Auto Dealership Parts Price Fixing Class Action Settlement

Class Eligibility

Your dealership is part of one or more of the Settlements if it is a Dealer and falls within the definition of one or more of the Settlement Classes approved by Judge Marianne O. Battani. The Settlement Class definitions are set forth below. For the purposes of only this Paragraph 5, the term “Defendants” as used below shall be as defined in the applicable settlement agreements:

(A) The Aisan Fuel Injection Systems Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through December 19, 2016, (a) purchased a new Vehicle in the United States for resale, which included as a component part one or more Fuel Injection Systems manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant, or (b) indirectly purchased one or more Fuel Injection Systems as a replacement part, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant.

(B) The Aisin Seiki Valve Timing Control Devices Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through August 25, 2016, indirectly (a) purchased Valve Timing Control Devices manufactured by the Defendants or any current or former subsidiary or affiliate thereof or any co-conspirator, or (b) purchased new vehicles containing Valve Timing Control Devices manufactured by the Defendants or any current or former subsidiary, affiliate thereof or co-conspirator.

(C) The Alps Heater Control Panels Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through May 5, 2017, (i) indirectly purchased one or more Heater Control Panels which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant, or (ii) purchased a Vehicle in the United States for resale which included one or more Heater Control Panels as a component part, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant.

(D) The Bosch Windshield Wiper System Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through September 29, 2017, purchased a Vehicle in the United States for resale, which included, as a component part, one or more Windshield Wiper System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate thereof, or any co-conspirator of a Defendant; or indirectly purchased one or more Windshield Wiper System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(E) The Bosch Starters Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through September 29, 2017, purchased a Vehicle in the United States for resale which included, as a component part, one or more Starter(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant; or indirectly purchased one or more Starter(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(F) The Bosch Fuel Injection Systems Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through September 29, 2017, purchased a Vehicle in the United States for resale, which included, as a component part, one or more Fuel Injection System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant; or indirectly purchased one or more Fuel Injection System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(G) The Bosch Spark Plugs Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through September 29, 2017, purchased a Vehicle in the United States for resale, which included, as a component part, one or more Spark Plug(s), Standard Oxygen Sensor(s), or Air Fuel Ratio Sensor(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant; or indirectly purchased one or more Spark Plug(s), Standard Oxygen Sensor(s), or Air Fuel Ratio Sensor(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(H) The Bridgestone Anti-Vibration Rubber Parts Settlement Class is defined as:

All Automobile Dealerships that, from March 1, 1996 through September 27, 2017, (a) indirectly purchased Anti-Vibration Rubber Parts manufactured by the Defendants or any current or former subsidiary or affiliate thereof or any co-conspirator, or (b) purchased Vehicles for resale that contained Anti-Vibration Rubber Parts manufactured by the Defendants or any current or former subsidiary, affiliate thereof or co-conspirator.

(I) The Chiyoda Automotive Wire Harness Systems Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 1999 through January 5, 2017, (a) indirectly purchased one or more Automotive Wire Harness Systems manufactured or sold by Defendants or any current or former parent, subsidiary or affiliate thereof, or any co-conspirator, or (b) purchased a new Vehicle in the United States for resale, which included as a component part Automotive Wire Harness Systems manufactured by Defendants or any or current or former parent, subsidiary, affiliate thereof, or co-conspirator.

(J) The Diamond Electric Ignition Coils Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through June 14, 2017, (a) indirectly purchased one or more Ignition Coil(s) as a component part, or indirectly purchased one or more Ignition Coil(s) as a replacement part, which were manufactured or sold by Defendants, any current or former subsidiary of Defendants, or any co-conspirator of a Defendant, or (b) purchased Vehicles for resale that contained Ignition Coil(s) manufactured or sold by Defendants, any current or former subsidiary of Defendants, or any co-conspirator of a Defendant.

(K) The Eberspächer Exhaust Systems Settlement Class is defined as:

All automobile dealers that, from January 1, 2002 through September 29, 2017, (a) indirectly purchased one or more Exhaust System(s) manufactured or sold by a Defendant or any current or former subsidiary or affiliate thereof or any co-conspirator, or (b) purchased Vehicles for resale that contained one or more Exhaust System(s), which were manufactured or sold by a Defendant or any current or former subsidiary or affiliate thereof, or co-conspirator.

(L) The G.S. Electech Automotive Wire Harness Systems Settlement Class is defined as:

All automobile dealers that, from January 1, 1999, through August 29, 2016, (1) purchased new vehicles that included one or more Automotive Wire Harness System(s) as a component part, which were manufactured or sold by a Defendant, any current or former parent, subsidiary, or affiliate of a Defendant, or any co-conspirator of the Defendants, or (2) indirectly purchased one or more Automotive Wire Harness System(s), which were manufactured or sold by a Defendant, any current or former parent, subsidiary, or affiliate of a Defendant or any co-conspirator of the Defendants.

(M) The Hitachi Automotive Brake Hoses Settlement Class is defined as:

All Automobile Dealerships that, from February 1, 2004 to May 23, 2017, (a) indirectly purchased Automotive Brake Hoses manufactured or sold by the Defendants or any current or former subsidiary or affiliate thereof or any co-conspirator, or (b) purchased a new Vehicle in the United States, which contained Automotive Brake Hose manufactured or sold by Defendants or any current or former subsidiary, affiliate thereof or co-conspirator.

(N) The HIAMS Shock Absorbers Settlement Class is defined as:

All Automobile Dealerships that, during the period from and including January 1, 1995 through October 2, 2017, (a) indirectly purchased for resale one or more Shock Absorbers manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant, or (b) purchased Vehicles for resale containing Shock Absorbers manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant.

(O) The INOAC Interior Trim Settlement Class is defined as:

All automobile dealers that, from June 2004 through March 9, 2017, (a) indirectly purchased one or more Interior Trim(s) manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, including, but not limited to, Intertec Systems, LLC, a U.S. company, and Intertec Systems, an Ontario general partnership, or any co-conspirator of a Defendant, or (b) purchased Vehicles containing one or more Interior Trim(s) manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, including, but not limited to, Intertec Systems, LLC, a U.S. company, and Intertec Systems, an Ontario general partnership, or any co-conspirator of a Defendant.

(P) The JTEKT Automotive Bearings Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through October 6, 2016, (1) purchased new Vehicles in the United States that included one or more Automotive Bearings as a component part, which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant or (2) indirectly purchased one or more Automotive Bearings, which were manufactured or sold by a Defendant, any current or former parent, subsidiary, or affiliate of a Defendant, or any co-conspirator of Defendants.

(Q) The JTEKT Electronic Powered Steering Assemblies Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through October 6, 2016, (1) purchased new Vehicles in the United States that included one or more Electronic Powered Steering Assemblies as a component part, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant, or (2) indirectly purchased one or more Electronic Powered Steering Assemblies, which were manufactured or sold by a Defendant, any current or former parent, subsidiary, or affiliate of a Defendant, or any co-conspirator of Defendants.

(R) The Kiekert Side-Door Latches and Latch Minimodules Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2004 through September 22, 2017, (a) indirectly purchased Side-Door Latches or Latch Minimodules, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant, or (b) purchased Vehicles for resale that contained one or more Side-Door Latches or Latch Minimodules, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant.

(S) The Koito Automotive Lamps Settlement Class is defined as:

All Automobile Dealers that, from July 1, 2002 through May 26, 2017, (a) indirectly purchased Automotive Lamps manufactured by a Defendant or any current or former subsidiary or affiliate thereof or any co-conspirator, or (b) purchased Vehicles for resale containing Automotive Lamps manufactured by a Defendant or any current or former subsidiary, affiliate thereof or co-conspirator.

(T) The Koito HID Ballasts Settlement Class is defined as:

All Automobile Dealers that, from July 1, 1998 through May 26, 2017, (a) indirectly purchased HID Ballasts manufactured or sold by a Defendant or any current or former subsidiary or affiliate thereof or any co-conspirator, or (b) purchased Vehicles for resale containing HID Ballasts manufactured or sold by a Defendant or any current or former subsidiary, affiliate thereof or co-conspirator.

(U) The Mitsuba Windshield Wiper Systems Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through August 30, 2017, purchased a Vehicle, which included, as a component part, one or more Windshield Wiper System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate thereof, or any co-conspirator of a Defendant, or indirectly purchased, as a replacement part, one or more Windshield Wiper System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(V) The Mitsuba Radiators Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through August 30, 2017, purchased a Vehicle, which included, as a component part, one or more Radiator(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate thereof, or any co-conspirator of a Defendant, or indirectly purchased, as a replacement part, one or more Radiator(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(W) The Mitsuba Starters Settlement Class is defined as:

All Automobile Dealerships that, from June 1, 2000 through August 30, 2017, purchased a Vehicle, which included, as a component part, one or more Starter(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant, or indirectly purchased, as a replacement part, one or more Starter(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(X) The Mitsuba Automotive Lamps Settlement Class is defined as:

All Automobile Dealerships that, from July 1, 2002 through August 30, 2017, purchased a Vehicle, which included, as a component part, one or more Automotive Lamp(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant, or indirectly purchased, as a replacement part, one or more Automotive Lamp(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(Y) The Mitsuba Electric Powered Steering Assembly Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through August 30, 2017, purchased a Vehicle, which included, as a component part, one or more Electric Powered Steering Assembly(ies), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant, or indirectly purchased, as a replacement part, one or more Electric Powered Steering Assembly(ies), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(Z) The Mitsuba Fan Motor Settlement Class is defined as:

All Automobile Dealerships that, from July 1, 1999 through August 30, 2017, purchased a Vehicle in the United States, which included, as a component part, one or more Fan Motor(s), which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant, or indirectly purchased, as a replacement part, one or more Fan Motor(s), which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any coconspirator of a Defendant.

(AA) The Mitsuba Fuel Injection System Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through August 30, 2017, purchased a Vehicle, which included, as a component part, one or more Fuel Injection System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant, or indirectly purchased, as a replacement part, one or more Fuel Injection System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(BB) The Mitsuba Power Window Motor Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through August 30, 2017, purchased a Vehicle, which included, as a component part, one or more Power Window Motor(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant, or indirectly purchased, as a replacement part, one or more Power Window Motor(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any co-conspirator of a Defendant.

(CC) The Mitsuba Windshield Washer Systems Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through August 30, 2017, purchased a Vehicle, which included, as a component part, one or more Windshield Washer System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any coconspirator of a Defendant, or indirectly purchased, as a replacement part, one or more Windshield Washer System(s), which were manufactured or sold by a Defendant, any current or former subsidiary or affiliate of a Defendant, or any coconspirator of a Defendant.

(DD) The NGK Ceramic Substrates Settlement Class is defined as:

All Automobile Dealerships that, from July 1, 1999 through October 26, 2017, (a) indirectly purchased one or more Ceramic Substrates, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant, or (b) purchased Vehicles for resale that contained Ceramic Substrates manufactured by the Defendants or any current or former subsidiary, affiliate thereof, or any co-conspirator of a Defendant.

(EE) The NRC Body Sealings Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through November 15, 2017, (a) purchased Vehicles for resale in the United States which included one or more Body Sealing(s) as a component part, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant, or (b) indirectly purchased one or more Body Sealing(s) in the United States, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant.

(FF) The NTN Bearings Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through November 16, 2016, indirectly: (a) purchased Bearings manufactured by the Defendants in any current or former subsidiary or affiliate thereof or any co-conspirator, or (b) purchased new vehicles containing Bearings manufactured by the Defendants or any current or former subsidiary, affiliate thereof or co-conspirator.

(GG) The Tokai Rika Automotive Wire Harness Systems Settlement Class is defined as:

All automobile dealers that, from January 1, 1999, through September 1, 2016, purchased a new vehicle in the United States, which included one or more Automotive Wire Harness System(s) as a component part, or indirectly purchased one or more Automotive Wire Harness System(s) as a replacement part, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirators of the Defendants.

(HH) The Toyo Anti-Vibration Rubber Parts Settlement Class is defined as:

All Automobile Dealerships that, from March 1, 1996 through September 14, 2017, (a) indirectly purchased Anti-Vibrational Rubber Parts manufactured by the Defendants or any current or former subsidiary or affiliate thereof or any co-conspirator, or (b) purchased Vehicles for resale that contained Anti-Vibration Rubber Parts manufactured by the Defendants or any current or former subsidiary, affiliate thereof or co-conspirator.

(II) The Toyo Constant-Velocity Joint Boot Products Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2006 through September 14, 2017, (a) indirectly purchased Automotive Constant-Velocity Joint Boot Products manufactured by the Defendants or any current or former subsidiary or affiliate thereof or any co-conspirator, or (b) purchased Vehicles for resale that contained Automotive Constant-Velocity Joint Boot Products manufactured by the Defendants or any current or former subsidiary, affiliate thereof or co-conspirator.

(JJ) The Yamada Electronic Powered Steering Assemblies Settlement Class is defined as:

All Automobile Dealerships that, from January 1, 2000 through November 28, 2016, purchased a new Vehicle in the United States for resale which included one or more Electronic Powered Steering Assemblies as a component part, or indirectly purchased one or more Electronic Powered Steering Assemblies as a replacement part, which were manufactured or sold by a Defendant, any current or former subsidiary of a Defendant, or any co-conspirator of a Defendant.

(KK) The Yamashita Anti-Vibration Rubber Parts Settlement Class is defined as:

All Automobile Dealerships that, from March 1, 1996 through September 27, 2016, purchased new Vehicles that included one or more Anti-Vibration Rubber Parts as a component part, which were manufactured or sold by a Defendant, any current or former parent, subsidiary, or affiliate of a Defendant, or any co-conspirator of the Defendants.

A list of the Defendants and the alleged co-conspirators for each case involving the affected component parts described in the Settlement Class definitions above is available on the Settlement Website. You may also call the Settlement Administrator toll free at 1-888-565-3171 for more information.

Dealers who indirectly purchased certain component parts and/or purchased new vehicles for resale containing these component parts, listed in the Settlement Class definitions above, in one or more of the Included States (Arizona, Arkansas, California, District of Columbia, Florida, Hawaii, Illinois, Iowa, Kansas, Maine, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Nebraska, Nevada, New Hampshire, New Mexico, New York, North Carolina, North Dakota, Oregon, South Carolina, South Dakota, Tennessee, Utah, Vermont, West Virginia, and Wisconsin) may receive money benefits from the Settlements. Dealers in the United States who indirectly purchased certain component parts and/or purchased new vehicles for resale containing these component parts, listed in the Settlement Class definitions above, may receive other, non-monetary benefits from the Settlements as explained in further detail on the Settlement Website.

If your dealership is a member of one or more of these Settlement Classes and purchased in an Included State, the amount of money it will receive, if any, will depend upon where the dealership purchased the affected vehicles or component parts and the Plans of Allocation discussed below.

Estimated Amount

Varies

our dealership’s share (if any) of the Settlement Funds will be determined based upon the Plans of Allocation, which have been devised under the supervision of a special allocation consultant and which have been, or will be, approved by the Court. The Plans of Allocation are or will be made available on the Settlement Website, at www.AutoDealerSettlement.com. The Plans of Allocation allocate the net proceeds of each of the Settlements to: (1) Dealers who purchased vehicle models that were subject to alleged collusion on bids for components parts, (2) Dealers who purchased vehicles from manufacturers of vehicles allegedly affected by collusion on bids for component parts, (3) Dealers who purchased the allegedly affected component parts manufactured by the Settling Defendants and/or their predecessors, subsidiaries and affiliates or their alleged

co-conspirators, and (4) a reserve fund for future allocation and distribution to Settlement Class Members. Payments will take into account the number and type of vehicles and affected component parts your dealership purchased during the periods set forth in the Settlement Class definitions.

At this time, it is unknown how much money each Settlement Class Member who purchased new affected vehicles or any of the affected component parts in the Included States listed in Question 2 above will receive. It is expected that each Settlement Class Member who purchased new affected vehicles or any of the affected component parts in the Included States and who files a valid Proof of Claim will receive a minimum payment of $350.00 under these Settlements.

Proof of Purchase

Yes

Case Name

In re: Automotive Parts Antitrust Litigation, Case
Case No. 12-md-02311

District Court for the Eastern District of Michigan

Case Summary

The separate lawsuits claim that the Defendants in each lawsuit conspired to fix, maintain, and artificially raise the price of component parts at issue in each lawsuit. The lawsuits claim that, as a result of the relevant Defendants’ conduct, Dealers paid more than they should have for the parts at issue in that lawsuit and paid more for the new vehicles in which those parts are contained. The lawsuits also allege that Dealers were unable to pass on all of these increased costs to their customers. These cases are proceeding as class actions for monetary recovery for Dealers in the District of Columbia and one or more of the following states: Arizona, Arkansas, California, Florida, Hawaii, Illinois, Iowa, Kansas, Maine, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Nebraska, Nevada, New Hampshire, New Mexico, New York, North Carolina, North Dakota, Oregon, South Carolina, South Dakota, Tennessee, Utah, Vermont, West Virginia, and Wisconsin (the “Included States”). The lawsuits also seek nationwide injunctive relief.

Settlement Pool

$115,000,000

Deadline

01/21/2019

Contact

Auto Dealer Settlement Administrator

Gilardi & Co LLC

P.O. Box 404000

Louisville, KY 40233-4000

1-888-565-3171

info@AutoDealerSettlement.com