On October 8, 2002, Crompton announced that is was cooperating with authorities in the United States and European Union concerning an investigation into allegations of collusive business dealings in the rubber chemicals industry. That day, the Company’s stock price dropped 35.5%, from a closing price of $9.15 on October 8, 2002 to $5.90 on October 9, 2002.

On or after July 28, 2003, three actions were filed in the District of Connecticut against Crompton and certain of the Company’s officers and directors. These three actions were consolidated by Order dated October 3, 2003. Thereafter, on March 18, 2004, the Court approved Pierre Brull and William Ashe as Lead Plaintiffs, and appointed their choice of counsel, Murray, Frank & Sailer LLP and Schiffrin Barroway Topaz & Kessler, LLP (now known as Barroway Topaz Kessler Meltzer & Check, LLP) as co-lead counsel (“Co-Lead Counsel”) for the Class.

Lead Plaintiffs filed their Consolidated Amended Class Action Complaint for Violations of Federal Securities Laws (the “Complaint”) on July 20, 2004. The Complaint alleged, among other things, that throughout the Class Period, Crompton participated in collusive business conspiracies designed to artificially fix price and demand for most of its product line. The Complaint further alleged that, as a result, Defendants’ Class Period statements concerning financial results, competition, pricing, sales, and margins were materially false and misleading as these statements were largely the result of undisclosed anticompetitive business practices.

On September 17, 2004, Defendants Crompton, Calarco and Barna filed a motion to dismiss the Complaint. On November 19, 2004, Lead Plaintiffs filed an opposition to that motion to dismiss, and on January 4, 2005, those Defendants filed a reply memorandum in support of the motion to dismiss. In addition, Defendants Cook, Hohn, Wesson, Brinberg and Pappas filed a motion to dismiss the Complaint on February 14, 2005. Lead Plaintiffs filed an opposition to that motion to dismiss on April 11, 2005, and those Defendants filed a reply in support of their motion to dismiss on May 11, 2005.

While Defendants’ motions to dismiss were pending, the Parties engaged in settlement negotiations, participating in a formal mediation before a retired state superior court judge. Following the mediation and continued telephonic negotiations, the Parties reached a tentative agreement to settle the Lawsuit, and executed a Memorandum of Understanding outlining the general terms of their proposed settlement on April 30, 2008. Thereafter, Lead Plaintiffs engaged in discovery in order to confirm the fairness of the Settlement.

On November 28, 2008, the Parties executed a stipulation of settlement. On December 12, 2008, the Court issued an Order preliminarily approving that settlement, and scheduled a fairness hearing for June 12, 2009 (which was subsequently postponed and cancelled due to Chemtura’s bankruptcy).

On March 18, 2009, Crompton’s successor, Chemtura Corporation (“Chemtura”), filed for Chapter 11 bankruptcy protection. Pursuant to 11 U.S.C. § 362(a), Chemtura’s bankruptcy resulted in an automatic stay of this Lawsuit. On October 30, 2009, as required by 11 U.S.C. §§ 547 and 550, Co-Lead Counsel returned to Chemtura the $9,292,500 that Crompton contributed to fund the original settlement.

After significant consideration and further mediation and negotiations, the Parties have agreed to modify the settlement in order to lift the bankruptcy stay in this Lawsuit and avoid further delay in administering any settlement. Accordingly, the Lawsuit will be settled for the $11,357,500 that Defendants paid or caused to be paid from the Company’s Directors & Officers Insurance (the “Settlement”).

The Class includes: all those who purchased or otherwise acquired the securities of Crompton during the period between October 26, 1998, and October 8, 2002, inclusive, including without limitation all persons and entities that purchased or otherwise acquired Crompton Securities pursuant to the merger between Crompton & Knowles Corporation and Witco Corporation, except those persons and entities that are excluded, as described below.

Excluded from the Class are: Defendants, members of the immediate family of any Defendant, any parent, subsidiary, affiliate, partner, or successor-in-interest of Crompton, and the directors and officers of Crompton or its subsidiaries, affiliates, or successor-in-interest, or any entity in which any excluded person has a controlling interest, and the legal representatives, heirs, successors and assigns of any excluded person. Also excluded from the Class are any putative Class members who exclude themselves by filing a request for exclusion in accordance with the requirements set forth in question 13 of the Notice.

If you sold Crompton Securities during the period between October 26, 1998, and October 8, 2002, inclusive, that alone does not make you a Class member. You are a Class member only if you purchased or otherwise acquired Crompton Securities during the Class Period.

If one of your mutual funds purchased or owns Crompton Securities, that alone does not make you a Class member.

If you are not sure whether you are included in the Class, you can ask for help, which will be provided to you at no cost. You can call the Claims Administrator at 1-866-840-0341, or write to the following address:

     In re Crompton Corp. Securities Litigation
     Claims Administrator
     P.O. Box 4655
     Portland, OR 97208-4655

Or you can fill out and return the Proof of Claim form to see whether you qualify. If you already submitted a valid Proof of Claim in connection with the original settlement, you do not need to submit another claim form.

Defendants have created a $11,357,500 cash Settlement Fund. The balance of this fund, after payment of court-approved attorneys’ fees and expenses and the costs of claims administration, including the costs of printing and mailing this Notice and the cost of publishing notice (the “Net Settlement Fund”), will be divided among all Class members who submit timely and valid claim forms.

A Class Member’s actual recovery will be a proportion of the Net Settlement Fund determined by comparing his, her or its Recognized Loss to the total Recognized Loss of all Class Members who submit acceptable Proofs of Claim. An individual Class Member’s actual recovery will depend on, for example: (1) the total number of claims submitted; (2) when the Class Member purchased and/or acquired Crompton securities during the Class Period; (3) the purchase price paid; (4) the type of security purchased or acquired; (5) whether those Crompton securities were held at the end of the Class Period or sold during the Class Period (and, if sold, when they were sold and the amount received); (6) administrative costs, including the costs of notice, for the Action; and (7) the amount awarded by the Court for attorneys’ fees, costs and expenses. Distributions to Class Members will be made based on the Plan of Allocation set forth in the Notice.

To qualify for a payment from the Net Settlement Fund, you must send in a Proof of Claim form. Please Note: If you previously submitted a Proof of Claim in connection with the original settlement of this Lawsuit and wish to participate in this Settlement, you do not need to do anything else. Your previously submitted Proof of Claim will be included in connection with the modified settlement.

You may obtain a Proof of Claim form on the Documents page of this website or by calling the Claims Administrator at 1-866-840-0341. Please read the instructions carefully, fill out the form, include all the documents the form asks for, sign the form, and mail it postmarked no later than September 24, 2010 to the following address:

    In re Crompton Corp. Securities Litigation
    Claims Administrator
    P.O. Box 4655
    Portland, OR 97208-4655

If you are an individual, you can submit a claim form online by following the instructions on the Online Claim Form Filing page of this website. If you are a nominee and would like to file claim(s) on behalf of your clients, you may submit the information by following the instructions on the Nominees page of this website. All online claim forms must be submitted no later than September 24, 2010.

Please note that all Proof of Claim forms must be signed and returned to the Claims Administrator with a postmark date of September 24, 2010 in order to be eligible to receive any payment from the Net Settlement Fund. Improperly completed claim forms require more processing time by the Claims Administrator and could potentially reduce the amount of money in the Net Settlement Fund.

The Court will hold a hearing on August 17, 2010 to decide whether to approve the Settlement. If the Court approves the Settlement, there may be appeals. It is always uncertain whether appeals, if any, can be resolved, and resolving them can take time, perhaps several years. In addition, the Claims Administrator must process all of the Proofs of Claim. The processing is complicated and will take many months. Please be patient.

To exclude yourself from the Settlement, you must send a letter by mail stating that you want to be excluded from the Settlement in the In re Crompton Corp. Securities Litigation, No. 3:03-CV-1293 (EBB). You must include your name, address, telephone number, your signature, and information concerning your purchase(s), acquisition(s) and sale(s) of Crompton Securities during the Class Period, including the type and amount of Crompton Securities (e.g., the number of shares of Crompton common stock) and the dates of each purchase, acquisition and sale of Crompton Securities. You must mail your exclusion request so that it is received no later than July 28, 2010 to:

    In re Crompton Corp. Securities Litigation
    Claims Administrator
    P.O. Box 4655
    Portland, OR 97208-4655

Please keep a copy of everything you send by mail, in case it is lost or destroyed during shipping.

You cannot exclude yourself over the phone or by e-mail. If you ask to be excluded from the Settlement, you are not eligible to receive any payment from the Net Settlement Fund, and you cannot object to the Settlement. You will not be legally bound by anything that happens in this lawsuit and you will be able to pursue the claims that are being released in this Settlement.

No. If you exclude yourself, do not send in a Proof of Claim form. But, you may exercise any right you may have to sue, continue to sue, or be part of a different lawsuit asserting the claims being released in this Settlement against the Defendants or the Released Parties.

No. Unless you exclude yourself, you give up any right to sue the Defendants or the Released Parties for the claims being released by this Settlement. If you have a pending lawsuit relating to the claims being released in this Action against any of the Defendants, speak to your lawyer in that case immediately. Remember, the exclusion deadline is July 28, 2010.

If you are a Class member, you can object to the Settlement if you do not like any part of it. If you submitted a Proof of Claim in connection with the original settlement, but now wish to object to this Settlement, you may still do so. To object, you must send a letter saying that you object to the Settlement in the In re Crompton Corp. Securities Litigation, No. 3:03-CV-1293 (EBB) and the reasons why you object to the Settlement. Be sure to include your name, address, telephone number and your signature. You must also include information concerning your purchase(s), acquisition(s) and sale(s) of Crompton Securities during the Class Period, including the type and amount of Crompton Securities (e.g., the number of shares of Crompton common stock) and the dates of each purchase, acquisition and sale of Crompton Securities. Any objection to the Settlement must be received by each of the following by July 28, 2010:

Court

    Clerk of the Court
    United States District Court
    District of Connecticut
    Richard C. Lee United States Courthouse
    141 Church Street
    New Haven, CT 06510

Co-Lead Counsel

    Michael K. Yarnoff, Esq.
    Karen E. Reilly, Esq.
    Jennifer L. Enck, Esq.
    BARROWAY TOPAZ KESSLER MELTZER & CHECK, LLP
    280 King of Prussia Road
    Radnor, PA 19087

    Brian P. Murray, Esq.
    Gregory B. Linkh, Esq.
    MURRAY, FRANK & SAILER LLP
    275 Madison Avenue, Suite 801
    New York, NY 10016

Defendants' Counsel

    Andrew J. Frackman, Esq.
    William J. Sushon, Esq.
    O'MELVENY & MYERS LLP
    7 Times Square
    New York, NY 10036

    Bradford S. Babbitt, Esq.
    Jeffrey J. White, Esq.
    ROBINSON & COLE LLP
    280 Trumbull Street
    Hartford, CT 06103

    Thomas D. Goldberg, Esq.
    Terence J. Gallagher, Esq.
    DAY PITNEY LLP
    One Canterbury Green
    Stamford, CT 06901-2047

Objecting is simply telling the Court that you do not like something about the Settlement, the Plan of Allocation, or the application for attorneys’ fees and expenses. You can object only if you stay in the Class. Excluding yourself is telling the Court that you do not want to be part of the Settlement. If you exclude yourself, you have no basis to object because the case no longer affects you.

The Court will hold a fairness hearing at 10:00 a.m. on August 17, 2010, at the United States District Court for the District of Connecticut, Richard C. Lee United States Courthouse, 141 Church Street, New Haven, CT 06510, Courtroom Three. At this hearing, the Court will consider whether the Settlement and the Plan of Allocation are fair, reasonable, and adequate. If there are objections, the Court will consider them. The Court will listen to people who have requested in writing by July 28, 2010 to speak at the hearing. The Court may also consider Co-Lead Counsel’s application for attorneys’ fees and reimbursement of expenses.

You do not need to attend the Fairness Hearing, but, you are welcome to come at your own expense. Co-Lead Counsel will answer any questions the Court may have at the Fairness Hearing.

You should be aware that the Court can and may change the date and time of the Fairness Hearing without notice to the Class. If you plan to attend the hearing, you should periodically check this website or check with Co-Lead Counsel to be sure that no change to the date and time of the hearing has been made.