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Four tech giants have formally put a settlement before court that would put an end to a class action case that accuses them of conspiring to suppress wages in Silicon Valley through no-poaching agreements.

New court filings (embedded below), spotted by Reuters, confirm earlier reports that Apple(s aapl), Google(s goog), Adobe and Intel(s intc) have agreed to pay $324.5 million to around 64,000 workers.

The settlement, which proposes a schedule of notice and opt-out deadlines, must still be approved by a judge before it can take effect. One of the original plaintiffs, Michael Devine, is objecting to the deal on the grounds that it does do enough to punish the companies, but that will not necessarily halt approval.

The case began in 2011 and has been a hot topic in Silicon Valley, in part because of the role of Apple’s CEO in organizing the anti-poaching agreements.

Unlike many states, non-compete agreements are illegal in California, which is one reason the tech companies sought other ways to restrict employees’ movements.

Correction: an earlier version of this story named IBM instead of Adobe as part of the settlement. IBM was not involved in the proceeding. The story was updated at 12:45am ET.

Proposed Settlement in Wage Class Action

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