This page provides the answers to class members' most frequently asked questions. 

The information provided is in summary form and is not intended as a complete explanation of your rights. For full and complete information, you are directed to review carefully the Notice of Proposed Settlements, Stipulation and Agreement of Settlement, and Proof of Claim form.

A:  No, you are not.

A:  This lawsuit alleges that Raytheon and the individual defendants misled investors by knowingly or recklessly overstating its financial condition, and its outside auditor, PricewaterhouseCoopers LLP knowingly or recklessly misrepresented that Raytheon's audited 1998 financial statements fairly presented its financial condition. The lawsuit also claims that Raytheon issued statements that had false and misleading information about Raytheon's income and earnings per share during the class period.

A:  In a class action, one or more people called class representatives (in this case Lead Plaintiff, the New York State Common Retirement Fund ), sue on behalf of people who have similar claims. All these people are a class or class members. Raytheon Company and PricewaterhouseCoopers, which are being sued, are the defendants. The court will resolve the common issues for everyone in the class. The lawyers representing the class are called "class counsel".

A:  The principal reason for the settlement is the substantial amounts of cash and settlement warrants to be provided to the class now, and to avoid the risks and uncertainty of continued litigation.

A:  Class counsel believes that thousands of people are members of the class.

A:  No, you do not have to pay anything.

A:  We cannot offer any advice as to what you should do. That said, you have 4 options:

First, to qualify for a payment, you must submit a valid Proof of Claim form. A Proof of Claim form is being circulated with the Settlement Notice. You may also get a Proof of Claim form here. Read the instructions carefully, fill out the form, include all the documents the form asks for, sign it, and mail it postmarked no later than December 31, 2004.

Second, you can exclude yourself from the Class with respect to the PricewaterhouseCoopers settlement. Persons and entities who are within the definition of the Class may only exclude themselves with respect to the PricewaterhouseCoopers Settlement at this time. Pursuant to the prior Notice of Pendency, class members were allowed to request exclusion until January 15, 2003. The Raytheon settlement does not provide another opportunity to request exclusion. Even if you exclude yourself with respect to the PricewaterhouseCoopers settlement, you may still file a Proof of Claim form to share in the settlement proceeds from the Raytheon Defendants Settlement.

Persons who exclude themselves will NOT receive any share of the PricewaterhouseCoopers settlement proceeds and will not be bound by the PricewaterhouseCoopers settlement. Detailed directions on how to exclude yourself from the PricewaterhouseCoopers Settlement are contained in Section 13 of the Class Notice.

Third, you may object and write to the court about why you do not agree with either or both of the settlements or any part of them. Persons who previously excluded themselves from the Class are not affected by the settlements and may not object to either settlement.

Persons who elect to exclude themselves from the class with respect to the PricewaterhouseCoopers settlement may not object to the PricewaterhouseCoopers settlement, but, unless they previously excluded themselves from the class in connection with the prior Notice of Pendency, will still be bound by, and are entitled to object to, the Raytheon settlement.

Detailed directions on how to object to the settlement - and to make an appearance at the Settlement Fairness Hearing - are contained in Sections 16 of the Class Notice.

Persons who object to either or both of the settlements must still submit a Proof of Claim form in order to receive any share of the settlements' proceeds in the event the Court approves either or both settlements. Submitting a Proof of Claim does not waive any objection that you file. Submitting an objection does not exclude you from the Class.

A:  The defendants have agreed to pay a total of $460 million to the class, including $260 million in cash ($210 million from the Raytheon defendants and $50 million from PricewaterhouseCoopers) and $200 million in Settlement Warrants. The cash and settlement warrants, net of fees and expenses, are to be divided among all class members who send in a valid Proof of Claim form. Proof of Claim forms are required to be submitted by December 31, 2004.

A Class Member's actual individual recovery will be a proportion of the Net Cash Settlement Fund and Net Settlement Warrants determined by his, her or its Recognized Claim as compared to the total Recognized Claims of all Class Members who submit acceptable Proofs of Claim. You can calculate what is called your Recognized Claim by the formula beginning at the bottom of page 10 of the Notice. It is unlikely that you will get payments equal to all of your Recognized Claim. After all Class Members have sent in their Proof of Claim forms, the payments you get will be a part of the Net Cash Settlement Funds and a part of the Net Settlement Warrants equal to your Recognized Claim divided by the total of everyone's Recognized Claim.

While each Class Member's individual recovery will depend on the Recognized Claim amount that is established in their Proof of Claim, Plaintiff's Lead Counsel have estimated that the "average" recovery per damaged share under the settlement is $3.06 (including both the cash and the value of the Settlement Warrants) before deduction of Court-awarded attorneys' fees and expenses.

A:  A settlement warrant is a freely tradable warrant that gives the holder the right to purchase from Raytheon one share of Raytheon common stock at a price of $37.50 per share for a period of five years starting on the Warrant Issue Date. These warrants will be listed on the New York Stock Exchange for trading. As a consequence, after the date of issuance, the value of the settlement warrants will be determined by the market and may decrease or increase over time.

A:  You may communicate with them by writing to Raytheon Company Securities Litigation, c/o Salvatore J. Graziano, Esq., Milberg Weiss Bershad & Schulman LLP, One Pennsylvania Plaza, New York, NY 10119-0165.

A:  You do not have to hire your own lawyer because class counsel is working on behalf of all Class Members. If you want your own lawyer to separately represent your own interests, to object to either or both of the settlements or, if you exclude yourself, to bring a separate action against PricewaterhouseCoopers, you can hire a lawyer at your own expense.

A:  The Court will hold a hearing to decide whether to approve the proposed settlements with the Raytheon Defendants and/or with PricewaterhouseCoopers. At this hearing the Court will consider whether the settlements with the Raytheon Defendants and with PricewaterhouseCoopers are fair, reasonable and adequate. If there are objections, the court will consider them. The court will listen to people who have asked to speak at the hearing. The Court may also decide how much to pay to class' counsel. After the hearing, the Court will decide whether to approve the settlement with the Raytheon defendants and/or with PricewaterhouseCoopers. We do not know how long these decisions will take.

A:  No, you do not.

A:  You can call the claims administrator toll free at 1-888-300-2319 or write to In re Raytheon Company Securities Litigation, Post Office Box 2003, Chanhassen, MN 55317-2003.

To view detailed examples of acceptable documentation that can be submitted with your Proof of Claim, please click on the following link: Documentation

For even more detailed information concerning the matters involved in this Action, reference is made to the pleadings, to the Stipulation, to the Orders entered by the court and to the other papers filed in the Action, which may be inspected at the Office of the Clerk of the United States District Court for the District of Massachusetts, John Joseph Moakley United States Courthouse, 1 Courthouse Way, Boston, Massachusetts 02210, during regular business hours.