Welcome to the Boland v. Gerdau S.A. Securities Litigation Website

This website has been established to provide general information regarding the proposed settlement (the "Settlement") of the action entitled Boland v. Gerdau S.A., et al., Civil Action No. 1:16-cv-03925-LLS (the "Litigation").  This Litigation is pending before the United States District Court for the Southern District of New York (the "Court"). The capitalized terms used on this website and not defined herein shall have the same meanings ascribed to them in the Stipulation of Settlement (the "Stipulation") dated July 5, 2017, which can be found and downloaded by clicking on the Case Documents tab above. Your rights may be affected by the Settlement if you purchased or otherwise acquired American Depositary Receipts ("ADRs") of Gerdau S.A. ("Gerdau" or the "Company") between April 23, 2012 and May 16, 2016, inclusive.

As more fully described in the Notice of Proposed Settlement of Class Action (the "Notice"), the initial complaint in this action was filed on May 26, 2016. On August 9, 2016, the Court appointed Lead Plaintiff and Lead Counsel. On October 31, 2016, Lead Plaintiff filed its Consolidated Complaint for Violations of the Federal Securities Laws (the “Complaint”).

Lead Plaintiff alleges that Defendants violated Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 by, inter alia, issuing false and misleading statements and/or failing to disclose that: (i) the Company was engaged in a bribery scheme in collusion with Brazil’s Board of Tax Appeals; (ii) Gerdau had defrauded Brazilian tax authorities of approximately 4 billion Brazilian reais in taxes; and (iii) directors and employees of the Company had engaged in bribery, money laundering and influence peddling. Lead Plaintiff alleges that as a result of these material misrepresentations and omissions, Gerdau ADRs traded at artificially inflated prices. Defendants deny Lead Plaintiff’s allegations.

On January 17, 2017, Defendants (other than three individuals who had not been served) filed Motions to Dismiss the Complaint. At the Settling Parties’ request, on February 16, 2017, the Court stayed the Litigation in order for the parties to attempt a mediation.

In an effort to settle the Litigation, the parties engaged the services of the Hon. Layn R. Phillips (Ret.), a nationally recognized mediator. The parties prepared detailed mediation statements and engaged in a full-day in-person mediation session with Judge Phillips on April 25, 2017. These efforts culminated with the parties agreeing to settle the Litigation on May 15, 2017, for $15,000,000, subject to the negotiation of the terms of the Stipulation and approval by the Court.

The Settlement, if approved, will result in the creation of a cash settlement fund of $15,000,000 (the “Settlement Fund”). The Settlement Fund, less all taxes, approved costs, fees and expenses ("the Net Settlement Fund") shall be distributed to Class Members who submit timely Proofs of Claim to the Claims Administrator and which are valid pursuant to the Plan of Allocation detailed on pages 9-12 of the Notice.

The law firm of Robbins Geller Rudman & Dowd LLP represents the Class Members, including you. These lawyers are called Lead Counsel, and will apply to the Court for payment of attorneys’ fees and expenses from the Settlement Fund; you will not be otherwise charged for their work. If you want to be represented by your own lawyer, you may hire one at your own expense.

Although the information in this website is intended to assist you, it does not replace the information contained in the Notice and Stipulation, both of which can be found and downloaded by clicking on the Case Documents tab above. We recommend that you read the Notice and other relevant case documents carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

DEADLINES