Specifically, the class is composed of all persons or entities possessing, for some period of time after the AT&T cable was installed, an ownership interest in land underlying or adjoining the following railroad corridors in Virginia:

Washington #3 to Dillwyn (Norfolk Southern)
Washington #3 to Dillwyn (CSX)
Washington #3 to Dillwyn (Conrail
Lynchburg to Roanoke
Lynchburg to North Carolina state line
Dillwyn to Lynchburg
Lynchburg
Norfolk to Richmond
Monrovia to Parkersburg

Maps of these corridors may be accessed at http://att.fsiwebs.net/rrcorridors.

The following parties are not included in the settlement: (1) railroads or any persons or entities (and their successors-in-interest) who acquired their fee simple interest from a railroad subject to AT&T's preexisting rights in the land; (2) persons who prior to August 21, 1998, granted AT&T rights to operate and maintain a telecommunication cable system across the property; and (3) persons all of whose property adjoins or underlies railroad corridors originally derived from federal land grant.

Eligible landowners will receive direct cash payments calculated by linear foot in accordance with predetermined compensation amounts. These payments are not subject to any reduction for administrative or class notice costs, fees and expenses of class counsel, or any other costs. The settlement provides cash benefits of $2.60 per linear foot, subject to possible adjustment in certain circumstances.

The settlement creates two categories of cash benefits: current landowner benefits and prior landowner benefits.

Current Landowner Benefits

Current landowner benefits are cash benefits payable to landowners who establish that they (1) currently own property on a cable-side corridor segment and have the right, power, and authority to grant to AT&T an easement, or (2) previously owned such property, expressly reserved in a recorded deed of conveyance or other document recorded among the land records the right to receive any recovery from litigation such as this class action, and have the right, power, and authority to grant to AT&T an easement over the property. Most landowners who own property adjoining the cable side of a settlement corridor can qualify for current landowner benefits as long as the railroad did not own the particular segment of railroad corridor, but merely had an easement when the railroad conveyed rights to AT&T.

Current landowner benefits are payable on a linear foot basis, calculated by the length of AT&T telecommunication cable traversing the landowner's property. Linear footage is to be determined by algorithmic methods using map projections. Current landowner benefits are to be paid with a guaranteed minimum payment of $100 for each qualifying landowner, or landowners if the property is jointly owned.

As an example of payment, if two persons jointly own a parcel on which 500 linear feet of AT&T telecommunication cable have been installed, and if that parcel qualifies for an award of $2.60 per linear foot, then the total award for that parcel would be $1,300, to be shared equally by the two joint owners.

If a current landowner has owned the parcel qualifying for benefits for at least 10 years or throughout the ownership period described above, then the current landowner will receive 100% of the benefit amount for that parcel. If the qualifying current landowner has not owned the parcel for at least 10 years or throughout the applicable ownership period, the current landowner will receive 70% of the benefit amount to which the current landowner would otherwise be entitled. Persons desiring more detailed information about their specific properties, including a preliminary evaluation of potential benefits, may call 1-800-436-6136 or e-mail TeleCableCenter@lecg.com.

Prior Landowner Benefits

The other compensation category, prior landowner benefits, are cash benefits payable to persons who establish that, during some past portion of the ownership period described above, they owned property along one of the named railroad segments, and that the current owner of the property has not owned it for at least 10 years. As with current landowner benefits, prior landowner benefits will be paid on a linear foot basis, calculated by the length of AT&T telecommunication cable located on the qualifying parcel.

The ownership period that applies to certain railroad corridors varies slightly—all periods apparently end on the date the settlement agreement was signed, January 8, 2003: (a) Monrovia to Parkersburg from February 1988; (b) Dillwyn to Lynchburg, Lynchburg, Lynchburg to Roanoke, and Lynchburg to the South Carolina state line from September 1988; (c) Washington #3 to Dillwyn (CSX Transpotation), Washington #3 to Dillwyn (Consolidated Rail Corporation) from March 1989; (d) Washington #3 to Dillwyn (Norfolk Southern Railway) from September 1989; and (e) Norfolk to Richmond from November 1990.

Persons who qualify for prior landowner benefits will be entitled to 30% of the full benefit amount specified for the parcel minus any multi-user discount to be shared equally among all qualifying prior landowners who file a claim as to that parcel.

If a qualifying landowner's parcel adjoins or underlies a railroad corridor on which fiber optic cable has been installed by one or more companies in addition to AT&T, then the landowner's benefit amount shall be reduced by 30%. The qualifying landowner's rights of recovery against other fiber optic companies are not affected by this settlement.

In exchange for the payment, AT&T will receive a 16½ -foot-wide easement on which to maintain its communications system. AT&T will relinquish any claim to any other right in the railroad corridors except where AT&T might in the future enter into an agreement with a Corridor Enterprise.

Corridor Enterprise

Besides receiving cash compensation, participating landowners also have the option to participate on a voluntary basis in a "corridor enterprise" which attorneys for the class intend to create for the benefit of the landowners. If any landowners do not wish to participate in that enterprise, they may exclude themselves by so indicating on the claim form that is found on the class action settlement site. A decision to not participate will not affect the landowner's eligibility for any other benefits under the settlement. The corridor enterprise will be a business entity in the form of a corporation, limited partnership, or other limited liability entity recognized under applicable law, formed to aggregate corridor rights in or across right-of-way parcels owned by landowners, with the intent of enhancing the value of the right-of-way property by the creation or preservation of continuous corridors. For all landowners who participate by not excluding themselves, the court will be asked to accomplish the transfer of their remaining easement rights in the corridor (i.e., easement rights not granted to AT&T) to the corridor enterprise in exchange for equity shares in the "corridor enterprise," without the necessity of their signing any additional documents.

By controlling the corridors as units, the corridor enterprise may license, lease, sell, or use them for the benefit of participating class members. If the corridor enterprise is successful, participating landowners should expect to receive a share of any profits. Attorneys for the landowners will receive no additional fee beyond the fee approved by the Court for creation of the corridor enterprise, but may receive rights to a portion of the equity or profits earned by the corridor enterprise, in lieu of a cash fee, subject to approval by the court.

Applying for Benefits

If you wish to apply for current landowner benefits, you must mail or fax by March 1, 2004, a completed claim form and a copy of the recorded deeds that show your ownership of the land through which you are asserting your claim. The deed copy must either have been certified by the recorder's office or show on its face pertinent recording information, including the date and office of recording, deed book and page, and document number. A photocopy of the deed that you obtained and had recorded when you purchased your property should be sufficient. If there are liens on your property, and your claim is in excess of $10,000, before receiving benefits, you also will be asked to provide a letter authorizing the claims office or AT&T to obtain the lienholder's consent and approval to your release of AT&T.

If you wish to apply only for prior landowner benefits, you must mail or fax a completed claim form to the claims office by March 1, 2004, but you do not need to submit a copy of your deed. In certain circumstances the claims office might later ask for a copy of the deed to your property, but the filing of the Claim Form normally will satisfy your claim filing obligation. Current and former landowners will have a reasonable time to cure deficiencies in their submissions; those who are asked by the claims office to cure or supplement their submission will have 30 days from the date of the claims office request to do so. The claims office, if requested, will acknowledge receipt of your claim form and your documentation, and provide information as to your claim's status.

If you have questions, you may either call the settlement information line at 1-877-288-2808.

The settlement will not be effective until the court grants it final approval. The court has scheduled a hearing on the matter for January 15 or January 22, 2004, depending on whether objections are received from class members.