The following is a summary of information presented in more detail in the Notice of Proposed Settlement of Class Action (the "Notice"). This website incorporates by reference the definitions in the Stipulation of Settlement dated January 13, 2011 ("Stipulation"), and all capitalized terms used, but not defined herein, shall have the same meanings as in the Stipulation. Since this is just a summary, you should read the full Notice for additional details. The Notice and Stipulation are available for download on the left hand side of this page.

IF YOU PURCHASED NAVISTAR INTERNATIONAL CORPORATION ("NAVISTAR" OR THE "COMPANY") COMMON STOCK ON THE OPEN MARKET BETWEEN FEBRUARY 14, 2003 AND JULY 17, 2006, INCLUSIVE, (THE "CLASS PERIOD"), AND ARE NOT OTHERWISE EXCLUDED FROM THE CLASS, YOU COULD GET A PAYMENT FROM A CLASS ACTION SETTLEMENT (THE "SETTLEMENT").

Securities Brokers and other Nominees: Please see instructions on Page 11 of the Notice.

WHAT IS THIS CASE ABOUT?
The litigation alleges that Navistar, Mark T. Schwetschenau, Robert C. Lannert and Daniel C. Ustian ("Defendants") violated the federal securities laws by making statements during the Class Period that were false and/or misleading and that as the truth of the misstatements became public, Class Members suffered damages as a result of the decline in the price of Navistar common stock.

Defendants vigorously deny that the restatement of Company financials was the result of fraud by the Defendants or that Defendants engaged in any wrongdoing whatsoever. Defendants also vigorously deny that Plaintiffs or the Class suffered damages as a result of Defendants' alleged conduct or that the price of Navistar common stock was artificially inflated by reasons of alleged misrepresentations, non-disclosures or otherwise.

Nonetheless, Defendants have concluded that further litigation would be protracted and expensive, and that it is desirable that the matter be fully and finally settled upon the terms and conditions set forth in the Stipulation. 

THE SETTLEMENT BENEFITS
Defendants have agreed to pay or cause to be paid $13,000,000 in cash (the "Settlement Fund"). The Settlement Fund, plus interest earned from the date it is established, less costs, fees, and expenses, will be divided among all eligible Class Members who send in valid Proof of Claim forms.

THE COURT'S SETTLEMENT FAIRNESS HEARING
The Court will hold a hearing on May 25, 2011, at 10:00 a.m., at the United States District Court for the Northern District of Illinois, 219 South Dearborn Street, Courtroom 1703, Chicago, IL 60604. At this hearing, the Court will consider whether the proposed Settlement is fair, reasonable, and adequate. The Court will also decide at this hearing whether to approve the payment of fees and expenses to Lead Counsel. If there are any objections, the Court will consider them at this hearing.

IF YOU ARE A CLASS MEMBER, YOU HAVE THE FOLLOWING OPTIONS:

SUBMIT A PROOF OF CLAIM
To qualify to get money from the proposed Settlement, you must timely send in a completed Proof of Claim form (available for download on the left hand side of this page) with supporting documents (DO NOT SEND ORIGINALS) to the Claims Administrator. Please read the Proof of Claim instructions carefully, fill the form out and include all required documentation, sign it, and mail it to the Claims Administrator by first class mail, postmarked no later than June 14, 2011. The Claims Administrator needs all of the information requested in the Proof of Claim in order to determine what you may be entitled to.

EXCLUDE YOURSELF FROM THE CLASS
All members of the Class have the option to exclude themselves from the Settlement by mailing a valid, timely request for exclusion postmarked no later than April 25, 2011, to:

Navistar Securities Litigation
ATTN: EXCLUSIONS
c/o Rust Consulting, Inc.
P.O. Box 2456
Faribault, MN 55021-9156

If you ask to be excluded, you are not eligible to get any Settlement payment, you cannot object to the Settlement, and you will not be legally bound by anything that happens in the litigation. To exclude yourself from the Class, you must send a written letter that includes:

• A statement indicating you want to be excluded from Norfolk County Retirement System, et al. vs. Daniel C. Ustian, et al., No. 1:07-cv-07014;
   
• Your name, address, and telephone number;
   
• The number of shares of Navistar common stock you purchased on the open market between February 14, 2003 and July 17, 2006, inclusive, and the dates and prices of such purchases; and
   
• Your signature.

OBJECT TO THE SETTLEMENT
If you are a Class Member, you may object to the Settlement or any of its terms, any part of the Plan of Allocation, or the application for attorneys’ fees, costs and expenses. You may give reasons why you think the Court should not approve any or all of the Settlement terms. The Court will consider your views.

To object, you must include:

• A statement indicating you object to the proposed Settlement in Norfolk County Retirement System, et al. vs. Daniel C. Ustian, et al., No. 1:07-cv-07014;
   
• Your name, address, telephone number, and signature;
   
• The purchases and sales of Navistar common stock you made during the Class Period, including the dates of purchase or sale, the number of shares purchased and/or sold, and the price paid or received per share for each such purchase or sale; and
   
• A statement of the reasons for objecting to the Settlement, the requested attorneys’ fees and expenses, or the Plan of Allocation.

The objection must be mailed or delivered on or before April 25, 2011 to the CLERK OF THE COURT and Lead Counsel and Defendants’ Counsel at the addresses listed on Page 9, Question 19 of the Notice.

ADDITIONAL INFORMATION
Additional information regarding the Settlement, the Notice and how to file your claim may be obtained by contacting the Claims Administrator at 877-497-5924.