17. How
do
18. What’s the

I
tell
difference

PAGE 7-8

the
Court if
I
between
objecting

don’t
and

like
the
excluding?

Settlement?

THE COURT’S FINAL APPROVAL HEARING
19. When
20. Do
21. May

and
I
I

where will
need to
speak at

the
go
the

PAGE 8 - 9

Court decide whether to
to
the
hearing?
hearing?

approve the

Settlement?

WHAT IF I DO NOTHING?
9
22. What

happens

PAGE
if

I

do

nothing?

GETTING MORE INFORMATION
9
23. Can
A

I

get

more

PAGE
details about

the

Settlement?

Court has
authorized
this
notice because you
have a
right
the
proposed
settlement
of
this
class-action
lawsuit, and
the
Court decides whether to
give
“final approval”
to
the
This notice explains
the
lawsuit, the
proposed
Settlement,
rights.
You
have received
this
notice because BMW of
records indicate that
you
are
a
current or
former owner or
or
more of
the
following
vehicles
purchased
or
United States, including
the
District of
Columbia
and
Puerto
Vehicles”):
Model Description
Model Years
X1

SAV

2012-2015

X3

SAV

2013-2015

X4

SAV

2015

Z4

2012-2015

228i

Coupe, Convertible

2014-2015

320i

Sedan

2012-2015

328i

Sedan, Sports Wagon, Gran
Turismo
Coupe, Convertible,
Gran
Coupe
Sedan

2012-2015

428i
528i

to
know about
your options, before
Settlement.
and
your legal
North America’s
lessee of
one
leased in
the
Rico (“Class

2014-2015
2012-2015

*Model Years are not fully indicative of actual vehicles, which will depend on production ranges.
Judge Cathy L.
Waldor of
the
United States District Court for
Jersey is
overseeing
this
class-action
lawsuit, captioned
Bayerische Motoren Werke Aktiengesellschaft and BMW of North America, LLC, Civil
(the
“Action”).
Artem V.
Gelis, Bhawar Patel, Robert
Olson, Gregory
Heyman,
Susan Heyman,
Debra P.
Martinez,
Amanda
Gorey, Chris Williams,
Ashok Patel,
Gagnon,
Michael
Cerny, Maria Meza, Andre Malske, Nicole Guy,
Turner, and
Eric
T.
Zinn, the
people who
sued, are

the
District of
New
as
Gelis,
et
al.
v.
Action No.
2:17-cv-07386
McDonald,
James V.
Ward, Darrian Stovall, Alex
Kenneth
David Richardson,
Stacey
called the
“Plaintiffs,”

QUESTIONS? CALL TOLL-FREE (866) 411-6985 OR VISIT www.TimingChainModuleSettlement.com
3
-

and
the
called the
“Defendant.”

company

that

was

sued,

BMW of

North America,

LLC,

is

and
oil
pump
sudden engine failure
North America,
the
U.S., denies
products.

drive chain
and
loss
which
these

2. What is the lawsuit about?
This

lawsuit alleges
modules
of
power
distributes
allegations

that
are
to
and
and

the
Class Vehicles’
timing
defective
and
could lead
the
vehicles.
BMW
warrants
BMW vehicles
stands behind and
supports

chain
to
of
in
its

3. Why is this a class action?
In

a
class action, one
or
on
behalf of
people who
“Class” or
“Class Members.”
Class Members,
except for
of)
the
Class.
The
Plaintiffs
identified
above.
have been identified
as

more
have

people called “Class Representatives”
similar claims. All
of
these people
One
court resolves
the
issues
those who
timely exclude themselves
from
Class Representatives in
the
Action are
You
have received
this
notice
potentially
being a
Class Member.

assert claims
are
the
for
all
(“opt out”
the
because you

4. Why is there a Settlement?
All
parties have agreed to
a
Settlement
to
avoid further
a
trial, and
so
that
the
people affected can
begin getting
for
releasing
the
Defendant
from liability for
the
claims
could have been raised in
the
Action involving
the
Class
with the
timing chain and
oil
pump drive chain modules. The
mean that
BMW of
North America
broke any
laws, or
anything
wrong, because
Judge Waldor did
not
decide which side
was
right.
The
the
lawyers representing
them think the
Settlement
is
for
the
Class.

cost
and
benefits in
that
were
Vehicles’
Settlement
otherwise
Class
fair

risk
of
exchange
raised or
alleged issues
does not
did

Representatives and
and
reasonable

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

Settlement
Date) in
Rico, who
of
the
purchased
including

Class includes
all
persons or
entities (as
of
the
the
United States, including
the
District of
Columbia
currently
own
or
lease, or
previously
owned or
following
U.S.specification
2012-2015
model year
BMW
or
leased, and
registered
and
operated
in
the
the
District of
Columbia
and
Puerto Rico:
Model Description
Model Years

X1

SAV

2012-2015

X3

SAV

2013-2015

X4

SAV

2015

Z4

2012-2015

228i

Coupe, Convertible

2014-2015

320i

Sedan

2012-2015

328i

Sedan, Sports Wagon, Gran
Turismo
Coupe, Convertible,
Gran
Coupe

2012-2015

428i

Effective
and
Puerto
leased, certain
vehicles
United States,

2014-2015

QUESTIONS? CALL TOLL-FREE (866) 411-6985 OR VISIT www.TimingChainModuleSettlement.com
4
-

528i

Sedan

2012-2015

*Model Years are not fully indicative of actual vehicles, which will depend on production ranges.
6. What are the benefits of the Settlement?