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.
No, you are not being sued.
The Actions claim that under ERISA, Defendants owed fiduciary duties of care and prudence to the Plan, and that they violated those duties in three primary ways. First, Named Plaintiffs allege Defendants failed to prudently monitor and control the recordkeeping fees charged to Plan participants. Recordkeeping in simple terms refers to the suite of administrative services provided to retirement plan participants that generally includes provision of account statements to participants. Second, Named Plaintiffs allege the Plan’s offering of the Ricoh Stable Value Fund as an investment option was unreasonable and imprudent. Third, Named Plaintiffs allege Defendants improperly utilized “forfeitures”—forfeited employer contributions from participants who terminated before vesting—to offset other employer contributions rather than to pay Plan expenses.
Defendants deny all of the claims and allegations made in the Actions and deny that they ever engaged in any wrongful conduct. If the Actions were to continue, the Defendants would raise numerous defenses to liability, including:
You are a member of the Settlement Class if you fall within the definition of the Settlement Class preliminarily approved by Judge Juan R. Sanchez:
All persons who participated in the Plan at any time during the Class Period, including any Beneficiary of a deceased Person who participated in the Plan at any time during the Class Period, and any Alternate Payee of a Person subject to a QDRO who participated in the Plan at any time during the Class Period. Excluded from the Settlement Class are Defendants and their Beneficiaries.
The “class period” referred to in this definition is from February 22, 2016 to March 24, 2026.
As in any litigation, all parties face an uncertain outcome. On the one hand, continuation of the case against the Defendants could result in a judgment greater than this Settlement. On the other hand, continuing the case could result in Plaintiffs obtaining no recovery at all or obtaining a recovery that is less than the amount of the Settlement. Based on these factors, the Named Plaintiffs and Class Counsel have concluded that the proposed Settlement is in the best interests of all Settlement Class members.
Provided that the Settlement becomes Final, a Settlement Fund consisting of $1,750,000.00 will be established in the Actions. The amount of money that will be allocated among members of the Settlement Class, after the payment of any taxes and Court-approved costs, fees, and expenses, including attorneys’ fees and expenses of Class Counsel, any Court-approved Case Contribution Awards to be paid to the Named Plaintiffs, and payment of expenses incurred in calculating the Settlement payments and administering the Settlement, is called the Net Settlement Amount. The Net Settlement Amount will not be known until these other amounts are quantified and deducted. The Net Settlement Amount will be allocated to members of the Settlement Class according to a Plan of Allocation to be approved by the Court. The Plan of Allocation describes how Settlement payments will be distributed to Settlement Class members who receive a payment.
If the Settlement is approved by the Court, all Settlement Class members and anyone claiming through them shall be deemed to fully release the Released Parties from Released Claims.
The Released Parties are (a) Defendants; (b) Defendants’ insurers, co-insurers, and reinsurers; (c) Ricoh’s direct and indirect past, present, and future affiliates, parents, subsidiaries, divisions, joint ventures, predecessors, successors, successors-in-interest, assigns, boards of trustees, boards of directors, officers, trustees, directors, partners, principals, agents, managers, members, employees or heirs (including any individuals who serve or served in any of the foregoing capacities, such as members of the boards of trustees or boards of directors that are associated with any of Defendants’ past, present, and future affiliates), and each Person that controls, is controlled by, or is under common control with them; (d) the Plan and the Plan’s current and past fiduciaries, administrators, plan administrators, recordkeepers, service providers, consultants, attorneys, agents, insurers and parties-in-interest; and (e) Defendants’ independent contractors, representatives, attorneys, administrators, insurers, fiduciaries, accountants, auditors, advisors, consultants, personal representatives, spouses, heirs, executors, administrators, associates, employee benefit plan fiduciaries (with the exception of the Independent Fiduciary), employee benefit plan administrators, service providers to the Plan (including their owners and employees), members of their immediate families, consultants, subcontractors, and all persons acting under, by, through, or in concert with any of them. Released Claims are defined in the Settlement Agreement and include (but are not limited to) all claims that were or could have been asserted in the Actions. This means, for example, that Settlement Class members will not have the right to sue the Released Parties for failure to prudently select and monitor the Plan’s investment options or fees, or related matters, that occurred during the Class Period.
The above description of the proposed Settlement is only a summary. The complete terms, including the definitions of the Released Parties and Released Claims, are set forth in the Settlement Agreement (including its exhibits), which may be obtained at this website (see Important Case Documents).
You do not need to file a claim. The Final Entitlement Amount for Settlement Class members with an Active Account (an account with a positive balance) as of the calculation of the Final Entitlement Amount (unless that Plan account is closed in the intervening period between the calculation of the Final Entitlement Amount and the payment of the Final Entitlement Amount, in which case that Class Member will receive their allocation via a check) will be paid into the Plan. Former Participants entitled to a payment will be paid directly by the Settlement Administrator by check.
All such payments are intended by the Settlement Class to be “restorative payments” in accordance with Internal Revenue Service Revenue Ruling 2002-45. Checks issued to Former Participants pursuant to this paragraph shall be valid for 180 days from the date of issue. If you are a former Plan participant and have not provided the Plan with your current address, please contact Class Counsel.
Each Class Member who receives a payment under this Settlement Agreement shall be fully and ultimately responsible for payment of any and all federal, state, or local taxes resulting from or attributable to the payment received by such person.
The Court has preliminarily appointed the law firm of Capozzi Adler, P.C. as Class Counsel for the Named Plaintiffs in the Actions. You will not be charged directly by these lawyers. If you want to be represented by your own lawyer, you may hire one at your own expense.
You do not have the right to exclude yourself from the Settlement. The Settlement Agreement provides for certification of the Settlement Class as a non-opt-out class action under Federal Rule of Civil Procedure 23(b)(1), and the Court has preliminarily determined that the requirements of that rule have been satisfied. Thus, it is not possible for any Settlement Class members to exclude themselves from the Settlement. As a Settlement Class member, you will be bound by any judgments or orders that are entered in the Actions for all claims that were or could have been asserted in the Actions or are otherwise released under the Settlement.
If you are a Settlement Class Member, you can object to the Settlement if you do not like any part of it. You can give reasons why you think the Court should not approve it. To object, you must send a letter or other writing saying that you object to the Settlement in Kruchten, et al. v. Ricoh USA Inc., et al., No. 2:22-cv-00678-JS. Be sure to include your name, address, telephone number, signature, and a full explanation of all the reasons why you object to the Settlement. You must file your objection with the Clerk of the Court of the United States District Court for the Eastern District of Pennsylvania so that it is received no later than September 21, 2026. The address is:
Clerk of the Court
United States District Court for the Eastern District of Pennsylvania
James A. Byrne U.S. Courthouse
601 Market Street #2609
Philadelphia, PA 19106
The objection must refer prominently to this case name: Kruchten, et al. v. Ricoh USA Inc., et al., No. 2:22-cv-00678-JS.
A copy of your objection must also be provided to Class Counsel and Defense Counsel by email to settlement@Capozziadler.com (writing “Ricoh Settlement” in the subject line) or write to the following respective addresses for Class and Defense Counsel:
Class Counsel
Mark K. Gyandoh
Capozzi Adler, P.C.
312 Old Lancaster Rd
Merion Station, PA 19066
Defense Counsel
Jeremy P. Blumenfeld
Morgan, Lewis & Bockius LLP
2222 Market Street
Philadelphia, PA 19103
The Fairness Hearing currently is scheduled for 9:30 a.m. on October 8, 2026, at the United States District Court for the Eastern District of Pennsylvania, Courtroom 14-B, or such other courtroom as the Court may designate.
At that hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them. The Court will also rule on the motions for attorneys’ fees and reimbursement of expenses and for Case Contribution Awards for the Named Plaintiffs. The Parties do not know how long these decisions will take or whether appeals will be filed.
The Court may adjourn the Fairness Hearing without further notice to the Settlement Class and also may schedule the hearing to be done by telephone or video conference. If you wish to attend, you should confirm the date and time of the Fairness Hearing with Class Counsel before doing so. You can also refer to this website, where any updates to the date, time, or venue of the Fairness Hearing will be posted.
No, but you are welcome to come at your own expense. If you file an objection, you do not have to come to Court to talk about it. As long as you mailed your written objection on time, it will be before the Court when the Court considers whether to approve the Settlement. You also may pay your own lawyer to attend the Fairness Hearing, but such attendance is also not necessary.
If you submit a written objection to the Settlement to the Court and counsel before the Court-approved deadline, you may (but do not have to) attend the Fairness Hearing and present your objections to the Court. You may attend the Fairness Hearing even if you do not file a written objection, but you will only be allowed to speak at the Fairness Hearing if you file a written objection in advance of the Fairness Hearing AND you file a Notice of Intention To Appear, as described in this paragraph. To do so, you must file with the Court a letter or other paper called a “Notice of Intention to Appear at Fairness Hearing in Kruchten, et al. v. Ricoh USA Inc., et al., No. 2:22-cv-00678-JS.” Be sure to include your name, address, telephone number, and your signature. Your Notice of Intention To Appear must be received by the attorneys listed in the answer to “How do I object to the Settlement?”, no later than September 21, 2026, and must be filed with the Clerk of the Court at the address listed in the answer to “How do I object to the Settlement?”.
You may email Class Counsel at settlement@capozziadler.com (write “Ricoh Settlement” in the subject line), or call the Settlement Administrator at 855-294-0138.