Julie Siegmund and Seth Lipner as Co-Successor Trustees of The Frederick Siegmund Linkwell Corp. Claims Living Trust dated July 31, 2018 v. Xuelian Bian et. al.
Linkwell Corp. Securities Litigation
Case No. 16-cv-62506-FAM (S.D. Fla.)

Frequently Asked Questions


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  • You or someone in your family may have owned Linkwell common stock as of the close of business on September 19, 2014, the day that the Merger was approved. 

    The Court directed that the Notice be sent to Class Members because they have a right to know about the proposed partial Settlement in this  Action, and about all of their options, before the Court decides whether to approve the Settlement. If approved, the Settlement will end all of the Class’s claims against Defendants. The Court will consider whether to approve the Settlement at a Settlement Hearing on November 19, 2019 at 2 p.m. If the Court approves the Settlement, and after any appeals are resolved and the Settlement administration is completed, the Claims Administrator appointed by the Court will make the payments that the Settlement allows. 

    The Court in charge of the case is the United States District Court for the Southern District of Florida, and the case is known as Julie Siegmund and Seth Lipner as Co-Successor Trustees of The Frederick Siegmund Linkwell Corp. Clams Living Trust dated July 31, 2018 v. Xuelian Bian, et al., Civil Action No. 0:16-cv-62506-FAM (S.D. Fla.). This case was assigned to United States District Judge Federico A. Moreno. The parties that are suing are called “Proposed Class Representatives” and the companies and the persons being sued are called “Defendants.”

  • Proposed Class Representatives’ claims in the Action are stated in the First Amended Class Action Complaint dated October 19, 2017 (the “Complaint”). Proposed Class Representatives alleged claims against some or all of the Defendants for violations of Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”), and Florida law for breaches of fiduciary duty, aiding and abetting breaches of fiduciary duty, and civil conspiracy. The Complaint alleged that Defendants violated the federal securities law and/or Florida law by allegedly undertaking the Merger to (a) extinguish the valuable claims asserted in a previously filed derivative action on behalf of Linkwell; and (b) take Linkwell private and acquire the assets and operations of Linkwell’s subsidiary businesses without due notice and for less than fair consideration. 

    The Action was commenced on October 24, 2016.  Sidley moved to dismiss the Action on December 15, 2017. On September 29, 2017, the Court entered an Order granting the motion to dismiss, however, with leave to file an amended complaint. As set forth above, the amended pleading was filed on October 19, 2017. 

    On December 18, 2017 and January 30, 2018, Defendants filed motions to dismiss the Complaint for failure to state a claim upon which relief could be granted, lack of personal jurisdiction, and insufficient service of process. On January 17 and February 23, 2018, the motions were opposed. On April 2, 2018, the Court entered an Order granting the dismissal of the Section 10(b) claims against Sidley, however, sustained the Florida law claims in the Complaint for aiding and abetting breach of fiduciary duty and civil conspiracy. In another Order entered on the same date, the Court sustained the Section 10(b) claims and Florida law claims for breach of fiduciary duty and civil conspiracy against Bian and Guan. On May 14, 2018, the Court entered an Order denying Sidley’s motion for reconsideration of that part of the Order that sustained the Florida law claims. Fact and expert discovery was thereafter conducted by the parties.

    On June 5 and September 28, 2018, the parties participated in mediations of the Action before a well-respected mediator, Jed Melnick. Proposed Class Representatives and Defendants subsequently agreed to resolve the Action for $6,000,000 in cash subject to the negotiation of the terms of the Settlement Agreement and approval by the Court. 

    The Settling Parties entered into the Stipulation on May 1, 2019. On July 12, 2019, the Court preliminarily approved the Settlement, authorized the Notice to be sent to potential Class Members, and scheduled the Fairness Hearing to consider whether to grant final approval to the Settlement.

  • In a class action, one or more people called class representatives (in this case Proposed Class Representatives) sue on behalf of people or entities, known as “Class Members” who have similar claims. A class action allows one court to resolve in a single case many similar claims that, if brought separately by individuals, might be so small that they would not be economical to litigate and thus would never be brought. One court resolves the issues for all class members, except for those who exclude themselves, or “opt out,” from the Class (see FAQ "How do I “opt out” (exclude myself) from the Settlement?").

  • The Court has not decided the Action in favor of Proposed Class Representatives or Defendants. The Settlement will end all the claims against Defendants in the Action and avoid the uncertainties and costs of further litigation and any future trial. Assuming the Settlement is approved, affected investors will be eligible to receive cash compensation once the claims made against the Net Settlement Fund are validated and calculated. 

    Proposed Class Representatives, through Proposed Class Counsel, conducted an extensive investigation of the claims and transactions relating to the Action, vigorously pursued discovery from Defendants and third-parties related to the claims, underlying events, and transactions, and retained two outside separate experts to assist and evaluate the claims. Further, Proposed Class Counsel participated in hard-fought arm’s-length negotiations and two mediation sessions before an experienced mediator prior to entering into the Settlement. 

    Defendants also vigorously pursued discovery and retained outside experts. Defendants denied and continue to deny all allegations of liability contained in the Complaint and deny that they are liable to the Class. The Settlement should not be seen as an admission or concession on the part of Defendants regarding the truth or validity of the allegations, claims, and/or defenses in the Action, or their fault or liability for alleged damages allegedly suffered by any Class Member.

  • The Court has issued an Order, for the purposes of the Settlement only, that everyone who fits the following description, and is not excluded by definition from the Class (see FAQ "Are there exceptions to being included in the Class?" below), is a Member of the Class, or a “Class Member,” unless they take steps to exclude themselves:

    All persons and entities who owned, either as a record or beneficial owner, one or more shares of Linkwell common stock as of the close of business on September 19, 2014, who did not vote to approve the Merger between Linkwell and LeadingWorld Corporation, whose shares were canceled as a result of  the Merger between Linkwell and Leading World Corporation, and were allegedly damaged thereby.

    Receipt of the Notice does not mean that you are a Class Member. Please check your records or contact your broker to see if you owned Linkwell securities as of the close of business on September 19, 2014, and that your shares were canceled as a result of the Merger.

  • There are some people who are excluded from the Class by definition. Excluded from the Class are Bian, Guan, Sidley and its employees and agents, Yinling, Leading First, Leading World Corporation, and their subsidiaries and affiliates, all Linkwell shareholders who voted to approve the Merger, and all persons who make a timely request to opt out of the Settlement Class. 

    You are a Class Member only if you (or your broker on your behalf) owned shares of Linkwell common stock as of the close of business on September 19, 2014 and your shares were canceled as a result of the Merger.

  • If you are not sure whether you are included, you can ask for free help by writing to or calling the Claims Administrator: Linkwell Corp. Securities Litigation, Claims Administrator, c/o JND Legal Administration, P.O. Box 91211, Seattle, WA 98111-9311, 1-833-285-1327, or www.linkwellcorpshareholderlitigationsettlement.com. Or you can fill out and return the Proof of Claim and Release form (“Proof of Claim”) described in FAQ "How can I get a payment?", to see if you qualify.

  • In the Settlement, Defendants have agreed to pay or cause to be paid $6,000,000 in cash, which will be deposited in an interest-bearing escrow account for the benefit of the Class (the “Settlement Fund”). The Settlement Fund will be divided, after deduction of Court-awarded attorneys’ fees and expenses, settlement administration costs and any applicable taxes and tax estimates, among all Class Members, as set forth in the Plan of Allocation, who timely submit valid Proofs of Claim that are accepted for payment by the Court (“Authorized Claimants”).

  • The Plan of Allocation, discussed on page 16 of the Notice, explains how the Net Settlement Fund will be allocated among owners of Linkwell common stock. Your share of the Net Settlement Fund will depend on several things, including: (i) the number of claims filed by eligible Class Members; and (ii) the country of residence of those Class Members.

    After all Class Members wishing to receive a share of the Net Settlement Fund have sent in their Proofs of Claim, the payment any Authorized Claimant will get will be their pro rata share of the Net Settlement Fund based on the Plan of Allocation approved by the Court. In general, an Authorized Claimant’s share will be his, her or its number of shares of Linkwell common stock divided by the total number of shares of Linkwell common stock owned by all Authorized Claimants and then multiplied by the total amount in the Net Settlement Fund. Authorized Claimants residing in the United States and its territories shall have their claims valued at the full amount of the claim. Authorized Claimants who do not reside in the United States and its territories, and all Linkwell record shareholders who did not vote to approve the Merger, shall have their claims valued at 40% of the full amount of the claim. See the Plan of Allocation on page 16 of the Notice.

  • To qualify for a payment, you must timely mail, or submit online, a valid Proof of Claim and Release (“Proof of Claim”) with supporting documents (DO NOT SEND ORIGINALS of your supporting documents). A Proof of Claim is enclosed with the Notice. You may also get copies of the Proof of Claim on the Internet at the following website: www.linkwellcorpshareholderlitigationsettlement.com. Please read the instructions carefully, fill out the Proof of Claim, include all the documents the form asks for, sign it, and mail it to the Claims Administrator by First-Class Mail, postmarked or submitted online on or before February 4, 2020. The Claims Administrator needs all of the information and documents requested in the Proof of Claim in order to determine if you are eligible to receive a distribution from the Net Settlement Fund.

    Any Class Member who fails to timely submit a Proof of Claim shall be barred from receiving any distribution from the Net Settlement Fund or payment pursuant to the Settlement unless, by order of the Court or the discretion of Proposed Class Counsel, late-filed Proofs of Claim are accepted, but shall in all other respects be bound by all the terms of the Settlement, including the terms of the Judgment and all releases provided for herein and therein, and will be permanently barred and enjoined from bringing any action, claim or other proceeding of any kind against any Released Person concerning the Settled Claims.

  • The Court will hold a hearing on November 19, 2019 at 2 p.m., to decide whether to, among other things, approve the Settlement and the proposed Plan of Allocation. All Proofs of Claim must be postmarked or submitted online to the Claims Administrator, on or before February 4, 2020. If the Court approves the Settlement, there may still be appeals which would delay payment, perhaps for more than several years. It also takes time for all the Proofs of Claim to be processed. Please be patient.

  • Unless you exclude yourself, you will stay in the Class, which means that as of the date that the Settlement becomes effective under the terms of the Stipulation (the “Effective Date”), you will forever give up and release all “Settled Claims” (as defined below) against the “Released Parties” (as defined below). You will not in the future be able to bring a case asserting any Settled Claim against any Released Parties. 

    (a) “Settled Claims” means any and all claims, debts, demands, rights, losses, damages, causes of action or liabilities, of every nature and description whatsoever arising from the beginning of time through the Effective Date, whether fixed or contingent, accrued or unaccrued, liquidated  or unliquidated, based in law or equity, or based on any foreign, federal, state, local, statutory or common law, or any other law, rule or regulation (including any claims for violations of Fed. R. Civ. P. 11), including both known claims and Unknown Claims that have been or could have been asserted in any forum by any Class Member, on behalf of themselves and any other legal or natural persons and entities who or which may claim by, through or under them, including their executors, administrators, heirs, assigns, privies, predecessors and successors, whether directly, indirectly, derivatively, representatively or in any other capacity against any of the Released Parties, which arise out of, relate to, or are based upon, in any way, directly or indirectly (a) the claims, allegations, transactions, facts, events, matters, occurrences, acts, representations or omissions involved, set forth, or referred to, or that could have been asserted in the Action, or (b) the purchase, sale, or cancellation of Linkwell securities by any Class Member. For the avoidance of doubt, the Settled Claims do not include claims to enforce the Settlement, if approved by the Court. 

    (b) “Released Parties” means the Settling Defendants and includes their directors, officers, employees, agents, consultants, attorneys, partners, associates, insurers, reinsurers, personal representatives, spouses, issues, heirs, executors, administrators, predecessors, successors, assigns, and affiliates. The Released Parties are express third-party beneficiaries of the Stipulation.

    (c) “Unknown Claims” means any and all Settled Claims that any Class Member does not know or suspect to exist in his, her or its favor at the time of the release of the Released Parties, which if known by him, her, or it might have affected his, her or its decision(s) with respect to the Settlement. With respect to any and all Settled Claims, each Class Member acting through Proposed Class Counsel, shall each, for themselves and all persons claiming by, through, or on behalf of them, be deemed to have waived, and by operation of the Final Judgment and Order shall have expressly waived, any  and all provisions, rights and benefits conferred by any law of any state or territory of the United States, or principle of common law, that is similar, comparable, or equivalent to Cal. Civ. Code § 1542, which provides:


    Proposed Class Representatives, other Class Members or Defendants may hereafter discover facts in addition to or different from those which he, she, or it now know or believes to be true with respect to the subject matter of the Settled Claims, but hereby stipulates and agrees that Proposed Class Representatives, and each releasing person, shall be deemed to settle and release, and upon the Effective Date and by operation of the Order and Final Judgment shall have settled and released, fully, finally, and forever, and all Settled Claims against Released Parties, known or unknown, suspected or unsuspected, contingent or non-contingent, whether or not concealed or hidden, which now exist, or which heretofore existed upon any theory of law or equity now existing or coming into existence in the future, including, but not limited to, conduct that is negligent or intentional and with or without malice, or a breach of any duty, law, or rule, without regard to the subsequent discovery or existence of such different or additional facts.

  • If you want to keep any right you may have to sue the Released Parties on your own about the Settled Claims, then you must take steps to exclude yourself from the Class. Excluding yourself is known as “opting out” of the Class. Defendants may withdraw from and terminate the Settlement if potential Class Members who owned shares of Linkwell common stock as of the close of business on September 19, 2014 and whose shares were canceled as a result of the Merger opt out from the Class in an amount in excess of 5% of the Class.

    If you timely and properly request exclusion from the Class, you will retain any rights you have to sue Defendants yourself with respect to the Settled Claims to the extent those claims are viable under the applicable statute of limitations. You should note that if you exclude yourself from the Class, you may forfeit any claims you may have against Defendants relating to your ownership of Linkwell securities as of the close of business on September 19, 2014 if you fail to act in a proper and timely manner under the applicable statutes of limitation and repose. Before you decide to request exclusion from the Class, you are urged to consult with an attorney, at your own expense, to fully evaluate your rights and the consequences of excluding yourself from the Class.

  • To “opt out” (exclude yourself) from the Class, you must deliver or mail a signed letter by First-Class Mail stating that you “request exclusion from the Class in Julie Siegmund and Seth Lipner as Co-Successor Trustees of The Frederick Siegmund Linkwell Corp. Clams Living Trust dated July 31, 2018 v. Xuelian Bian, et al., Civil Action No. 0:16-cv-62506-FAM (S.D. Fla.).” Your letter must state the number of shares of Linkwell common stock you owned as of the close of business on September 19, 2014 and that your shares were cancelled as a result of the Merger. This information is needed to determine whether you are a Class Member. In addition, you must include your name, address, telephone number, and your signature. You must submit your request for exclusion addressed to Linkwell Corp. Securities Litigation, EXCLUSIONS, c/o JND Legal Administration, P.O. Box 91211, Seattle, WA 98111-9311. The request for exclusion must be received on or before October 21, 2019. You cannot exclude yourself or opt out by telephone or by email. Your request for exclusion must comply with these requirements in order to be valid. If you are excluded, you will not be eligible to get any payment from the Settlement proceeds and you cannot object to the Settlement, the proposed Plan of Allocation or the application for attorneys’ fees and expenses.

  • No. Unless you exclude yourself, you give up any rights you may have to sue Defendants for all Settled Claims. If you have a pending lawsuit against any of the Defendants, speak to your lawyer in that case immediately. You must exclude yourself from this Class to continue your own lawsuit. Remember, the exclusion deadline is October 21, 2019.

  • No. If you exclude yourself, do not send in a Proof of Claim to ask for any money, as any such Proof of Claim will be rejected.

  • The law firm of Wolf Haldenstein Adler Freeman & Herz LLP (“Proposed Class Counsel”) will move to be appointed as Class Counsel to represent all Class Members. You will not be separately charged for the services of these lawyers. The Court will determine the amount of attorney’s fees and expenses, if any, to be paid to Proposed Class Counsel. Any fees and expenses awarded by the Court will be paid from the Settlement Fund. If you want to be represented by your own lawyer, you may hire one at your own expense.

  • Proposed Class Counsel have not received any payment for their services in pursuing the claims against the Defendants on behalf of the Class since the Action was commenced in 2016, nor have they been paid to this point for any of their litigation expenses. At the Settlement Hearing described in the FAQ "When and where will the Court decide whether to approve the Settlement?", or at such other time as the Court may order, Proposed Class Counsel will ask the Court to award them, from the Settlement Fund, attorneys’ fees of no more than 35% of the Settlement Amount and litigation expenses that they have incurred in pursuing the Action in an amount not to exceed $450,000, plus interest on both amounts from the date of funding at the same rate earned by the Settlement Fund. Proposed Class Counsel will also request an award to The Siegmund Trust for the reimbursement of its reasonable costs and expenses (including lost wages) directly related to its representation of the Class, in an amount not to exceed $15,000, pursuant to the PSLRA.

  • If you are a Class Member and do not exclude yourself (opt out) in accordance with FAQ "How do I “opt out” (exclude myself) from the Settlement?", you can object to any part of the Settlement, the proposed Plan of Allocation, and/or the application by Proposed Class Counsel for attorneys’ fees and expenses and request for an award to the Siegmund Trust. You must write to the Court setting out your objection, giving reasons why you think the Court should not approve any part or all of the Settlement, the proposed Plan of Allocation, or the attorneys’ fee and expense request. 

    To object, you must send a signed letter stating that you object to the Settlement in the case known as: Julie Siegmund and Seth Lipner as Co-Successor Trustees of The Frederick Siegmund Linkwell Corp. Clams Living Trust dated July 31, 2018 v. Xuelian Bian, et al., Civil Action No. 0:16-cv-62506-FAM (S.D. Fla.). You must include your name, address, telephone number and your signature; include documents sufficient to prove your membership in the Class, such as the number of Linkwell securities owned as of the close of business on September 19, 2014 and the cancelation of those securities as a result of the Merger. Your letter must also state the specific reasons why you object to the Settlement, the proposed Plan of Allocation, the attorneys’ fee and expense request, or award request, including any legal or evidentiary support for your objection. 

    Unless otherwise ordered by the Court, any Class Member who does not object in the manner described in the Notice will be deemed to have waived any objection and will not be able to appear separately at the Fairness Hearing or to make any objection to the Settlement, the proposed Plan of Allocation, the application for attorneys’ fees and expenses, and/or award request. If you elect to “opt out,” you will not be entitled to share in the Settlement proceeds and will not have a right to make an objection to the Settlement, proposed Plan of Allocation, the application for attorneys’ fees and expenses, or award request. 

    Your objection must be filed with the United States District Court for the Southern District of Florida by hand or by mail such that it is received on or before October 29, 2019, at the address set forth below. You must also serve the papers on Proposed Class Counsel and Defendants’ Counsel at the addresses set forth below so that the papers are received on or before October 29, 2019.


    Clerk of the Court
    United States District Court
    Southern District of Florida
    United States Courthouse
    Wilkie D. Ferguson, Jr. Building
    400 North Miami Avenue
    Miami, FL 33128
    Charles J. Hecht, Esq.
    Wolf Haldenstein Adler Freeman & Herz LLP
    270 Madison Avenue
    New York, NY 10016
    Alice K. Sum, Esq.
    Fowler White Burnett, P.A.
    Brickell Arch
    1395 Brickell Avenue, 14th Floor
    Miami, FL 33131
    Stephen Warren, Esq.
    Holland & Knight LLP
    701 Brickell Avenue
    Suite 3300
    Miami, FL 33131


  • Objecting is simply telling the Court that you do not like something about the Settlement. You can still recover from the Settlement. You can object only if you stay in the Class. Excluding yourself is telling the Court that you do not want to be part of the Class. If you exclude yourself, you have no right to object because the Action no longer affects you and you are no longer a Member of the Class.

  • The Court will hold a Fairness Hearing at 2 p.m. on November 19, 2019, in the United States District Court for the Southern District of Florida, United States Courthouse, Wilkie D. Ferguson, Jr. Building, 400 North Miami Avenue, Miami, FL 33128. At this hearing, the Court will consider whether the Settlement is fair, reasonable and adequate. The Court also will consider the proposed Plan of Allocation for the proceeds of the Settlement and Proposed Class Counsel’s application for attorneys’ fees and expenses. The Court will take into consideration any written objections filed in accordance with the instructions set out in the FAQ "How do I tell the Court that I do not like something about the proposed Settlement?". We do not know how long it will take the Court to make these decisions. 

    You should also be aware that the Court may change the date and time of the Fairness Hearing without another Notice being sent to Class Members. If you want to come to the hearing, you should check with Proposed Class Counsel before coming to be sure that the date and/or time has not changed.

  • No. Proposed Class Counsel will answer any questions the Court may have. But, you are welcome  to come at your own expense. If you validly submit an objection, as set forth in FAQ "How do I tell the Court that I do not like something about the proposed Settlement?", it will be considered by the Court. You do not have to come to Court to talk about it.

  • If you file an objection, you may ask the Court for permission to speak at the Fairness Hearing. To do so, you must include with your objection (see FAQ "How do I tell the Court that I do not like something about the proposed Settlement?") a statement that it is your “notice of intention to appear in Julie Siegmund and Seth Lipner as Co-Successor Trustees of The Frederick Siegmund Linkwell Corp. Clams Living Trust dated July 31, 2018 v. Xuelian Bian, et al., Civil Action No. 0:16-cv-62506-FAM (S.D. Fla.).” Persons who object and want to present evidence at the Fairness Hearing must also include in their written objection the identity of any witness they may call to testify and exhibits they intend to introduce at the Fairness Hearing. You cannot speak at the hearing if you exclude yourself from the Class or if you have not provided written notice of your intention to speak at the Fairness Hearing according to the procedures described above and in the answer to FAQ "How do I tell the Court that I do not like something about the proposed Settlement?".

  • If you do nothing, you will get no money from this Settlement and you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendants about the Settled Claims in this case. To be eligible to share in the Net Settlement Fund you must submit a Proof of Claim (see FAQ "How can I get a payment?"). To start, continue or be a part of any other lawsuit against Defendants about the Settled Claims in this case you must exclude yourself from the Class (see FAQ "How do I “opt out” (exclude myself) from the Settlement?").

  • The Notice summarizes the proposed Settlement. More details are in the Stipulation. You may review the Stipulation filed with the Court and all documents filed in the Action during business hours at the Office of the Clerk of the United States District Court for the Southern District of Florida, United States Courthouse, Wilkie D. Ferguson, Jr. Building, 400 North Miami Avenue, Miami, FL 33128.

    You also can call the Claims Administrator at: 1-833-285-1327; call Proposed Class Counsel Wolf Haldenstein Adler Freeman & Herz LLP: 1-212-545-4600; write to Linkwell Corp. Securities Litigation, Claims Administrator, c/o JND Legal Administration, P.O. Box 91211, Seattle, WA 98111-9311; or visit the website www.linkwellcorpshareholderlitigationsettlement.com, where you can download copies of the Notice and the Proof of Claim. Please do not call the Court, the Defendants or their counsel with questions about the Settlement.

  • If you held Linkwell securities as of the close of business on September 19, 2014 for the beneficial interest of a person or organization other than yourself and those securities were canceled as a result of the Merger, the Court has directed that you either: (a) within ten (10) business days of your  receipt of the Notice, request additional copies of the Notice and the Proof of Claim form, which will be provided to you free of charge, and within ten (10) business days of receipt of such copies send them by First-Class Mail, postage prepaid, directly to the beneficial owners of those shares of Linkwell common stock; or (b) within ten (10) calendar days of your receipt of the Notice, provide to the Claims Administrator the name and last known address of each person or organization for whom or which you purchased or otherwise acquired Linkwell common stock during the Class Period (preferably in an MS  Excel, .CSV, or .TXT format), setting forth (i) title/registration, (ii) street address, and (iii) city/state/zip.

    If you choose to follow alternative procedure (a), the Court has directed that, upon such mailing, you shall send a statement to the Claims Administrator confirming that the mailing was made as directed. You are entitled to reimbursement from the Settlement Fund of your reasonable expenses actually incurred in connection with the foregoing, including reimbursement of postage expenses and the cost of ascertaining the names and addresses of beneficial owners. Those expenses will be paid after request and submission of appropriate supporting documentation. All communications concerning the foregoing should be addressed to the Claims Administrator:

    Linkwell Corp. Securities Litigation
    c/o JND Legal Administration
    P.O. Box 91211
    Seattle, WA 98111-9311



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Linkwell Corp. Securities Litigation
c/o JND Legal Administration
P.O. Box 91211
Seattle, WA 98111-9311