1. The plaintiffs and plaintiff class are formerly enslaved African-Americans or descendants of enslaved African-Americans who were forced into slavery from which the defendants unjustly profited.

2. The plaintiffs have alleged in nine (9) separate complaints filed in seven (7) jurisdictions nationwide that among other things:a)Defendants and/or their predecessors in interest are corporations in the textile, transportation, financial, insurance, tobacco and many other industries, who were unjustly enriched through the profits they earned either directly or indirectly from the Trans-Atlantic Slave Trade and slavery. This enrichment was to the detriment of the plaintiff class. All profits have continued to compound over time to serve as a basis of tremendous current wealth1 of many defendants.

b)Defendants and/or their predecessors in interest, individually and/or collectively, profited from the knowing and willful violation of all applicable prohibitions related to the Trans-Atlantic Slave Trade.

c)Defendants and their predecessors in interest engaged in human rights violations, international norms, and crimes against humanity against plaintiffs and/or plaintiffs' ancestors that included direct or third-party liability for conspiring with slave traders, with each other and other entities and institutions, all of whom are not yet known, to ship Africans from Africa to America, even after the slave trade was declared illegal here, to enslave Africans in America, to separate families, to intentionally inflict emotion distress upon Africans and African Americans, to dehumanize Africans, and through other acts.

3. The plaintiffs demand, among other things, that defendants:a)provide a full accounting of their actions, including, but not limited to, turning over all documents in their possession related in any way to the slave trade and slavery;

b)equitably disgorge all illicit profits;

c)be subject to and comply with an independent historical commission designed to fully examine their actions;

d)be subject to the imposition of a constructive trust;

e)pay restitution in the amount equivalent to the present value of the stolen labor from the ancestors of the plaintiffs' class members that was wrongfully earned, retained and has yet to be accounted for; and

f)pay compensatory, exemplary and punitive damages and other relief.