class-action-settlement

name	class-action-settlement
title	Class Action Settlement Agreement
description	Drafts class action settlement agreements for court approval under FRCP 23(e), covering settlement fund terms, class definitions, release provisions, allocation plans, claims administration, notice programs, opt-out procedures, and fee structures. Use when drafting class action settlements, settlement agreements requiring judicial approval, or FRCP 23(e) fairness submissions.
author	CaseMark
author_url	https://github.com/CaseMark/skills/tree/main/skills/legal/class-action-settlement
license	Apache-2.0
version	0.1.0
execution_mode	open
jurisdiction	us
practice	litigation
language	en
tags	["agreement","drafting"]

Class Action Settlement Agreement

Drafts a court-approvable class action settlement balancing class member interests, defendant finality, and FRCP 23(e) fairness standards.

Prerequisites

1. Case materials — complaint, class certification order, case number, jurisdictional details
2. Term sheet or negotiation record — agreed monetary amounts, allocation methodology, key terms
3. Class definition — certified or proposed class and any subclasses
4. Damages analysis — theories, calculations, aggregate and per-member ranges
5. Party information — all named parties, class representatives, counsel of record

Output Structure

Draft a formal settlement agreement with the following articles in order.

Article I — Recitals

Element	Content
Litigation background	Case caption, court, claims asserted, procedural history
Certification status	Class cert order date and scope, or proposed settlement class
Settlement purpose	Compromise to avoid risk/expense; no admission of liability
Negotiation history	Arms-length negotiation, mediator involvement if any

Article II — Definitions

Define all capitalized terms at the outset. At minimum:

• Settlement Fund, Net Settlement Fund, Settlement Class, Class Period
• Released Claims, Released Parties, Effective Date
• Claims Administrator, Class Counsel, Class Representatives
• Claim Form, Opt-Out Deadline, Objection Deadline

Article III — Settlement Fund & Payment

• Total amount — non-reversionary common fund
• Payment schedule — deadlines, escrow/QSF account details
• Fee treatment — fund inclusive or exclusive of fees/costs
• Tax provisions — QSF treatment under IRC § 468B; each party bears own tax liability
• Investment — permitted investment pending distribution

Article IV — Class Definition & Release

• Class definition — mirror or refine certification order language
• Release scope — all asserted and unasserted claims arising from same facts/transactions