All persons, corporations, and other entities, resident in British Columbia who have purchased defective Defendants’ toys subject to recall, that were manufactured, or caused to be manufactured, distributed, or ultimately offered for sale, and sold to the public, by the Defendants, to their customers or retailers, and as the next friend of all children suffering medical damage as a result of the use of the Defendants’ toys subject to recall.

And

All persons, corporations and other entities, who are no resident in British Columbia but who are resident or situated in another Canadian province or territory, who have purchased defective Defendants’ toys subject to recall, that were manufactured or caused to be manufactured, distributed, or ultimately offered for sale, and sold to the public, by the Defendants, to their customers or retailers, and as the next friend of all children suffering medical damage as a result of the use of the Defendants’ toys subject to recall.