FTSI Securities Settlement
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Welcome to the FTSI Securities Settlement Website

This website has been established to provide general information related to the proposed settlement of the case known as Carol Glock v. FTS International, Inc., et al., Case No. 4:20-cv-03928 (the "Litigation"), pending before the United States District Court for the Southern District of Texas, Houston Division (the "Court"). The capitalized terms used on this website, and not otherwise defined, shall have the same meanings ascribed to them in the Stipulation of Settlement (the "Stipulation") dated November 19, 2020, 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 FTS International, Inc. ("FTSI" or the "Company") publicly traded common stock in or traceable to FTSI's February 2, 2018 initial public offering ("IPO"), including all persons who purchased or acquired FTSI common stock during the period between February 2, 2018 and February 21, 2019, inclusive (the “Settlement Class Period”).

The law firms of Robbins Geller Rudman & Dowd LLP and Johnson Fistel, LLP represent you and other Settlement Class Members. You will not be charged for these lawyers. They will be paid from the Settlement Fund to the extent the Court approves their application for fees and expenses. If you want to be represented by your own lawyer, you may hire one at your own expense.


As more fully described in the Notice of Pendency and Proposed Settlement of Class Action (the "Notice"), the initial complaint in this action was filed in February 2019 in the 160th Judicial District Court of the State of Texas (“State Court”). On July 15, 2019, the State Court appointed Kendall Law Group, PLLC as liaison counsel and Robbins Geller Rudman & Dowd LLP (“Robbins Geller”) and Johnson Fistel, LLP as interim lead counsel. On September 16, 2020, the Litigation was transferred to the United States Bankruptcy Court for the Southern District of Texas (“Bankruptcy Court”).

Lead Plaintiff’s Amended Petition for Violation of the Securities Act of 1933 and Demand for Jury Trial (the “Amended Petition”) alleges that Defendants violated §§11 and 15 of the Securities Act of 1933 by making materially false statements and omissions in the Registration Statement for FTSI’s February 2, 2018 IPO. Specifically, Lead Plaintiff alleges that the Registration Statement was false and misleading as (among other things) it misrepresented that FTSI was experiencing a surge in demand for its services that no longer existed at the time of the IPO, in part because months before the IPO, FTSI’s controlling shareholder began to drastically scale back related party transactions with FTSI that had inflated the financial results highlighted in the IPO Registration Statement. Additionally, Lead Plaintiff alleges that FTSI’s purportedly steady stream of income promised in the Registration Statement evaporated as customers could and did simply cancel their purportedly “dedicated” contracts. The Amended Petition further alleges that these known adverse trends, which were in existence prior to the IPO, caused FTSI’s business to collapse.

On September 22, 2020, FTSI, FTS Manufacturing, LLC, and FTS International Services, LLC (collectively, the “Debtors”) commenced Chapter 11 cases (the “Chapter 11 Cases”) in the Bankruptcy Court and filed the Plan and a proposed disclosure statement (the “Disclosure Statement”) (Docket No. 17) for the Plan.

On September 24, 2020, the Bankruptcy Court entered an order (the “Solicitation Procedures Order”)(Docket No. 109) conditionally approving the Disclosure Statement for the Plan, and approving certain related solicitation procedures, notices, ballots, and scheduling matters (the “Solicitation Procedures”).

On March 30, 2020, the parties engaged the services of David Murphy of Phillips ADR, an experienced mediator, to facilitate settlement negotiations. On April 29, 2020, the parties engaged in a video conference mediation session with Mr. Murphy. Before the mediation, the parties submitted and exchanged statements with detailed descriptions of their claims and defenses and supporting evidence. The case did not settle, but the parties continued settlement discussions with the assistance of Mr. Murphy. On October 16, 2020, the parties accepted a mediator’s proposal from Mr. Murphy to resolve the Litigation for a cash payment of $9,875,000 to be paid by or on behalf of Settling Defendants, for the benefit of the Settlement Class, subject to the negotiation of the terms of a Stipulation of Settlement and approval by the Court. On October 23, 2020, the Settling Parties entered into a Memorandum of Understanding. On November 18, 2020, the Bankruptcy Court transferred the Litigation to this Court. The Stipulation (together with the Exhibits thereto) reflects the final and binding agreement between the Settling Parties to fully resolve the Litigation.


The Settlement, if approved, will result in the creation of a cash settlement fund of $9,875,000.00 (the “Settlement Amount”). The Settlement Amount and any interest it earns thereon is the “Settlement Fund.” The Settlement Fund, after deduction of Court-approved attorneys’ fees and expenses, Notice and Administration Expenses, Taxes, and any other fees or expenses approved by the Court, is the “Net Settlement Fund.” If the Settlement is approved by the Court, the Net Settlement Fund will be distributed to eligible Authorized Claimants—i.e., Settlement Class Members who timely submit valid Proofs of Claim—in accordance with the proposed Plan of Allocation.


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.


SUBMIT A PROOF OF CLAIM The only way to be eligible to receive a payment from the Settlement. Proofs of Claim must be postmarked (if mailed) or received (if submitted online) on or before March 22, 2021.
EXCLUDE YOURSELF FROM THE SETTLEMENT BY SUBMITTING A WRITTEN REQUEST FOR EXCLUSION Get no payment. This is the only option that potentially allows you to ever be part of any other lawsuit against any of the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement. Should you elect to exclude yourself from the Settlement Class, you should understand that Defendants and the other Released Defendant Parties will have the right to assert any and all defenses they may have to any claims that you may seek to assert, including, without limitation, the defense that any such claims are untimely under applicable statutes of limitations and statutes of repose. Exclusions must be received on or before March 22, 2021.
OBJECT TO THE SETTLEMENT BY SUBMITTING A WRITTEN OBJECTION Write to the Court about why you do not like the Settlement, the Plan of Allocation and/or the request for attorneys’ fees and expenses. You will still be a Member of the Settlement Class. Objections must be received by the Court and counsel for the Settling Parties on or before March 1, 2021.
GO TO THE HEARING ON APRIL 12, 2021, AND FILE A NOTICE TO APPEAR Ask to speak in Court about the fairness of the Settlement. Requests to speak must be received by the Court and counsel for the Settling Parties on or before March 1, 2021. If you submit a written objection, you may (but you do not have to) attend the hearing.
DO NOTHING Receive no payment. You will, however, still be a Member of the Settlement Class, which means that you give up your right to ever be part of any other lawsuit against the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement and you will be bound by any judgments or orders entered by the Court in the Litigation.


Submit Proof of Claim: March 22, 2021
File Objection: March 1, 2021
Request Exclusion: March 22, 2021
File Notice of Intention to Appear: March 1, 2021
Court Hearing on Fairness of Settlement: April 12, 2021, at 10:00 a.m. CT