WHO REPRESENTS THE CLASS?

15.

WHO IS RESPONSIBLE FOR CLASS COUNSELS FEES?

16.

WHEN WILL I RECEIVE MY SETTLEMENT BENEFITS?

17.

DO I HAVE TO ATTEND THE FINAL APPROVAL HEARING?

18.

WHERE CAN I GET MORE INFORMATION?

-2QUESTIONS? CALL 1-888-888-3082 TOLL FREE, OR VISIT WWW. DOORLOCKSETTLEMENT.COM

1.

WHY DID I RECEIVE THIS NOTICE?

You received this notice because you may have owned or leased (1) a Honda
CR-V, model year 2007-2008, or (2) a Honda CR-V, model year
2009, within certain VIN ranges.

2.

WHY SHOULD I READ THIS NOTICE?

You may be eligible to receive money and other benefits from the settlement of a
lawsuit regarding power door lock actuator failures in CR-Vs. If the judge approves the
settlement, it will release certain claims you might have.

3.

WHAT IS THE LAWSUIT ABOUT?

The lawsuit asserts that a part on your CR-V called a “door lock actuator” was
defectively designed and that as a result, the power door locks on your CR-V may not have
operated as intended.

4.

WHAT IS A CLASS ACTION?

In a class action, one or more people called “class representatives” sue on behalf of
people who may have similar claims. One court resolves the issues for all class members,
except for class members who exclude themselves from the class.

5.

HOW DO I KNOW IF I AM A CLASS MEMBER?

You are a class member if you are a resident of the United States, Puerto Rico, the
U.S. Virgin Islands, or Guam and you currently own or lease, or previously owned or
leased, (1) a Honda CR-V, model years 2007-2008, (2) a Two-Wheel Drive Honda CR-V,
model year 2009, with a VIN in one of the following ranges:
JHLxxxxxxxx000001–JHLxxxxxxxx007343; 5J6xxxxxxxx000001–5J6xxxxxxxx003420; or
3CZxxxxxxxx700001–3CZxxxxxxxx701680; or (3) an All-Wheel Drive Honda CR-V,
model year 2009, with a VIN in one of the following ranges:
JHLxxxxxxxx000001–JHLxxxxxxxx007327; 5J6xxxxxxxx000001–
5J6xxxxxxxx007526; or 3CZxxxxxxxx700001-3CZxxxxxxxx700240. You are also a Class
Member if you bought or leased one of these CR-Vs outside the United States while you
were serving in the U.S. military. You are not in the class if you work
-3QUESTIONS? CALL 1-888-888-3082 TOLL FREE, OR VISIT WWW. DOORLOCKSETTLEMENT.COM

for Honda or one of its affiliated companies or if you are an independent Honda or Acura
dealer that currently owns the vehicles.

6.

WHY IS THERE A SETTLEMENT?

The parties on both sides, despite believing in their positions, decided that a
settlement was better than the uncertainty and expense of litigation. The class
representatives and their attorneys believe the settlement is best for all settlement class
members.

7.

WHAT CAN I GET UNDER THE SETTLEMENT?
Under the proposed settlement, class members receive three kinds of benefits.

CURRENT OWNERS/LESSEES
The first benefit, provided to all current owners and lessees of the CR-Vs, is a free
replacement of the drivers door lock actuator even if the actuator is functioning properly, as
long as the actuator has not already been replaced with the appropriate part. To receive a
new door lock actuator, you must take your CR-V to an authorized Honda dealer.
The second benefit, provided to all current owners and lessees of the CR-Vs
(assuming they do not exclude themselves from the settlement) is a warranty extension on
the door lock actuators (this includes the front and rear passenger and driver doors but
excludes the hatch). The warranty extension lasts (i) three years from the date the original
limited car warranty expired, or (ii) until November 7, 2015, whichever is longer. The
warranty covers any diagnosis, repair, or replacement of a door lock actuator (excluding the
hatchback lock actuator) performed by a Honda dealer. The warranty extension does not
apply to repairs that result from accidents or misuse. Under the extended warranty, Honda
will provide door lock actuator repairs without charge at an authorized Honda dealer at any
time between the mailing of this Notice and the expiration of the extended warranty.

-4QUESTIONS? CALL 1-888-888-3082 TOLL FREE, OR VISIT WWW. DOORLOCKSETTLEMENT.COM

CURRENT AND FORMER OWNERS/LESSEES
The third benefit, provided to both current and former owners and lessees of the
CR-Vs who do not exclude themselves from the settlement, is reimbursement for outof-pocket expenses for door lock actuator repairs. If you paid to replace a door lock actuator
on your CR-V as a result of power door lock failure (not because of an accident), you may
submit a claim for reimbursement. If a portion of your out-of-pocket expenses for the repair
has been reimbursed by Honda or by a third party, only the amount not reimbursed will be
deemed an out-of-pocket expense. To be eligible for reimbursement, you must provide
original proof of payment and submit a valid Claim Form before July 6, 2015.

8.

HOW DO I MAKE A CLAIM FOR REIMBURSEMENT?

Follow the instructions on the Claim Form that accompanies this notice. You must
also include original proof of repair and cost, and complete the certification as required by
the Claim Form. Completed Claim Forms and supporting documentation must be sent to the
following address:
Settlement Administrator
P.O. Box 2718
Torrance, CA 90509
All Claim Forms and supporting documents must be postmarked by July 6, 2015.

9.

WHAT DO I GIVE UP IF THE SETTLEMENT IS APPROVED?

The settlement provides for a “release” of claims related to power door lock actuator
failures on the CR-Vs (excluding the hatchback lock actuator) but does not include claims
arising from death, personal injury, or property damage. This means you would not be able
to sue over the cost of replacing a door lock actuator or any other monetary losses you might
incur as a result of a door lock actuator failure.

-5QUESTIONS? CALL 1-888-888-3082 TOLL FREE, OR VISIT WWW. DOORLOCKSETTLEMENT.COM

10. WHO WILL DETERMINE WHETHER THE SETTLEMENT IS FAIR?
The judge will decide whether the settlement is fair to the class members. The judge
is scheduled to hold a hearing on the settlement on May 7, 2015, at 10:00 a.m. in Courtroom
MLK 2A of the United States District Court for the District of New Jersey, located at:
Martin Luther King Building & U.S. Courthouse 50 Walnut Street, Newark, New Jersey
07101. At that hearing, the Court will consider whether to approve the settlement. The Court
will also determine the amount of any awards for the class representatives, and the amount
of attorneys fees and costs to be awarded to the lawyers for the class.

11. CAN I OBJECT TO THE SETTLEMENT?
Yes. If you are a settlement class member and do not opt out of the class, you have
the right to object to the settlement. Any objection must be in writing and must be filed with
the Court and sent to class counsel and Hondas counsel at the addresses listed below. All
objections must be filed with the court electronically or postmarked on or before March
20, 2015.
If you file an objection, it must include: (1) the title of the case, Davitt v. American
Honda Motor Co., Inc., No. 13-cv-00381; (2) your name, address, and phone number; (3)
the approximate date when you bought or leased your CR-V and the vehicle identification
number (VIN) of your CR-V; (4) a statement that you have reviewed the settlement class
definition and that you are a settlement class member; (5) all legal and factual bases for any
objection; and (6) copies of any documents you wish to submit to support your objection. In
addition, if you object to the settlement, you must provide a list of all other objections
submitted by you, or your counsel, to any class action settlements in the United States in the
previous five years. If you (or your counsel) have not objected to any other class action
settlement in the United States in the previous five years, you must say so in the objection.
You may also have to attend a deposition on the issues raised in the objection.

-6QUESTIONS? CALL 1-888-888-3082 TOLL FREE, OR VISIT WWW. DOORLOCKSETTLEMENT.COM

If you intend to appear at the fairness hearing, you must file with the Court and send
to all counsel listed below a notice of intention to appear at the hearing by the objection
deadline. The notice must include copies of any papers, exhibits, or other evidence that you
or your counsel will present to the Court. If you do not provide a timely notice of intention
to appear, or if you do not file a timely objection, you may be deemed to have waived any
objection to the settlement.
Clerk of the Court

Clerk of the Court
Martin Luther King U.S.
Courthouse
50 Walnut Street, Rm. 4015
Newark, NJ 07101

Class Counsel

Matthew D. Schelkopf
Chimicles & Tikellis LLP
One Haverford Centre
361 West Lancaster Avenue
Haverford, PA 19041

Honda's Counsel

Eric S. Mattson
Michael C. Andolina
Sidley Austin LLP
One South Dearborn
Chicago, IL 60603

12. WHAT SHOULD I DO IF I DO NOT WANT TO PARTICIPATE IN THE
SETTLEMENT?
To exclude yourself from the settlement, you must submit a written request for
exclusion that includes (a) your name, address, and phone number; and (b) the approximate
date of acquisition and vehicle identification number (VIN) of your CR-V. All requests for
exclusion must also contain a signed statement that: “I request that I be excluded from the
proposed settlement in Davitt v. American Honda Motor Co., Inc.” All requests for
exclusion must be postmarked no later than March 20, 2015, and must be mailed to the
Settlement Administrator:
Settlement Administrator
P.O. Box 2722
Torrance, CA 90509

DO NOT REQUEST EXCLUSION IF YOU WANT TO PARTICIPATE IN THE
SETTLEMENT.
If you validly request exclusion from the class, you will still be able to receive the
drivers door lock actuator replacement described above, and you may be able to sue based
on the issues raised in the lawsuit. You will not be entitled to any of the other settlement
-7QUESTIONS? CALL 1-888-888-3082 TOLL FREE, OR VISIT WWW. DOORLOCKSETTLEMENT.COM

benefits, will not be bound by any judgment entered in the lawsuit, and will not be permitted
to object to the settlement.
If you do not request exclusion from the class, you will be bound by all judgments
in the lawsuit in connection with the settlement.

13. WHAT IS THE DIFFERENCE BETWEEN OBJECTING TO THE
SETTLEMENT AND EXCLUDING MYSELF FROM THE SETTLEMENT?
Objecting simply tells the Court that you do not like something about the settlement.
You can object and still participate in the settlement, including by filing a claim for benefits.
In contrast, excluding yourself is telling the Court that you do not want to be part of the
settlement. If you exclude yourself, you have no basis to object because the lawsuit no
longer affects you.

14. WHO REPRESENTS THE CLASS?
The Court has appointed Kevin Davitt, Scott Carter, and Mark Tudyk as class
representatives. They will ask the Court for awards not to exceed $1,500 each. Honda has
agreed to pay up to this amount if approved by the Court, and your settlement benefits will
not be reduced by the payment of this award.
The Court has also appointed the following lawyers and their firms as class counsel:
Joseph G. Sauder
Matthew D. Schelkopf
CHIMICLES & TIKELLIS LLP
One Haverford Centre
361 West Lancaster Avenue
Haverford, PA 19041

Jonathan W. Cuneo
William H. Anderson
CUNEO GILBERT & LADUCA, LLP
507 C Street, NE
Washington, DC 20002

These lawyers represent your interest in the lawsuit. You will not be charged for their
services. You may hire your own attorney at your own expense to advise you, but you are
not required to do so.

-8QUESTIONS? CALL 1-888-888-3082 TOLL FREE, OR VISIT WWW. DOORLOCKSETTLEMENT.COM

15. WHO IS RESPONSIBLE FOR CLASS COUNSELS FEES?
Class counsel intends to ask the Court for an award of attorneys fees for their work
on behalf of the settlement class, including their out-of-pocket expenses, in an amount not to
exceed $1,400,000. Honda has agreed to pay up to this amount. You will not have to pay

any of this amount.
16. WHEN WILL I RECEIVE MY SETTLEMENT BENEFITS?
You can now make an appointment with an authorized Honda dealer to get your free
replacement of the drivers door lock actuator. With respect to the other benefits, the Court
is scheduled to hold a final approval hearing on May 7, 2015, to decide whether to approve
the settlement. If the Court approves the settlement, the payment of benefits to class
members who submit valid claims will be made approximately 60 days from the deadline for
filing claims. If appeals are filed, payment of claims will be delayed.

17. DO I HAVE TO ATTEND THE FINAL APPROVAL HEARING?
No.

18. WHERE CAN I GET MORE INFORMATION?
This Notice is only a summary of the lawsuit and proposed settlement. Other
information (including the Settlement Agreement) that has been filed in this lawsuit is
available at www.DoorLockSettlement.com. If you have any questions about the settlement,
check the website, contact Honda at 1-888-888-3082, or contact one of the Class Counsel
listed in section 14, above. DO NOT CONTACT THE COURT FOR INFORMATION.
BY THE COURT:
Honorable Faith S. Hochberg
U.S. District Judge

-9QUESTIONS? CALL 1-888-888-3082 TOLL FREE, OR VISIT WWW. DOORLOCKSETTLEMENT.COM

American Honda Motor Co., Inc.

CLAIM FORM FOR POWER DOOR LOCKS
2007 AND 2008 HONDA CR-Vs and CERTAIN 2009 HONDA CR-Vs
Name/Address Changes (if any):
First Name

Last Name

Address
City

State

Zip

Claim #: NNS2- 6000068380

Please provide the information below for all claims so we can contact you if necessary
or notify you of status:
Daytime Phone
Cell Phone

Evening Phone
E-mail

Claim Form Instructions:

Your Claim Form must be sent to Honda at the address on page 2 of this form and
postmarked no later than July 6, 2015.
1. All Settlement Class Members are entitled to a free replacement of the front driver's-side
door lock actuator (even if the door lock is working), as long as the actuator has not
already been replaced with the appropriate part. To receive a replacement, please bring
your CR-V to an Authorized Honda Dealer. Please see the enclosed Notice or visit
DoorLockSettlement.com for additional details.
2. Settlement Class Members who previously paid for Door Lock Actuator Repairs (this
includes the front and rear passenger and driver doors and excludes the hatch door) may
submit a claim for reimbursement. Honda will reimburse eligible Out-of-Pocket Expenses
for parts and labor paid for Door Lock Actuator Repairs to those doors. To be eligible for
reimbursement, you must provide original Proof of Payment (or a duplicate receipt
stamped as “Paid”) and submit a valid Claim Form no later than July 6, 2015.
3. If a door lock actuator on your CR-V malfunctions, you may be eligible to receive Door
Lock Actuator Repairs under an extended warranty without charge at an Authorized
Honda Dealer. Please see the enclosed Notice or visit DoorLockSettlement.com for
details. If you think you are eligible for Door Lock Actuator Repairs, please contact your
Authorized Honda Dealer. You do not need to complete a Claim Form unless you are
seeking reimbursement for past door lock actuator repairs on your CR-V.
Page 1 of 3

1. Have you ever owned or leased a 2007 or 2008 Honda CR-V?
£ No
£ Yes Year
Vehicle Identification Number:
2. Have you ever owned or leased a 2009 Honda CR-V with a Vehicle Identification Number in the
following ranges: JHLxxxxxxxx000001–JHLxxxxxxxx007343;
5J6xxxxxxxx000001–5J6xxxxxxxx003420; 3CZxxxxxxxx700001–3CZxxxxxxxx701680;
JHLxxxxxxxx000001–JHLxxxxxxxx007327; 5J6xxxxxxxx000001–5J6xxxxxxxx007526; or
3CZxxxxxxxx700001–3CZxxxxxxxx700240?
£ No
£ Yes
Vehicle Identification Number:

If you answered "Yes" to EITHER question 1 or 2, and you paid to fix one or more door lock
actuators on your CR-V, you are eligible to submit a claim for reimbursement. If you
answered "NO" to BOTH questions 1 and 2, you are not eligible to submit a claim for
reimbursement.
Return this claim form to:
Settlement Administrator
P.O. Box 2718
Torrance, CA 90509

When you submit this Claim Form, include an original receipt (or other original supporting

documentation such as a duplicate receipt stamped as “Paid”) for Door Lock Actuator Repairs.
Your documentation must include all items below:
· The date the repairs were made and vehicle mileage at the time of the repairs; and
· The amount you paid for the Door Lock Actuator Repairs; and

Keep a copy of your documents for your records. Documents will NOT be returned.
DATE OF AND MILEAGE AT REPLACEMENT #1

AMOUNT YOU PAID FOR
THE REPLACEMENT

//
Mileage:

$.
Page 2 of 3

DATE OF AND MILEAGE AT REPLACEMENT #2
(if applicable)

AMOUNT YOU PAID FOR
THE REPLACEMENT

//
Mileage:

$.

DATE OF AND MILEAGE AT REPLACEMENT #3
(if applicable)

AMOUNT YOU PAID FOR
THE REPLACEMENT

//
Mileage:

$.

DATE OF AND MILEAGE AT REPLACEMENT #4
(if applicable)

AMOUNT YOU PAID FOR
THE REPLACEMENT

//
Mileage:

$.

I declare under penalty of perjury that the information I provided on this form is accurate.
//

Signature of Owner/Lessee

Date

Signature of Co-Owner/Co-Lessee (if any)

//

Date

For help completing this form or for answers to your questions, call Honda at 1-888-888-3082
or go to www.DoorLockSettlement.com.

Page 3 of 3