18, 2016 A15American Press September 18, 2016 B4Alaska Dispatch News September 18, 2016 A8 YesAnniston Star September 18, 2016 A9 YesThe Arizona Republic September 18, 2016 A21Arkansas Democrat-Gazette September 18, 2016 A13The Atlanta Journal-Constitution September 18, 2016 A21Bakersfield Californian September 18, 2016 A21The Baltimore Sun September 18, 2016 A7Baton Rouge Advocate September 18, 2016 A6Beaumont Enterprise September 18, 2016 A2Billings Gazette September 18, 2016 A5The Birmingham News September 18, 2016 A4Bismarck Tribune September 18, 2016 C4The Boston Globe September 18, 2016 A5The Buffalo News September 18, 2016 A3Casper Star-Tribune September 18, 2016 C6Champaign News-Gazette September 18, 2016 E6The Charleston Gazette*Charleston Daily Mail*Sunday Gazette-Mail September 18, 2016 A14The Post and Courier September 18, 2016 C5Cheyenne Wyoming Tribune-Eagle September 18, 2016 D4Chicago Tribune September 18, 2016 A14The Cincinnati Enquirer September 18, 2016 A10CNY Newspaper September 18, 2016 C3Corpus Christi Caller-Times September 18, 2016 B5The Denver Post September 18, 2016 A15Duluth News Tribune September 18, 2016 A9El Paso Times September 18, 2016 A2Erie Times-News September 18, 2016 D3Evansville Courier & Press September 18, 2016 A5Great Falls Tribune September 18, 2016 B4Green Bay Press-Gazette September 18, 2016 A5Gulfport Sun-Herald September 18, 2016 A10Hattiesburg American September 18, 2016 A6Honolulu Advertiser September 18, 2016 A15Houma Courier September 18, 2016 A4Houston Chronicle September 18, 2016 A23Intelligencer Journal September 18, 2016 D3Kingsport Times-News September 18, 2016 A7Knoxville News-Sentinel September 18, 2016 A15Lewiston Sun-Journal September 18, 2016 B5Lincoln Journal Star September 18, 2016 A7Los Angeles Times September 18, 2016 A20Lubbock Avalanche-Journal September 18, 2016 A8San Jose Mercury News September 18, 2016 B11Midland Reporter-Telegram September 18, 2016 A14

September 18, 2016September 18, 2016September 18, 2016

September 18, 2016September 18, 2016September 18, 2016September 18, 2016September 18, 2016

September 18, 2016

September 18, 2016

YesYes3 Col. x 9.5

3 Col. x 9.53 Col. x 9.5

3 Col. x 9.53 Col. x 9.53 Col. x 9.5

September 18, 2016

3 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.5

3 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.5

3 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.5

September 18, 2016 YesSeptember 18, 2016 Yes

September 18, 2016 YesSeptember 18, 2016 YesSeptember 18, 2016 Yes



September 18, 2016 Yes

YesYesYes


Yes

September 18, 2016

Yes


YesYes

Yes

Abilene Reporter-NewsTimes UnionAlbuquerque JournalAlexandria Town Talk


YesSeptember 18, 2016 YesSeptember 18, 2016

3 Col. x 9.5 September 18, 2016 Yes

YesSeptember 18, 2016 YesSeptember 18, 2016








Newspaper(s)

Legal Publication(s)Harris Martin's Asbestos Report Full Page (8.5" x 11") September 16, 2016 YesMealey's Asbestos Litigation Report Full Page (6.25" x 9.25") September 28, 2016 Yes

Local Community

YesVFW Full Page BW (7.25" x

9.75")September 26, 2016 Yes

People Full Page (7" x 10") September 16, 2016 YesReader's Digest Spread (9.375" x 6.75") September 20, 2016 Yes

National Geographic Full Page (5.75" x 9") September 15, 2016 YesAmerican Legion Full Page BW (7" x 10") September 13, 2016 Yes


Newspaper Supplement(s)American Profile M Page (5.75" x 9.125") October 2, 2016 YesParade M Page (6.25" x 9") September 25, 2016 Yes

Reader's Digest - Large Print Edition Full Page (7" x 10") September 20, 2016

Implementation Report

Garlock/Coltec Bankruptcy Settlement

March 27, 2017

Magazine(s)AARP Bulletin 2/3 Page (5.75" x October 1, 2016 Yes

Media

Print Media

Unit Type/Size Date Ad(s)Ran

TearsheetReceived


Page 2 of 3

Milwaukee Journal Sentinel September 18, 2016 A6Missoulian September 18, 2016 B4Monroe News-Star September 18, 2016 B2Morning Star September 18, 2016 C6The New York Daily News September 18, 2016 A20The News & Record September 18, 2016 A15The Virginian-Pilot September 18, 2016 A6The Oklahoman September 18, 2016 A4Omaha World-Herald September 18, 2016 A19The Oregonian September 18, 2016 A11Panama City News-Herald September 18, 2016 B11Parkersburg News and Sentinel September 18, 2016 A3Peoria Journal Star September 18, 2016 A14The Philadelphia Inquirer*Philadelphia Daily News September 18, 2016 A17Pittsburgh Post-Gazette September 18, 2016 A8Press-Register September 18, 2016 A7The Providence Journal September 18, 2016 A11Quad City Times September 18, 2016 B7Quincy Herald-Whig September 18, 2016 B5Rapid City Journal September 18, 2016 A8Reno Gazette Journal September 18, 2016 D2Richmond Times-Dispatch September 18, 2016 A19The Roanoke Times September 18, 2016 13Rockford Register Star September 18, 2016 A11The Sacramento Bee September 18, 2016 A2The Salt Lake Tribune*Deseret Morning News September 18, 2016 B4San Antonio Express-News September 18, 2016 A15The San Diego Union-Tribune September 18, 2016 A7San Luis Obispo Tribune September 18, 2016 A4Savannah Morning News September 18, 2016 A17The Seattle Times September 18, 2016 A9Sherman Herald Democrat September 18, 2016 A9The Times September 18, 2016 A6Southbend Tribune September 18, 2016 A12Spokane Spokesman Review September 18, 2016 A5St. Louis Post Dispatch September 18, 2016 B4Star Tribune September 18, 2016 A2Tallahassee Democrat September 18, 2016 A13The Miami Herald September 18, 2016 A29Tampa Bay Times September 18, 2016 A19Terre Haute Tribune Star September 18, 2016 C7The Clarion Ledger September 18, 2016 A13The Columbus Dispatch September 18, 2016 B5The Commercial Appeal September 18, 2016 A5The Courier-Journal September 18, 2016 A12The Daily Advertiser September 18, 2016 A12The Daily Sentinel September 18, 2016 B5The Dallas Morning News September 18, 2016 B4The Flint Journal September 18, 2016 A3The Florida Times-Union September 18, 2016 A13The Forum September 18, 2016 A7The Fresno Bee September 18, 2016 A13The Grand Rapids Press September 18, 2016 A6The Hartford Courant September 18, 2016 B12The Indianapolis Star September 18, 2016 A4The Joplin Globe September 18, 2016 A6Journal Gazette-News Sentinel September 18, 2016 C3The Kansas City Star September 18, 2016 A22The Lima News September 18, 2016 A7The Monitor September 18, 2016 A10The Oakland Press September 18, 2016 A8The Plain Dealer September 18, 2016 A8The Tennessean September 18, 2016 A10The Blade September 18, 2016 A9Traverse City Record Eagle September 18, 2016 A3Tulsa World September 18, 2016 A19Twin Falls Times-News September 18, 2016 A11Tyler Morning Telegraph September 18, 2016 A11Waco Tribune-Herald September 18, 2016 A3Wheeling News Intelligencer-Record September 18, 2016 C7The Wichita Eagle September 18, 2016 A11Wichita Falls Times Record News September 18, 2016 A6Wilmington Starnews September 18, 2016 A13Democrat and Chronicle September 18, 2016 A20Finger Lakes Times September 18, 2016 A2Wayne Post September 21, 2016 A5Times of Wayne County September 25, 2016 A2Sun and Record September 22, 2016 9The Vindicator September 18, 2016 A19San Francisco Chronicle September 18, 2016 A8Beloit Daily News September 22, 2016 A4The Kansan September 22, 2016 A5Baldwin Times September 30, 2016 4Juneau County Star Times September 21, 2016 18


3 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 10.53 Col. x 10.53 Col. x 10.5


3 Col. x 9.53 Col. x 10.53 Col. x 10.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5

3 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.53 Col. x 9.5

September 18, 2016 Yes3 Col. x 9.5

3 Col. x 10.53 Col. x 10.53 Col. x 10.5



3 Col. x 9.53 Col. x 9.5


3 Col. x 9.53 Col. x 9.53 Col. x 9.5



3 Col. x 10.53 Col. x 10.53 Col. x 10.5














Page 3 of 3

Cook County Chronicle September 21, 2016 19Courier Post September 18, 2016 A35Des Moines County News September 22, 2016 8Carroll Daily Times Herald September 22, 2016 2Times & Democrat September 18, 2016 A3Lexington Progress September 21, 2016 9BPine Bluff Commercial September 18, 2016 C5

September 22. 2016 10September 22, 2016 31September 18, 2016 8September 22, 2016 49September 19, 2016 5September 21, 2016 12September 21, 2016 13September 24, 2016 5

September 24, 2016 A2September 24, 2016 F3

US TerritoriesEl Nuevo Dia 10.87" x 6" September 22, 2016 YesEl Vocero 10.25" x 6.25" September 22, 2016 Yes


Pacific Daily News 5.87" x 10" September 18, 2016 YesPrimera Hora 10.87" x 6" September 22, 2016 YesSamoa News 6" x 10" September 19, 2016 Yes

Ad Type/Size Delivered Impressions

St. Croix Avis 6" x 10" September 21, 2016 YesVirgin Islands Daily News 6" x 9" September 21, 2016 YesVirgin Islands Daily News 6" x 9" September 24, 2016 Yes

YesThe Globe and Mail 1/4 Page (4.86" x 10") September 24, 2016 Yes

Broadcast MediaDelivered TRPs

(Target Rating Points)Date Range

TV

CompletedCompleted

MNR with Video (US National)Press Release (Canadian Bilingual General Newsline)

Viant (fka Specific Media) 728x90; 300x250; 160x600 46,449,400weather.com 300x250 3,318,053Xaxis 728x90; 300x250; 160x600 60,022,519

Ongoing - until end dateKeyword Search Campaign

Earned MediaStatus

September 18, 2016 Yes3 Col. x 10.5

Facebook.com 254x133 53,580,572

Yahoo! Network 728x90; 300x250; 160x600 24,918,137

Canadian National Network & Cable TV 259 9/12/2016 - 10/2/2016National Network & Cable TV 362 9/12/2016 - 10/9/2016

Online Media

WebAdvertising.com Network 728x90; 300x250; 160x600 53,028,697

Canada National Post 1/4 Page (5.32" x 10.71) September 24, 2016


3 Col. x 10.53 Col. x 10.53 Col. x 10.53 Col. x 10.53 Col. x 10.53 Col. x 10.5


EXHIBIT 2


Network Scheduled Affidavits Network Scheduled AffidavitsCABLE CABLECNN 13 17 BNN 69 78FBN 51 69 CTVNC 77 106FXNC 29 42 HIS 69 67HLN 33 38 SCI 15 69TWC 55 52 TSN 21 24AHC 67 89 TSN2 25 38AMC 21 21 RDS 44 52GOLF 73 75 RDI 45 44HIS 22 28 Total Cable 365 478IFC 35 35SUN 65 90 NETWORK TVTotal Cable 464 556 CBC 42 41

CBC News 71 71NETWORK TV CTV 30 30ABC 19 19 Global 12 13CBS 31 31 SRC 37 37Total Network TV 50 50 Total Network TV 192 192

Combo Totals: 514 606 Combo Totals: 557 670

US TELEVISION BUY CANADA TELEVISION BUY

US: Men 65+ TRPs purchased: 284.42;Men 65+ TRPs delivered: 362.37

Over-‐delivery is due in part to bonus units receivedaswell as the2016 political season having increasednewsratings. ABCeveningnews over-‐delivered 30%andbothCNNand FXNCalso over-‐delivered (thoughFox is due in largepart toall thebonusweight theyran).

Canada:Men 50+ TRPs purchased: 208.95; Men50+TRPs delivered: 259.07

Over-‐delivery is due to cable having run 113additional units (combo of program repeats andbonus airings) as well as the fringe and prime onbroadcast networks delivering stronger thananticipated ratings.

*TargetRatingPoints (TRPs) represent the sum ofallthe ratings for a specific audience delivered by agiven media vehicle in a schedule. A rating is thepercentage of households or persons in the targetwhohavebeenexposedto the media vehicles in theschedule. One TRP equals 1% of a given targetpopulation.

# Units # Units


EXHIBIT 3


Mapquest 300x250



Today’s Forecast Page - 300x250

3


CO

PY

RIG

HT

© Y

AH

OO

201

6

2



4 4

728x90


EXHIBIT 4


DIRECT NOTICE TO THIRD-PARTIES The Publication Notice with a cover letter were sent to the following third-parties requesting cooperation in notifying their retired members:

• The chief executive officers of trade unions whose membership has been identified as having occupational exposure asbestos-containing products will be asked to include information about the Debtors’ Motion for the Entry of an Order Approving Solicitation and Confirmation Procedures and Schedule in their union publications that reach retirees:

� American Federation of Labor-Congress of Industrial Organizations � Atlantic Independent Union � Glass, Molders, Pottery, Plastics & Allied Workers International Union � Industrial Union of Marine and Shipbuilding Workers of America � International Association of Heat and Frost Insulators and Allied Workers � International Association of Machinists and Aerospace Workers

International Association of Bridge, Structural, Ornamental and Reinforcing Iron Workers

� International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers & Helpers

� International Brotherhood of Electrical Workers � International Chemical Workers Union � International Longshore and Warehouse Workers Union � International Union of Painters and Allied Trade � International Union of Bricklayers and Allied Craftworkers � International Union of Electronic, Electrical, Salaried, Machine and Furniture

Workers � International Union of Operating Engineers � International Union, United Automobile, Aerospace and Agricultural Implement

Workers of America � Laborers’ International Union of North America � Marine Engineers Beneficial Association � Seafarers International Union of North America � Operative Plasterers' and Cement Masons' International Association � Paper, Allied-Industrial, Chemical and Energy Workers International Union � Service Employees International Union � Sheet Metal Workers International Association � Teamsters � United Association: Union of Plumbers, Fitters, Welders, and HVAC Service

Techs � UNITE HERE �


� � � United Association of Journeymen and Apprentices of the Plumbing and Pipe

Fitting Industry of the United States and Canada � United Brotherhood of Carpenters and Joiners of America � United Steelworkers � United Union of Roofers, Waterproofers & Allied Workers � Utility Workers Union of America � Workers United


Documents

UNITED STATES BANKRUPTCY COURT FOR THE WESTERN … · Nielsen Company and is used for planning, buying and evaluating media audiences across various markets.! 7 Formerly known as