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NHTSA ID Number: 10199287

Manufacturer Communication Number: B011321

TSB/Document Date: 2021-07-19


Summary

CLASS ACTION SETTLEMENT: N54/N54T/N55 ELECTRIC ENGINE COOLANT PUMP . With the court's FINAL approval, BMWeBay logo of North America, LLC (BMWeBay logo NA) has entered a nationwide settlement with the plaintiffs in the following class action: Oliver, et al v. BMWeBay logo NA, et al


Sample

*7078*

*CF*

*RUST*

This form must be submitted or postmarked on or within 30 days of the Effective Date, currently estimated to be no earlier than
March 20, 2021. Please see the settlement website to find out if the Effective Date has changed.

CLAIM FORM TO RECEIVE REIMBURSEMENT FOR ELIGIBLE PAST EXPENSES IN
OLIVER v. BMWeBay logo OF NORTH AMERICA, LLC
Complete this form only if you wish to make a claim for reimbursement
for eligible past expenses available under the Settlement.
PLEASE TYPE OR PRINT LEGIBLY
You must supply all of the following information in order to obtain reimbursement
for eligible past expenses under this Settlement.
Name:
Address:
City:

State:

Zip:

Email address:
BMWeBay logo Model Year: 20

Model:

(example: 335i)

Vehicle Identification Number:
(The VIN is 17 characters and can be found on the metal plate at the bottom of the driver’s side front windshield or on your
sale or title documents.)
Date of Purchase/Lease:

/

/
CLAIMANT DECLARATION

I declare under penalty of perjury that the information above and the documents I have supplied are true and correct.
Signed On:

/
(DD/MM/YYYY)

/

in

,
(City)

(State)
(Sign your name here)

(Type or print your name here)

(Capacity of person signing - if applicable)

YOU MAY BE ELIGIBLE FOR REIMBURSEMENT FOR UP TO $1,000.00 FOR COSTS (PARTS AND LABOR) OF REPLACEMENT
OF ONE FAILED ELECTRIC ENGINE COOLANT PUMP AND, IF ALSO DAMAGED , ONE FAILED ELECTRIC ENGINE COOLANT
THERMOSTAT.
PLEASE COMPLETE THIS CLAIM FORM ONLY IF YOU ARE SEEKING REIMBURSEMENT BENEFITS.
PLEASE SEE QUESTIONS 6 THROUGH 8 ON THE NOTICE FORM FOR MORE INFORMATION AND LIMITATIONS.
Page 2 of 2

CLAIMS FOR REIMBURSEMENT FOR PAST EXPENSES
To obtain reimbursement for up to $1,000.00 in total for the replacement cost of one (1) failed electric engine coolant pump and,
if also damaged, one (1) failed engine coolant thermostat you must submit documents showing:
a.

That the replacement was made at an authorized BMWeBay logo dealer (e.g., a BMWeBay logo Center), or at a third-party repair shop; and

b. Your Settlement Class Vehicle’s model, model year, and VIN; and
c.

The identity of the owner/lessee of the Settlement Class Vehicle; and

d. That your Settlement Class Vehicle had fewer than 7 years and 84,000 miles at the time of the replacement of the
electric engine coolant pump, as evidenced by required proofs, such as a repair order with vehicle mileage at the time of
replacement or service records from before and after the replacement; and
e.

The cost of repair, with parts and labor separated; and

f.

Proof of payment for the amount(s) sought for reimbursement (credit card receipt, credit card statement, or cancelled
check); and

g.

The nature of the repair; and

h. The part(s) description and part number(s) used in the repair; and
i.

The date of repair.
COMPLETED CLAIMS FORMS CAN BE SUBMITTED BY MAIL OR ONLINE.

IF YOU ARE SUBMITTING BY MAIL, COMPLETE THIS CLAIM FORM AND MAIL IT, POSTMARKED ON OR BEFORE the later of 30
days after the date of Final Approval of the Settlement or the Effective Date of the Settlement, to be posted on the Settlement
Website but estimated to be March 20, 2021 TO:
Oliver Claims Administrator
c/o Rust Consulting - 7078
PO Box 13
Minneapolis, MN 55440-0013
IF YOU ARE SUBMITTING ONLINE, COMPLETE AND SUBMIT THE CLAIM FORM AVAILABLE AT www.ElectricCoolantPumpSettlement.com
ON OR BEFORE the later of 30 days after the date of Final Approval of the Settlement or the Effective Date of the Settlement, to be
posted on the Settlement Website but estimated to be March 20, 2021.

QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT www.ElectricCoolantPumpSettlement.com

United States District Court for the District of New Jersey

If you are a current or former owner or lessee of a model-year 2007 to 2019 BMWeBay logo vehicles,
you could get benefits from a class-action settlement.


A federal court has authorized this notice. This is not a solicitation from a lawyer.

A nationwide settlement has been reached in a class action lawsuit against BMWeBay logo of North America, LLC, captioned
Oliver, et al v. Bayerische Motoren Werke Aktiengesellschaft, et al., Civil Action No. 2:17-cv-12979, involving the electric
engine coolant pump in certain model-year 2007 to 2019 BMWeBay logo vehicles.

The Settlement provides an opportunity to be reimbursed for certain past expenses.

Your legal rights are affected whether you act or don’t act, so please read this notice carefully.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:
SUBMIT A CLAIM FORM Make a claim to receive reimbursement for Claims must be submitted by the later
eligible past expenses potentially available to of thirty (30) days after the date of
you under the Settlement.
Final Approval of the Settlement or
the Effective Date of the Settlement,
to be posted on the Settlement Website
but estimated to be on or about March
20, 2021. See Question 8, below.
EXCLUDE YOURSELF
Write to Settlement Class Counsel and Requests for Exclusion must be
Defendant’s Counsel to exclude yourself from postmarked by January 8, 2021. See
(“opt out” of ) the Settlement. This is the only Question 12, below.
option that allows you to be part of any other
lawsuit, or your own lawsuit, against BMWeBay logo of
North America about the legal claims released
in this Settlement.
OBJECT
Write to the judge about why you do not like Objections must be postmarked by
the Settlement.
January 8, 2021. See Question 17, below.
GO TO A HEARING
Ask to speak in court to the judge about the The Final Approval Hearing is
Settlement.
currently scheduled for February 18,
2021 at 10:00 a.m. See Questions 19 to
21, below.
DO NOTHING
Give up the benefits to which you may be See Question 22, below.
entitled under the Settlement and your right to
be part of any other lawsuit against BMWeBay logo of
North America about the legal claims released
by the Settlement (but not your right to future
repairs under the extended warranty explained
below).
These rights and options -- and the deadlines to exercise them -- are explained in this notice.

The Court in charge of this case still must decide whether to approve the Settlement before any benefits can be
distributed. Please be patient and check the settlement website for updates.

QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-1-

WHAT THIS NOTICE CONTAINS

BASIC INFORMATION

1. Why have I received this notice?
2. What is the lawsuit about?
3. Why is this a class action?
4. Why is there a Settlement?

PAGE 2-3

WHO IS IN THE SETTLEMENT

PAGE 3

THE BENEFITS: WHAT YOU GET

PAGE 4-5

HOW TO GET BENEFITS

PAGE 5

EXCLUDING YOURSELF FROM THE SETTLEMENT

PAGE 5-6

THE LAWYERS REPRESENTING YOU

PAGE 6

OBJECTING TO THE SETTLEMENT

PAGE 6-7

THE COURT’S FINAL APPROVAL HEARING

PAGE 7

WHAT IF I DO NOTHING?

PAGE 7

GETTING MORE INFORMATION

PAGE 7

5. How do I know if I am part of the Settlement? What vehicles are included in the Settlement?

6. What are the benefits of the Settlement?
7. What am I giving up in exchange for the Settlement benefits?
8. How do I get the benefits of the Settlement?
9. What if my claim for benefits is denied?
10. When will I get the benefits?

11. Can I exclude myself from this Settlement?
12. If I exclude myself, can I get anything from this Settlement?
13. If I don’t exclude myself, can I sue later?
14. How do I exclude myself from the Settlement?
15. Do I have a lawyer in the case?
16. How will the lawyers be paid?

17. How do I tell the Court if I don’t like the Settlement?
18. What’s the difference between objecting and excluding?

19. When and where will the Court decide whether to approve the Settlement?
20. Do I need to go to the hearing?
21. May I speak at the hearing?
22. What happens if I do nothing?

23. Can I get more details about the Settlement?

1. Why have I received this notice?

A Court has authorized this notice because you have a right to know about the proposed settlement of this class-action
lawsuit, and your options, before the Court decides whether to give “final approval” to the Settlement. This notice explains
the lawsuit, the proposed Settlement, and your legal rights. You have received this notice because BMWeBay logo of North America’s
records indicate that you are a current or former owner or lessee of one or more of the following vehicles purchased or leased
in the United States, including the District of Columbia and Puerto Rico (“Class Vehicles”):

QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-2-

Model Years
2008-2013
2007-2013
2008-2016
2012-2017
2010-2015
2012-2015
2011-2017
2015-2018
2007-2013
2008-2019
2009-2016

Models
135i
335i, 335i xDrive, 335is Convertible
535i, 535i xDrive, 535i Active HybrideBay logo
640i, 640i xDrive
740i, 740Li
X1 3.0si
X3 xDrive
X4 xDrive, X4 M40i
X5 3.0si, X5 xDrive30i , X5 xDrive
X6 sDrive, X6 xDrive
Z4 sDrive

Magistrate Judge Mark Falk of the United States District Court for the District of New Jersey is overseeing this class-action
lawsuit, captioned Oliver v. Bayerische Motoren Werke Aktiengesellschaft and BMWeBay logo of North America, LLC, Civil Action No.
2:17-cv-12979 (the “Action”). Shelton Oliver, Donnie Baker, and Khader Mohiuddin, the people who sued, are called the
“Plaintiffs,” and the company that was sued, BMWeBay logo of North America, LLC, is called the “Defendant.”
2. What is the lawsuit about?

This lawsuit alleges that the Class Vehicles’ electric engine coolant pump is defective, which could lead to sudden engine
failure and loss of power to the vehicles. BMWeBay logo of North America, which distributes and warrants BMWeBay logo vehicles in the
U.S., denies these allegations and stands behind and supports its products.
3. Why is this a class action?

In a class action, one or more people called “Class Representatives” assert claims on behalf of people who have similar claims.
All of these people are the “Class” or “Class Members.” One court resolves the issues for all Class Members, except for those
who timely exclude themselves from (“opt out” of ) the Class. The Class Representatives in the Action are the Plaintiffs
identified above. You have received this notice because you have been identified as potentially being a Class Member.
4. Why is there a Settlement?

All parties have agreed to a Settlement to avoid further cost and risk of a trial, and so that the people affected can begin
getting benefits in exchange for releasing the Defendant from liability for the claims that were raised or could have been
raised in the Action involving the Class Vehicles’ alleged issues with the electric engine coolant pump. The Settlement
does not mean that BMWeBay logo of North America broke any laws, or otherwise did anything wrong, because Judge Falk did not
decide which side was right. The Class Representatives and the lawyers representing them think the Settlement is fair and
reasonable for the Class.
5. How do I know if I am part of the Settlement? What vehicles are included in the Settlement?

The Settlement Class includes all persons or entities in the United States, including the District of Columbia and Puerto
Rico, who currently own or lease, or previously owned or leased, certain U.S.-specification model-year 2007-2019 BMWeBay logo
vehicles purchased or leased, and registered and operated, in the United States, including the District of Columbia and
Puerto Rico, which include the following vehicles:

QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-3-

Model Years
2008-2013
2007-2013
2008-2016
2012-2017
2010-2015
2012-2015
2011-2017
2015-2018
2007-2013
2008-2019
2009-2016

Models
135i
335i, 335i xDrive, 335is Convertible
535i, 535i xDrive, 535i Active HybrideBay logo
640i, 640i xDrive
740i, 740Li
X1 3.0si
X3 xDrive
X4 xDrive, X4 M40i
X5 3.0si, X5 xDrive30i , X5 xDrive
X6 sDrive, X6 xDrive
Z4 sDrive

Please note that not all vehicles in the model years identified above contained the electric engine coolant pump at issue in the Action.
You have received this notice because BMWeBay logo of North America’s records indicate that you have or had a BMWeBay logo vehicle with the electric
engine coolant pump at issue in the Action.
6. What are the benefits of the Settlement?

If Judge Falk grants final approval of the Settlement and the Settlement becomes effective (the “Effective Date”), you may
be eligible for reimbursement of up to $1,000 in total in costs for replacement of one (1) failed electric engine coolant pump
and, if also damaged, one (1) engine coolant thermostat, per VIN, per owner/lessee if the replacement occurred prior to the
earlier of the first 7 years or 84,000 miles of the Class Vehicle’s in-service date. If you are unsure of your Vehicle’s in-service date,
please check with your local BMWeBay logo Center, which can look up the date based on your Vehicle Identification Number (VIN).
Additionally, the limited warranty period for the electric engine coolant pump in all Class Vehicles will be extended from the
4-year/50,000-mile New Passenger Vehicle Limited Warranty period to 7 years/84,000 miles, whichever comes first. If your
original electric engine coolant pump or a BMWeBay logo-approved replacement electric engine coolant pump installed at a BMWeBay logo
Center fails during this extended-warranty period, it will be replaced under this limited warranty extension, subject to the
terms and conditions of BMWeBay logo of North America’s New Passenger Vehicle Limited Warranty.
Finally, if your original electric engine coolant pump, or a BMWeBay logo-approved replacement electric engine coolant pump
installed at a BMWeBay logo Center, fails within one (1) year from the Effective Date (regardless of vehicle age or mileage), it will
be replaced in accordance with the Settlement, subject to the terms and conditions of BMWeBay logo of North America’s New
Passenger Vehicle Limited Warranty.
* * *
Limitations: BMWeBay logo of North America does not warrant or guarantee any repairs performed at third-party (non-BMWeBay logo
Center) repair shops and, should any such repairs fail after a Settlement Class Member has made a reimbursement claim
under the Settlement, the Settlement Class Member will not be entitled to submit an additional claim or seek replacement
under the extended warranty. BMWeBay logo of North America does not warrant replacement parts that were not certified by the
original equipment manufacturer. The limited warranty extension will not apply to vehicles whose owners or lessees opt out of
the Settlement, vehicles declared a total loss, sold for salvage purposes, or branded with a “salvage” title. There are additional
limitations and exclusions from coverage set forth in BMWeBay logo of North America’s New Passenger Vehicle Limited Warranty and
in Section III of the Settlement Agreement, which can be viewed at www.ElectricCoolantPumpSettlement.com.
In order to obtain reimbursement for eligible past out-of-pocket expenses, you must submit a Claim Form and include all
of the documentation described above and identified on the Claim Form.
7. What am I giving up in exchange for the Settlement benefits?

If the Settlement becomes final, Class Members will be releasing Defendant and related people and entities from all
of the claims described and identified in Section VII.A of the Settlement Agreement. In essence, Class Members are
releasing all claims (except for personal injury or damage to property other than the Class Vehicle) that could arise based
on alleged defect in the electric engine coolant pump in the Class Vehicles. The Settlement Agreement is available at www.
ElectricCoolantPumpSettlement.com. The Settlement Agreement describes the released claims with specific descriptions,
in necessarily precise legal terminology, so read it carefully.
QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-4-

Judge Falk has approved specific lawyers to represent you in this lawsuit and Settlement. You can talk to one of the lawyers
listed in Question 15 below, free of charge, if you have questions about the released claims or what they mean. You can also
speak with your own lawyer, should you have one, about this Settlement.
8. How do I get the benefits of the Settlement?

If you are a Class Member and would like to obtain the reimbursement benefits (described in Question 6 above), you need to
complete the Claim Form that accompanies this Notice and mail it, with all the required proofs, to the address provided on
the Claim Form or file the Claim Form online through the Settlement website portal. Additional Claim Forms are available
at www.ElectricCoolantPumpSettlement.com. The current deadline for submitting your Claim Form is March 20, 2021.
These benefits are also subject to limitations, which are discussed in Question 6 and in the Settlement Agreement.

If you have any questions on how to complete the Claim Form or what information is needed, you can call the toll-free
number at the bottom of this notice.
9. What if my claim for benefits is denied?

There is a process in the Settlement Agreement to resolve disagreements between you and Defendant over your claim. During
this process, the court-appointed lawyers listed in Question 15 below will represent you in any dispute regarding relief under
the terms of the Settlement, and the dispute will be handled in accordance with the procedures set forth in Section III.B. of
the Settlement Agreement. If you have questions regarding this process, visit www.ElectricCoolantPumpSettlement.com
to see a copy of the Settlement Agreement, or contact Class Counsel below.
10. When will I get the Settlement benefits?

If you have submitted a claim, your Claim Form will be processed and payments will be issued on a continuing, rolling basis
after the Effective Date, which will be after the Court’s Final Approval hearing, scheduled for February 18, 2021, and all
appeals, if any, are resolved.
Please be patient, and feel free to check the website for current status.

11. Can I exclude myself from this Settlement?

Yes. If you want to keep the right to sue or if you are already suing Defendant in another action over the legal issues in this
case, then you must take steps to do so. This is called asking to be excluded from – sometimes called “opting out” of – the
Settlement.
12. If I exclude myself, can I get anything from this Settlement?

No. If you ask to be excluded, you will not receive any of the reimbursement benefits of the Settlement or the warranty
extension and you cannot object to the Settlement. But you may sue, continue to sue, or be part of a different lawsuit against
Defendant in the future, including for claims that this Settlement resolves. You will not be bound by anything that happens
in this lawsuit.
13. If I don’t exclude myself, can I sue later?

No. Unless you exclude yourself, you give up the right to sue Defendant for the claims that this Settlement resolves.
14. How do I exclude myself from the Settlement?

To exclude yourself from the Settlement, you must send a letter by mail to the Claims Administrator saying that you want to
be excluded from Oliver v. Bayerische Motoren Werke Aktiengesellschaft, Civil Action No. 2:17-cv-12979. Be sure to include:
(1) your full name and current address; (2) the model-year, model, and VIN of your Class Vehicle(s) and the date(s) of
purchase/lease; (3) specifically and clearly state your desire to be excluded from the Settlement and from the Settlement
Class; and (4) your signature. You cannot ask to be excluded over the phone or via the internet. You must mail your request
to be excluded, postmarked no later than January 8, 2021, to Claims Administrator at the address listed in Question 17.

Failure to comply with any of these requirements for excluding yourself will result in you being bound by this Settlement.

QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-5-

15. Do I have a lawyer in the case?

The Plaintiffs and you have been represented by the law firm Kantrowitz Goldhamer & Graifman, P.C. and Thomas P.
Sobran, Esq. Judge Falk has approved as “Class Counsel” the following lawyers to represent you and other Class Members:
Gary S. Graifman, Esq.
KANTROWITZ, GOLDHAMER & GRAIFMAN, P.C.
210 Summit Avenue
Montvale, New Jersey 07645
Thomas P. Sobran, Esq.
7 Evergreen Lane
Hingham, MA 02043

You will not be charged for these lawyers. If you want to be represented by another lawyer, you may hire one to appear in
Court for you at your own expense.
16. How will the lawyers be paid?

As part of the resolution of the Action, Class Counsel and Defendant have agreed that Class Counsel may apply for an
award of attorneys’ fees, costs, expenses, and service payments for the three Class Representatives not to exceed a total of
$900,000.00. Defendant has agreed not to oppose this request. The Parties have agreed that Class Counsel will not seek
payment of any amount in excess of $900,000.00 in the aggregate. The Parties have also agreed that Class Counsel may
ask Judge Falk to award service payments to the three Class Representatives in the amount of $1,000 each ($3,000 in
total), which will be included in the $900,000 payment. The Class Counsel fees, expenses, and Class Representative service
payments, will be paid separate and apart from any relief provided to the Class and will not reduce the value of the benefits
distributed to Class Members. Defendant will also separately pay the costs to administer the Settlement. Judge Falk will
determine the amount of attorneys’ fees, costs, expenses, and service payments after evaluating Plaintiffs’ submission.
17. How do I tell the Court if I don’t like the Settlement?

If you don’t like some part of the Settlement, you can object to it. You can give reasons why you think Judge Falk should not
approve it. To object, you must send a letter to the Clerk of the Court saying that you object to the Settlement in Oliver v.
Bayerische Motoren Werke Aktiengesellschaft, Civil Action No. 2:17-cv-12979. You must include: (1) your full name, current
address, current telephone number, and the name of your lawyer and your lawyer’s address if you are represented by a lawyer
other than Class Counsel; (2) the model year, model, and VIN of your Class Vehicle(s) and the date(s) of purchase or lease;
(3) whether the objection applies only to you, to a specific subset of the Class, or to the entire Class; (4) the reasons why you
object and the factual and legal reasons for your objection (including all relevant documents that pertain to your objection);
(5) copies of relevant repair history or other proof that you have owned or leased the Class Vehicle (i.e., a true copy of a
vehicle title, registration, or license receipt); (6) a statement that you have reviewed the Settlement Class definition and
understand that you are a Settlement Class Member, and you have not opted out of the Settlement Class; (7) a detailed list
of any other objections to any class action settlements you have submitted in the previous five (5) years to any court, whether
state, federal, or otherwise, in the United States; (8) a Notice of Intention to Appear at the Final Approval Hearing, if you
intend to appear in person at the hearing; and (9) your signature. The objection must be mailed to the Court, the Claims
Administrator, Class Counsel, and Defendant’s Counsel at the addresses below. The mailed copies must be postmarked
on or before January 8, 2021:
COURT

CLAIMS
ADMINISTRATOR

Clerk of Court
United States District Court for the District of New Jersey
Rev. Dr. Martin Luther King, Jr. Federal Building & U.S. Courthouse
50 Walnut Street
Newark, New Jersey 07102
Oliver Claims Administrator
c/o Rust Consulting - 7078
PO Box 13
Minneapolis, MN 55440-0013

QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-6-

CLASS COUNSEL

Gary S. Graifman, Esq.
KANTROWITZ, GOLDHAMER & GRAIFMAN, P.C.
210 Summit Avenue
Montvale, New Jersey 07645

DEFENDANT’S COUNSEL

Thomas P. Sobran, Esq.
7 Evergreen Lane
Hingham, MA 02043
Christopher J. Dalton, Esq.
Argia J. DiMarco, Esq.
Buchanan Ingersoll & Rooney PC
550 Broad Street, Suite 810
Newark, New Jersey 07102-4582

18. What’s the difference between objecting and excluding?

Objecting is simply telling Judge Falk that you don’t like something about the Settlement. You can object only if you stay
in the Settlement. Excluding yourself is telling Judge Falk that you don’t want to be part of the Settlement. If you exclude
yourself, you have no basis to object because the Settlement no longer affects you.
19. When and where will Judge Falk decide whether to approve the Settlement?

Judge Falk will hold a “Final Approval Hearing” to decide whether to approve the Settlement on February 18, 2021 at 10:00
a.m., at the United States District Court for the District of New Jersey, Rev. Dr. Martin Luther King, Jr. Federal Building
& U.S. Courthouse, 50 Walnut Street, Newark, New Jersey 07102. At this hearing, Judge Falk will determine whether the
Settlement is fair, adequate, and reasonable and whether the objections by Class Members, if any, have merit. If you have
filed an objection on time, you may attend and ask to speak, but you don’t have to. However, Judge Falk will only listen to
people who have asked to speak at the hearing (see Question 21 below). At this hearing, Judge Falk will also decide the
service payments for the Class Representatives, as well as the attorney’s fees for the lawyers representing the Class Members.
We do not know how long the Court’s decision will take, and the hearing date may change due to other court business. You
should monitor www.ElectricCoolantPumpSettlement.com to find out if any dates have changed and to learn if Judge Falk
has approved the Settlement.
20. Do I need to go to the hearing?

No. Class Counsel will answer any questions Judge Falk may have, but you are welcome to come at your own expense. If
you send an objection, you don’t have to come to Court to talk about it. As long as you mail your valid written objection on
time, Judge Falk will consider it. You may also pay another lawyer to attend, but it’s not required.
21. May I speak at the hearing?

You may ask Judge Falk for permission to speak at the Final Approval Hearing. To do so, you must file a “Notice of Intent
to Appear” in Oliver v. Bayerische Motoren Werke Aktiengesellschaft, Civil Action No. 2:17-cv-12979. Be sure to include your
name, address, telephone number, signature, and other requirements outlined in Question 17. Your Notice of Intent to
Appear must be postmarked no later than January 8, 2021, and mailed to the addresses listed in Question 17. You cannot
speak at the hearing if you have excluded yourself from the Settlement.
22. What if I do nothing?

If you do nothing, you will give up the right to be part of any other lawsuit against Defendant about the legal claims released
by the Settlement. You will not receive any of the reimbursement benefits described in Question 6 offered by this Settlement
unless you timely submit a Claim Form. Your vehicle will, however, still get the benefit of the extended warranty, if applicable.
23. Can I get more details about the Settlement?

This notice summarizes the proposed Settlement. More details are in the Settlement Agreement. You can review the
Settlement Agreement and related documents at www.ElectricCoolantPumpSettlement.com.

QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-7-

12

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TSB/Document ID: B011321

Replacement Service Bulletin Number:

MFR Communication Date: 2021-05-01

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iCarsoft Bidirectional Scan Tool, CR Max OBD2 Diagnostic Scanner for All Vehicles, Full System 49 Resets+46 Extra Services, 40000+Active Tests,ECU Coding, Battery Registration, Oil Reset/ABS,CAN FD
  • WHY CHOOSE THE 2025 CR MAX -Upgrade the latest diagnostic capabilities for all vehicles after 1996: upgrade to 49+maintenance services; 46 extra specific functions; real all systems/all control modules diagnose; over 40K+ bidirectional actuation tests for diagnosing all control moduels of cars; Powerful full OBD2 Functions; built-in ECU Coding for BMWeBay logo/ AudieBay logo/ VWeBay logo/ RollsRoyce; Fr ee V.A.G Guide Function; Battery retistration for new battery adaptation and more. It covers all vehicle diagnostic services and some special professional vehicle maintenance servces, assists you to do home DIY vehicle maintenance or car repair as a pro technician.
  • NEWEST IN INNOVATION FULL OBD2 SERVICES- iCarsoft auto car diagnostic scanner compatible with CAN-FD, CR MAX can do it all-reads and clears trouble codes, ALL SYSTEM DIAGNOSIS such as engine, transmission, ABS and airbag etc. CR MAX code reader for all cars can perform I/M Readiness, Live Data, Freeze Frame, Vehicle Information, Monitor Test, On-Board Monitor, E vap System Test,O2 Sensor Test,DTC Library Lookup,etc. (Warm Tips: If you car is after 2023,please contact us for compatibility; 3. It comes with 16PIN OBD2 diagnostic adapter, please check your car diagnostic socket if it is 16pin socket, if your car is 14pin diagnostic socket please contact us for the solution.)
  • 49 RESET+ 46 SERVICES- Performs: Oil Reset, EPB,SAS,Throttle, D-P - F, Battery, ABS, Injector, TPMS, Suspension, AC, Head Lamp, Body Stablity, Engine, Tramsmission, Airbag, Seat, Door-Win-Roof, Fuel Pump, Door, E-G- R.+21 NEWEST SERVICES( Need update scanner)-AdBlue, Clutch, Crankshaft, High Voltage BatteryeBay logo, Cruise Control, NO xSensor, Rain Sensor, Stop And Start, Turbocharger, Head Up Display, Radar Camera, Vehicle Setup, Cyliner Misfire Check,Speedlimitassist, ControlUnitReset,OxygenSensor, Seatbelt. Extra 46+ extra services based on car brand.(Tips: Quantity of reset/ calibration fucitons are based on car system that your vehicle model has)
  • REVOLUTIONARY 40000+BIDIRECTIONAL ACTIVE TESTS: Upgraded CR Max scanner equip with numberous of actuational test items for covering all available vehicle control modules, no longer only do simple light test or window test like other scanners, performs hardware modules test and software control modules test for checking car units or new updated control moduels work well or not after maintenance/ repair/ re-installation/ control system updated (Example for Benz- Roller Sun Blind test; Backup Camera test ;Self-test; EPB test; Transport Mode test;Boost Pressure Positioner test; Fuel Pump test; AND MORE!!).(Warm tip: The available test items are based on control modules your car has)
  • ECU CODING+ BATTERY REGISTRATION- Powerful ECU Coding service for BMWeBay logo/MINIeBay logo/RollsRoyce / AudieBay logo/VWeBay logo/Seat/Skoda/BentleyeBay logo/BugattieBay logo/LamborghinieBay logo, Improves Engine Power Performance and Optimizes Fuel Efficiency and Match New Hardware Unit to car and Customized a comfortable Driving Modes and Fixes & Updates Original Software Bug. The battery test function for checking car battery health, perform battery reset (BMS ) for replacing a damaged or aging car battery with a new one and register new battery to car ECU
SaleBestseller No. 2
iCarsoft E660 2026 Version 4 Systems OBD2 Scanner, ABS SRS Engine Transmission Car Code Reader with 6 Reset Service Clear Fault Codes Battery Test Diagnostic Scan Tools Lifetime Free Upgrade
  • 【Looking for More Professional Vehicle Scan Tool?】iCarsoft E660 2026 Upgrade Version OBD2 scan tool can do it all-reads and clears trouble codes on Engine system, ABS system, Transmission system and Airbag system, And with 6 reset function. It covers more than 59 vehicle makes from 1996-2023 models ( included most USA/ Asia / EU vehicle brand) with full OBDII. (As every car model has its-owned specific car system and ECUs, not all car models have full car ECUs which may prevent the scanner from performing all listed system diagnostics or reset services. Therefore, please email to us with car VIN and services required to do scanner's services for a compatibility check before purchasing.)
  • 【OE-Level 4 Systems OBD2 Scanner】iCarsoft E660 2026 Upgrade Version diagnostic scanner offers comprehensive OBDII services, allowing you to quickly scan Engine system. It supports functions such as reading and erasing codes, checking I/M readiness, viewing freeze frame data, performing O2 sensor tests, conducting on-board monitoring, testing the evap system, auto VIN retrieval, and reading both generic and specific codes, as well as DTCs and battery tests.
  • 【4 Systems Diagnosis for 10000+ Vehicles】 iCarsoft E660 2026 Upgrade Version adopts unique diagnostic software, works well for most PorscheeBay logo, Benz, BMWeBay logo, US FordeBay logo, Land RovereBay logo, JaguareBay logo, AudieBay logo, VWeBay logo, VolvoeBay logo, HondaeBay logo, NissaneBay logo, InfinitieBay logo, ToyotaeBay logo, LexuseBay logo, ScioneBay logo, IsuzueBay logo, HyundaieBay logo, KiaeBay logo, Daewoo, MazdaeBay logo, SprintereBay logo, MinieBay logo, Seat, Skoda, SAABeBay logo, EU FordeBay logo, Holden, AUS FordeBay logo, AcuraeBay logo, SubarueBay logo, MitsubishieBay logo, Dacia, Renault, FiateBay logo, GM, ChryslereBay logo, Citroen, Peugeot, Opel, Smart,SuzukieBay logo, Vauxhall, Alfa-Romeo, Lancia and etc.
  • 【6 Reset Services】iCarsoft E660 2026 Upgrade Version is a diagnostic tool that offers professional maintenance services, including Oil Reset, EPB, BMS, ETC, SAS, TPMS Reset. It can help you easily reset oil change indicators, recalibrate steering angle sensors, relearn replaced electric parking brake and so on. For optimal vehicle performance and maintenance convenience. (Tips: Please update the softwareafter receiving the product to obtain new service functions)
  • 【118+ Real Time Record & Live Graph View】iCarsoft E660 2026 Upgrade Version can automatically record vehicle text history and identify vehicle information. Preserve real-time data information. View & Graph Live Data. Support Data Review and Print. 15 languages: English, German, Dutch, Spanish, French and so on. We promise to offer Lifetime updates (Lifetime free Update via PC), and confidence in products. We also provide 1 year warranty + extra lifetime hardware free repair if you need it in the future. We prioritize user experience & strive to meet your expectations. Please do feel free to reach out to us if you have any question or problem about the usage.
Bestseller No. 3
iCarsoft POR V4.0 Bidirectional Diagnostic Tool for Porsche + 2 Extra Car Brands, OBD2 Scanner with 1333 Test Items/ 29 Services (177 Subservices)/ 66 Extra Services/Battery Registration-Free Update
  • 【All-in-One Diagnostic Tool for PorscheeBay logo + 2 Extra Vehicle Brands】New POR V4.0 is a professional car scanner specifically engineered with dedicated software pre-installed for PorscheeBay logo. You can also download 2 additional software packages FOR FREE from 26 supported brands (e.g., for Benz, for BMWeBay logo, for AudieBay logo, for Land RovereBay logo).Upgraded to adopt quad-core 1.3GHz processor and HD touchscreen and professional diagnsotic OS for faster& smooth diagnsotic.LIFETIME FREE UPDATES, NO SUBSCRIPTION COST! PLEASE TELL US YOUR CAR INFORMATION TO OBTAIN A LIST OF ALL COMPATIBLE SERVICES FOR YOUR CAR FIRST (FOR EXAMPLE: BATTERY REGISTRATION FUNCTION IS NOT COMPATIBLE WITH PORSCHEeBay logo 997.2)
  • 【29 MAINTENANCE SERVICES FOR PORSCHEeBay logo SERIES CARS】 It can perform the 29 reset service for PorscheeBay logo series cars-Oil Reset; SAS; EPB; BMS; ETC; DP ; ABS Bleeding; Injector Coding; TPMS; Air Suspension; Air Conditioner; Head Lamp; Body Stablity Control; Engine Control; Transmission; AirBag; Seat; DWR; MIS; EG; ODO; Clutch; High Voltage BatteryeBay logo; Cruise Control; Radar/Camera; Vehicle Setup,etc. Up to 49 vehicle-maintenance-services for the extra 2 vehicle brands you installed (Tip: Not all services will be worked on every car mode. Some vehicle models may be lack of certain ECU-control modules to make some services may not work).
  • UPGRADE SERVICES: Breaks down 29 services to 234 sub-service for car owners/machinist to perform maintenance based on corresponding sub-modules! The detailed sub-service for sub-modules assist to perform precise vehicle maintenance.Improving the accuracy of car maintenance and reducing potential failure risks caused by whole-module maintenance to main modules.such as Oil Reset is refined into Reset maintenance interval/Reset service interval/Service Reset; Engine Control Reset is refined into Delete adaptation data/Short tests/System tests/Swirl-flap actuator/Bleeding high temperature coolant circuit and more.(sub-services vary based on vehicle model/year)
  • 【EXTRA VEHICLE MAINTENANC SERVICES FOR SPECIFIC SYSTEMS】Have no ability to perferm calibration to special/specific systems/modules? This OBD2 scanner solve your troubles- for common systems/modules & for specific sytems/modules, assist you to perform diagnsing/calibration/reset/relearn services for non-common modules to finish your car maintenance/ diagnostic (eg: Central Computer system/module :Function activation/Multimedia interface test/AM Field Strength/Current FM Field Strength/FM Field Strength/MOST system reserve/Self-test/Deactivate Production Mode/Reset to factory settings/MOST System Test). (Tip: The services vary based on the vehicle brands)
  • 【 MORE PROFESSIONAL BI-DIRECTIONAL ACTUATION TESET 】Exclusive POR V4.0 comes with powerful bidirectional testing capability,do actuaction test for deeper unit-checking after replacement or overhaul (1333 test items for PorscheeBay logo, like:Fuel high-pressure fuel injector 1-4, Empty tank, Radiator fan, OTA-FC Connectivity, backrest, Backup battery, and more; 2136 test items for AudieBay logo; 1670 test items for Benz; 1599 test items for VolvoeBay logo; 1360 test items for VWeBay logo; 2705 test items for GM etc.). Help to check your car units work well or not after vehicle maintenance or daily car-body check, keep drives always in safety.(Warm tip:The quantity of test item is based on the units your car has)

Last update on 2026-06-23 / Affiliate links / Images from Amazon Product Advertising API


 


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