FAQ's

The Lawsuit alleges that Defendants violated federal antitrust laws by agreeing to restrict their recruitment, solicitation, and hiring of each other’s employees. Plaintiffs allege that Defendants compete with one another to hire aerospace engineers and other skilled workers. Plaintiffs further allege that by agreeing to restrict hiring among themselves, Defendants intended to suppress their employee’s compensation by restraining competition for aerospace engineers and other skilled workers. As a result of the agreement, Plaintiffs allege that they and other Class Members were paid less than they otherwise would have been in an unrestrained market.
A copy of the operative class action complaint, which was filed on November 2, 2023, is available on the Court Docs tab.
Defendants deny these allegations, including that the Plaintiffs or Class Members are entitled to damages or other relief. There has been no determination by the Court or a jury that the allegations against any Defendant have been proven or that, if proven, Defendants’ conduct caused harm to the Class. This Notice is not an expression of any opinion by the Court as to the claims against Settling Defendants or the defenses asserted by them. Judge Sarala V. Nagala of the United States District Court for the District of Connecticut is overseeing this class action and the Settlements. The Lawsuit is known as Borozny, et al. v. RTX Corp., Pratt & Whitney Division, et al., No. 21-cv-1657-SVN (D. Conn.).

A federal court authorized this Notice because you have a right to know that you may be part of the Class and about all of your options under the proposed Settlements. This Notice explains the Lawsuit and the Settlements; describes the Class whose rights may be affected by the Settlements; and explains your legal rights. Note that you may have received this Notice in error; simply receiving this Notice does not mean that you are a member of the Class. You may confirm that you are a member of the Class by reviewing the criteria set forth in FAQ "Am I Part of the Class?". You may also call, email, or write to the Notice Administrator at the email, telephone number, or addresses listed on the Contact Us tab.

The Settlements are the products of extensive, arm’s length negotiations between Class Counsel and counsel for Belcan, Cyient, QuEST, Agilis, PSI, and Pratt & Whitney. Settlement avoids the risk that a trial could result in no compensation for Class Members. Settlement also avoids the cost of further litigation against the Defendants, and the lengthy delay for Class Members to receive compensation that would result from continuing to a trial. After over two years of hard-fought litigation, Class Counsel and counsel for Belcan, Cyient, QuEST, Agilis, PSI, and Pratt & Whitney are well-informed about the strengths and weaknesses of their respective positions. Class Counsel believe that the terms of the Settlements are fair, adequate, and reasonable, and in the best interests of the Class.

Employees who held specific job titles at one or more of the Defendants’ companies may be Class Members and may be eligible for a payment from the Settlements when funds are distributed, if they meet the following definition:

All persons employed by Pratt & Whitney, Agilis, Belcan, Cyient, Parametric Solutions, QuEST, or their wholly-owned subsidiaries as Aerospace Workers at any time from January 1, 2011 through January 3, 2025. “Aerospace Workers” are defined as aerospace engineers and other skilled workers in the jet propulsion systems industry, including but not limited to employees of the Outsourcing Defendants (Agilis, Belcan, Cyient, Parametric Solutions, or QuEST) who engaged in any work for the following aerospace companies, and their related subsidiaries or affiliates: Aerojet Rocketdyne, Airbus Americas Inc., BE Aerospace, Bombardier Aerospace, General Electric, GE Aerospace, Hamilton Sundstrand, Honeywell, Lockheed Martin, Northrup Grumman, Parker Hannifin, Raytheon, Rolls Royce Corporation, Rockwell Collins, Sikorsky Aircraft, and UTAS.

Excluded from the Class are Defendants and their affiliates, parents, subsidiaries, and co-conspirators, whether or not named in the Complaint, senior officers and directors, and human resources personnel of Defendants, and the United States government.

To be a Class Member, you must have been employed as an Aerospace Worker for one of the Defendants at any time during the Class Period.

If you received this Notice, it is because you were listed as a potential Class Member. If you are still not sure whether you are included, you can get help by reviewing this website or by calling (800) 341-4827.

Plaintiffs have reached Settlements with all the Defendants in this case, so upon final approval of the Settlements and final judgment being entered by the Court, the lawsuit will end.

Any one of the Settlements may be terminated if, for example, the Court does not approve one or more of the Settlements. If any of the Settlements are terminated, the lawsuit will proceed against any Defendant whose settlement was terminated as if a settlement had not been reached.

If you are a Class Member, you have the right to (1) file a claim to receive a payment from the Settlement Fund, in which case you will waive any rights to pursue a lawsuit of your own against any of the Settling Defendants, (2) do nothing, in which case you will not receive a payment and will waive any rights to pursue a later lawsuit of your own against any of the Settling Defendants, (3) exclude yourself (i.e., “opt out”) from the Class and/or from one or more Settlements and retain your right to pursue a lawsuit of your own against any of the Settling Defendants from whom you have excluded yourself from that respective Class, in which case you will not receive a payment from the Settlement Fund, (4) comment on or object to one or more of the Settlements, or (5) attend the Court’s Fairness Hearing to speak in support of or against the Court’s final approval of one or more of the Settlements.

Settling Defendants will pay a total of $60,500,000 into a Settlement Fund: Belcan has agreed to pay $9,900,000; Cyient has agreed to pay $7,400,000; QuEST has agreed to pay $8,200,000; Agilis has agreed to pay $1,000,000; and Pratt & Whitney has agreed to pay $34,000,000. The Settlement with PSI, which is in bankruptcy, provided cooperation while Plaintiffs continued litigation against other Defendants. After deducting attorneys’ fees, costs, applicable taxes, and other fees and expenses, the Settlement Fund will be distributed to Class Members.
In exchange for the above consideration, and upon Final Approval of the Settlements by the Court, entry of judgment, and the completion of any appeals, the Class’s claims against the Settling Defendants will be dismissed with prejudice, and Settling Defendants will be released by Class Members from all claims arising in any way from or in any way related to the facts, activities, or circumstances alleged in the operative complaint. The full text of the releases are included in the respective Settling Defendants’ Settlement Agreements: Belcan Settlement Agreement at paragraph 52; Cyient Settlement Agreement at paragraph 53; QuEST Settlement Agreement at paragraph 52; Agilis Settlement Agreement at paragraph 52; PSI Settlement Agreement; and Pratt & Whitney Settlement Agreement at paragraph 52, which are available on the Court Docs Page.

If you decide that you do not want to be part of the Class in one or more of the Settlements, you may exclude yourself from the Class (i.e., “opt out” of the Class) on or before May 3, 2025. To exclude yourself from a Settlement, you must send an email or mail a letter stating that you want to exclude yourself from one or more of the Settlements to the Notice Administrator at info@AerospaceAntitrustLitigation.com, or:

Aerospace Worker Settlements
c/o A.B. Data, Ltd.
P.O. Box 173132
Milwaukee, WI 53217

Your email or letter must include:

• Your full legal name, current mailing address, email address, and telephone number;
• The name(s) of the Defendant company or companies for which you worked during the Class period;
• Approximate dates of your employment with Defendant(s); and
• A statement that you want to be excluded from one or more of the Settlement(s), and the identity of the Settlement(s) from which you want to be excluded.

Your email requesting exclusion must be sent by—or your letter requesting exclusion must be postmarked by—no later than May 3, 2025. This will be the only opportunity you will have to exclude yourself from one or more of the Settlements.

If you exclude yourself from the Class in one or more of the Settlements, you will not get a share of the Settlement Fund from that Settlement(s), and you will not be able to object to that Settlement(s). You will not be legally bound by the terms of a Settlement from which you exclude yourself, and you may be able to sue (or continue to sue) the respective Settling Defendant in the future about the legal issues in this case. If you exclude yourself from the Class in one or more of the Settlements so that you can start, or continue, your own lawsuit against a Defendant, you should talk to your own lawyer as soon as possible, because your claims will be subject to a statute of limitations, which means that your claims will expire if you do not take timely action. You need to contact your own lawyer about this issue.

If you do not exclude yourself from a Class in one or more of the Settlements, you will not be able to start a lawsuit or other proceeding, continue a lawsuit or other proceeding, or be part of any other lawsuit or other proceeding against that Settling Defendant arising from the claims released as part of the Settlement, including claims brought in the case.

No. If you remain in the Class for a Settlement, and that Settlement is approved by the Court, you give up your right to sue that Settling Defendant for the same conduct at issue in this case. That is called “releasing” your claims and potential claims. The full text of the releases in the Settlements Agreements can be found on the Court Docs page.

If you have your own pending lawsuit(s) against one or more of the Settling Defendants, speak to your lawyer in that case immediately, because you may need to exclude yourself from one or more of the Settlements to continue your own lawsuit(s). Remember, the deadline to exclude yourself from the Settlements is May 3, 2025.

If you are a Class Member and have not opted out of the Class in one or more of the Settlements, you can comment on or object to any of the Settlements that you have not opted out of if you like or don’t like any part of it and ask the Court to deny approval of the respective Settlement(s). You can give reasons why you think the Court should or should not approve the Settlement. You cannot ask the Court to order a different settlement; the Court can only approve or deny the Settlement. If the Court denies approval of one or more of the Settlements, no payments will be sent out with respect to any Settlement that is not approved by the Court and the lawsuit will continue against that Settling Defendant(s).

All comments and objections must be in writing and must include the following: (a) your name, address, telephone number, email address and signature; (b) the case name and number

(Borozny, et al. v. RTX Corp., Pratt & Whitney Division, et al., No. 21-cv-1657-SVN (D. Conn.)); (c) the particular Settlement(s) to which you are objecting; (d) a summary of any other objections you or an attorney on your behalf filed to any class action settlements submitted to any court in the United States in the previous five years; and (e) a detailed statement of your comments or objections, including the grounds for your objections, if any, together with any supporting documents. All comments and objections must be signed by the objecting member of the Settlement Class (and his or her attorney, if individually represented, including any former or current counsel who may be entitled to compensation for any reason related to the objection).

All comments and objections and supporting papers must be submitted to the Court either by filing them electronically via the Court’s Case Management/Electronic Case Filing (CM/ECF) system or by mailing it to the Clerk of the United States District Court for the District of Connecticut, Abraham Ribicoff Federal Building, 450 Main Street, Hartford, CT 06103.

All comments and objections and supporting papers must also be mailed to Class Counsel and Defense Counsel below:

If you would like to appear and ask to be heard, you may but are not required to unless otherwise ordered to appear by the Court. You may appear at the Fairness 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. If you would like to speak at the Fairness Hearing about your comments or objections to one or more of the Settlements, please state your intention to appear in your objection or submit a letter with a statement that you intend to appear and speak at the hearing, for example, by stating “This is my Notice of Intention to Appear at the Fairness Hearing for Borozny, et al. v. RTX Corp., Pratt & Whitney Division, et al.”

If you choose to exclude yourself (“opt out”) from one or more of the Settlements, you will have no right to speak at the hearing about that Settlement(s) or object to it, because that Settlement(s) will no longer affect your rights.

All objections and/or Notice of Intention to Appear must be postmarked no later than May 3, 2025.

The Court will hold a Fairness Hearing on May 7, 2025, at 10:00 am in Courtroom One of United States District Courthouse for the District of Connecticut, Abraham Ribicoff Federal Building, 450 Main Street, Hartford, CT 061037. At this hearing, the Court will consider whether the Settlements are fair, reasonable, and adequate. If there are objections, the Court will consider them. After the hearing, the Court will decide whether to approve the Settlements. We do not know how long the decision will take. The date and time of the hearing is subject to change.

No, not unless the Court orders you to appear in person. Class Counsel will answer questions that the Court may have. But you are welcome to come at your own expense. If you send an objection, you do not have to come to Court to talk about it unless the Court orders you to do so; as long as you mail your written objection on time, the Court will consider it. You may also pay your own lawyer to attend, but it is not necessary. Attendance is not necessary to obtain a payment from the Settlement Fund.

You may ask the Court for permission to speak at the Fairness Hearing, either in person or through your own attorney, if you file a request to speak in person. If you appear through your own attorney, you are responsible for paying that attorney.

If you are a Class Member and you do nothing, you will not get any payment from the Settlements and any claims you might have against the Settling Defendants based on the allegations in this case will be released.

The law firms listed below have been appointed by the Court as Interim Co-Lead Counsel for the Class (“Class Counsel”). Class Counsel are experienced in handling similar cases against other companies. Class Counsel for the Class are:

DICELLO LEVITT LLP
485 Lexington Avenue, Suite 1001
New York, New York 10017

QUINN EMANUEL URQUHART & SULLIVAN, LLP
51 Madison Avenue, 22nd Floor
New York, New York 10010

You will not be personally charged for the services of these lawyers in litigating this case against the Defendants.

You do not need to hire your own lawyer because the lawyers appointed by the Court are working on your behalf. You may hire a lawyer and enter an appearance through your lawyer at your own expense if you desire.

Settlement Class members are not personally responsible for payment of attorneys’ fees or expenses. Any attorneys’ fees and expenses will be awarded only as approved by the Court in amounts determined to be fair and reasonable. Class Counsel may ask the Court to approve payment from the Settlement Fund for attorneys’ fees in the amount of no more than 33-1/3% of the Settlement Fund; an award of unreimbursed litigation costs and expenses incurred by Class Counsel in connection with the litigation; and for interest on such attorneys’ fees and litigation costs and expenses at the same rate as the earnings in the Settlement Fund, accruing from the inception of the Settlement Fund until the attorneys’ fees and litigation expenses are paid. Class Counsel may also ask the Court to approve payments from the Settlement Fund to each of the nine individual Named Plaintiffs as service awards in recognition of their efforts on behalf of the Class.