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Sturman LLC served as counsel to the two European institutional investor lead plaintiffs representing investors who acquired Avon common stock between July 31, 2006 and October 26, 2011. The action concerned Avon’s assurances to investors that the company had effective internal controls and accounting systems, as required under the Foreign Corrupt Practices Act (FCPA).  In October 2008, Avon disclosed that it had begun an investigation into possible FCPA violations in China that revealed severely deficient internal controls, contradicting the company’s earlier certifications. This allowed the company to make millions of dollars of improper payments in more than a dozen countries. The court approved a final settlement of $62 million.