Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 1 of 691 TRINETTE G. KENT (State Bar No. 222020)2 Lemberg Law, LLCFour Embarcadero Center, Suite 14003 San Francisco, CA 941114 Telephone: (480) 247-9644Facsimile: (480) 717-47815 E-mail: firstname.lastname@example.orgUNITED STATES DISTRICT COURTNORTHERN DISTRICT OF CALIFORNIA89Tony Woo, Daniel Rifkin, and Douglas P. Case No.:10 Schwert, on behalf of themselves and allCLASS ACTION COMPLAINT FOR:11 others similarly situated,1222(1) Breach of Express Warranty underthe Magnuson-Moss Warranty Act(2) Breach of Express Warranty underCal. Comm. Code § 2313(3) Breach of Express Warrantypursuant to Song-Beverly ConsumerWarranty Act(4) Breach of Implied Warrantypursuant to Song-Beverly ConsumerWarranty Act(5) Violation of California ConsumersLegal Remedies Act(6) Violation of California’s UnfairCompetition Law(7) Breach of Express Warranty underColo. Rev. Stat. Ann. § 4-2-313(8) Breach of Implied Warranty underColo. Rev. Stat. Ann. § 4-2-314(9) Breach of Express Warranty underTenn. Code Ann. § 47-2-31323DEMAND FOR JURY TRIALPlaintiffs,1314vs.15 American Honda Motor Co., Inc.,161718192021Defendant.2425262728CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 2 of 69123Plaintiffs, Tony Woo, Daniel Rifkin, and Douglas P. Schwert, by undersignedcounsel, bring the following complaint against American Honda Motor Co., Inc., and4 allege, on their own behalf and on behalf of all those similarly situated, as follows:5INTRODUCTION61.Plaintiffs Tony Woo (“Woo”), Daniel Rifkin (“Rifkin”), and Douglas P.78 Schwert (“Schwert,” and together with Woo and Rifkin, the “Plaintiffs”) bring this9 lawsuit against American Honda Motor Co., Inc. (hereafter “Defendant” or “Honda”)10on their own behalf and on behalf of a proposed class of past and present owners and1112 lessees of the following 2017-2019 Honda CR-V models: the EX, EX-L and the13 Touring (the “Class Vehicles”).142.Plaintiffs and the Class were damaged because Class Vehicles contain1516 defective display screens (the “Display Screen”) which dim and go dark, freeze, or17shine at full brightness, causing driver distraction and rendering the vehicle’s1819 information center inoperable.2021223.Specifically, the 7-inch touch-sensitive Display Screen allows drivers toaccess and operate Class Vehicles’ safety, information, communication, and23 entertainment features such as smartphone integration, hands-free calling, navigation24 (if equipped), Bluetooth audio streaming, radio and music controls, rear-view camera25and vehicle settings (collectively, “Infotainment /cr-v/specs-features-trim-comparison (last visited September 12,2019).2CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 3 of 691234.The Display Screen is standard equipment on the 2017-2019 Honda CR-V vehicles at EX, EX-L and Touring trim levels.25.4In practice, the Display Screen regularly and unexpectedly malfunctions5 while the Class Vehicles are in motion. At such times, the Display Screen (1) dims or6goes dark by itself, or (2) freezes, or (3) goes into full bright mode blinding a driver78 during night time, causing driver distraction, and rendering the above-listed9Infotainment Features inoperable (hereinafter referred to as “Display Defect”).106.11The Display Screen in Woo’s 2018 Honda CR-V EX repeatedly and12 unexpectedly switched to an elevated brightness setting and then went dark, and the1314Display Screen continued this behavior, rendering Infotainment Features inoperable15 and uncontrollable, until the Display Screen stopped the cycle by itself or until Woo16 stopped the car and restarted it.177.Likewise, the Display Screen in Rifkin’s 2017 Honda CR-V EX also1819 repeatedly and unexpectedly switched its brightness setting and then went dark, and20the Display Screen continued through such reboot cycle rendering Infotainment2122Features inoperable and uncontrollable, until Rifkin stopped the car and restarted it.23248.Similarly, the Display Screen in Schwert’s 2018 Honda CR-V Touringrepeatedly and unexpectedly went dark, or the Display Screen’s buttons froze,2526 rendering radio, navigation, and other Infotainment Features inoperable, while the27 vehicle was in motion, causing Schwert great distraction and aggravation.28 2Id.3CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 4 of 691239.Moreover, Plaintiffs’ experiences are not unique; numerous other drivershave complained about the Display Screen dimming and going dark, or distracting and4 blinding drivers by switching to full bright at night by itself.56710.Screen to the National Highway and Traffic Safety Administration (“NHTSA”).311.89In addition, many drivers reported their complaints with the DisplayOn January 23, 2019, Honda issued a Tech Line Summary Article(“TLSA”), acknowledging the Display Defect which, Honda admitted, it did not know104howtofix.1112131412.Honda directed its TLSA at the dealers’ service departments, not at thedealers’ sales departments, and did not instruct its dealers to inform prospective15 Honda consumers that the Class Vehicles they were about to purchase or lease16 suffered from the Display Defect.1713. Although Honda knew of such Display Screen faults from the time the1819 2019 Class Vehicles became available for sale in fall of 2018, and certainly at least as20of January 23, 2019, when it published the TLSA (and sooner as Honda gathered2122information and data to prepare such publication), Honda has not disclosed the23 Display Defect to consumers.2414.Plaintiffs have given Honda reasonable opportunities to cure the Display2526 Defect, but Honda has been unable to do so within a reasonable /CR-V/SUV/AWD (last visited September 23, 0152765-0001.pdf (last visited September 23, 2019).4CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 5 of 6912315.Honda’s conduct is in breach of express and implied warranties, theMagnuson-Moss Warrant Act, 15 U.S.C. § 2301, et seq. (the “MMWA”), and violates4 the California Unfair Competition Law, Cal. Bus. & Prof. Code § 17200, et seq. (the5 “UCL”), and the California Consumers Legal Remedies Act, Cal. Civ. Code § 1750,6et seq. (the “CLRA”).78916.Honda has and will continue to benefit from its unlawful conduct – byselling more vehicles, at a higher price, and avoiding warranty obligations – while1011 consumers are harmed at the point of sale as their vehicles continue to suffer from the12 unremedied defects with the Display Screen. Had Plaintiffs and other proposed class1314members known about the defect at the time of purchase or lease, they would not have15 bought or leased the Class Vehicles, or would have paid substantially less for them.1617.To remedy Honda’s unlawful conduct, Plaintiffs, on behalf of proposed1718class members, seek damages and restitution from Honda, as well as notification to19 class members about the defect.202122PARTIES18.Plaintiff Tony Woo is, and at all times mentioned herein was, an adult23 individual who resided in Pleasant Hill, California.2419.Plaintiff Daniel Rifkin is, and at all times mentioned herein was, an adult25262728individual residing in Denver, Colorado.20.Plaintiff Douglas P. Schwert is, and at all times mentioned herein was, anadult individual residing in Signal Mountain, Tennessee.5CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 6 of 6912321.Torrance Boulevard, Torrance, California 90501-2746.JURISDICTION AND VENUE456Defendant American Honda Motor Co., Inc. is headquartered at 191922.This Court has subject matter jurisdiction over this action pursuant to 28U.S.C. § 1332(d) of the Class Action Fairness Act of 2005 because: (i) there are 10078 or more class members, (ii) there is an aggregate amount in controversy exceeding9 5,000,000, exclusive of interest and costs, and (iii) there is minimal diversity because10at least one Plaintiff and Honda are citizens of different states.111223.Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) because13 Honda resides in this District and a substantial part of the events or omissions giving14rise to Plaintiffs’ claims occurred in this District.1516FACTUAL ALLEGATIONS17 A. Honda’s Display Screen1824. Defendant American Honda Motor Co., Inc. is the manufacturer,1920 distributor, and warrantor of all Class Vehicles sold and leased within the United21States.222325.Since at least December of 2016, Honda has designed, manufactured,24 distributed, sold, and leased the Class Vehicles. Honda has sold, directly or indirectly,25through dealers and other retail outlets, thousands of Class Vehicles equipped with the2627 Display Screen in California and nationwide.286CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 7 of 6912326.In its online marketing materials5 and in its marketing brochure6 for theClass Vehicles, Honda advertised that Class Vehicles are equipped with the Display4 Screen.527.Specifically, the 7-inch touch-sensitive Display Screen allows drivers to67access and operate such Class Vehicles’ safety, information, communication, and8 entertainment features as smartphone integration, hands-free calling, navigation (if9equipped), Bluetooth audio streaming, playing of radio and music, and tion1,below.11121314151617181920Illustration eatures-trim-comparison (last visited September 12,24 eird/MY17CRV-Wave2-Reprint.pdf (last visited October 25, atures-trim-comparison (last visited September oconnectivity-youtube (last visited September 20, 2019).7CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 8 of 6912328.Display Screen is standard equipment on the following 2017-2019 HondaCR-V models: the EX, EX-L and the Touring.929.4Upon information and belief, Honda created, authorized, approved, and5 disseminated its online marketing materials and its marketing brochure about Class6Vehicles’ Display Screen out of its Torrance, California headquarters to all United78 States purchasers or lessees of the Class Vehicles, and Honda manages, directs and9conducts its sales and service operations out of its Torrance, California headquarters.101011 B. Display Defect Poses an Unreasonable Safety Hazard12131430.Unbeknownst to Honda’s customers, Class Vehicles are sold with acapacitive touch panel sensor that is defective in material and/or workmanship, which15 causes repeat intermittent and unexpected failure of the Class Vehicle’s Display16 Screen.1731.18In practice, the Display Defect makes the Class Vehicles more19 dangerous, not safer, because the Display Screen regularly and unexpectedly20malfunctions where, while the Class Vehicles are in motion, the Display Screen (1)2122dims or goes dark by itself, or (2) freezes, or (3) goes into full bright mode blinding23 the driver during night time, causing distraction to the driver, and rendering the24Infotainment Features inoperable.252692728Id.10See https://honda.com/operations (last visited September 20, 2019); see nda 2017 Digital FactBook.pdf (last visited September 20,2019).8CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 9 of 6912332.Purchasers and lessees of the Class Vehicles have experienced theDisplay Defect. Complaints filed by consumers with the National Highway Traffic4 Safety Administration (“NHTSA”) demonstrate that the defect is not only widespread5 and dangerous, but that it manifests without warning.633. The complaints also indicate Honda’s awareness of the Display Defect,78 since, as evidenced below, Class Members have taken their Class Vehicles to Honda9authorized dealers for service after experiencing the Display Defect.101134.Honda dealerships are required by Honda’s policies to report customer12 complaints to Honda by filling out Field Technical Reports, or similar documents,131415including reports about the Display Defect.35.Such reports were compiled and catalogued by Honda’s engineering16 personnel.1736. Accordingly, Honda was on actual notice of hundreds, perhaps1819 thousands, of consumers nationwide complaining about the Display Defect before any20of the Plaintiffs bought their cars.212237.In addition, Honda owners and lessees made complaints about the23 Display Defect to the NHTSA (Safercar.gov, Search for Complaints (September rchSafetyIssues/)(spellingand2526 grammatical issues in original):2728 12/05/2017: CENTER CONSOLE / INFOTAINMENT SYSTEM WILLNOT DIM AT NIGHT, NOR CAN IT BE ADJUSTED. IT STAYS AT9CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 10 of 691MAXIMUM BRIGHTNESS. THE CONSOLE DISPLAYS LIGHT EVENWHEN OFF AND ADJUSTING THE VOLUME KNOB TURNS IT BACKON. IT ALSO MAY SPONTANEOUSLY COME BACK ON WHEN OFF.ONCE THE ISSUE APPEARED, IT COULD NOT BE RESOLVED WITHA REBOOT OR HARD RESET. HAVING A BRIGHT LIGHT SOURCECLOSE TO THE DRIVER AT NIGHT IN A DISTRACTION.23456 12/31/2017: AUDIO HEAD UNIT (7" LED PANEL ON EX-L) ONDASHBOARD DOES NOT DIM AT NIGHT. WHEN YOU TRY ANDMOVE THE DIMMER SLIDER ON THE UNIT, IT TRIES TO DIM,THAN GOES BACK TO FULL BRIGHTNESS. THE DEALER HASTRIED TO FIX THIS FOR OVER A YEAR, AND IT’S STILL NOTFIXED. DOING A QUICK GOOGLE SEARCH SHOWS MANY OTHERSHAVING THE SAME PROBLEM. THIS IS A SAFETY ISSUE BECAUSEIT’S TOO BRIGHT AT NIGHT AND AFFECTS/INTERFERES WITHNIGHT DRIVING ESPECIALLY WHEN MAKING RIGHT HANDTURNS BY CREATING A BLINDING CONDITION. 04/28/2018: THE DISPLAY IN MY 2017 HONDA CR V EX WILLSTART BEEPING AT RANDOM AND THE BRIGHTNESS WILLSTART GOING UP AND DOWN BY ITSELF. IT IS VERYDISTRACTING. I HAVE SEEN OTHERS COMPLAIN OF THE EXACTSAME PROBLEM, BUT I CALLED HONDA AND THEY SAID THATDON’T HAVE A FIX. THIS HAPPENS WHILE DRIVING OR WHILESTATIONARY. 05/11/2018: THE DISPLAY IN THE MIDDLE GOES BLANK WHILE IAM DRIVING A LOT. LAST TIME I WAS BACKING OUT WHEN ITDID WHICH CAUSE MY CAR TO HAVE SERIOUS SCRATCHES ONIT. AT THE SAME TIME THE BACK UP SEEMED NOT TO BEWORKING EITHER. 08/04/2018: THE INFOTAINMENT DISPLAY WILL RANDOMLYTURN OFF WHILE DRIVING. AUDIO CONTINUES TO PLAYWITHOUT DISPLAY. PRESSING THE HOME BUTTON SOMETIMESRESOLVE THE ISSUE, BUT SOMETIME IT REQUIRES TO HAVE THEVEHICLE COMPLETELY TURNED-OFF TO GET THE CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 11 of 691BACK.23 10/01/2018: ON 08-10-2018 AFTER JUST GETTING ONTO THEFREEWAY ON THE WAY TO A MEETING, THEAUDIO/INFORMATION SCREEN (INFOTAINMENT SCREEN) WENTINTO MALFUNCTION. IT WAS TURNING ITSELF ON AND OFF,AND BEEPING. THERE WAS NO WAY TO TURN THE SCREEN OFFAND NO WAY TO SILENCE THE BEEPING. THE MALFUNCTIONCONTINUED NON-STOP UNTIL THE VEHICLE WAS TURNED OFF.THIS CAUSED AN EXTREME STATE OF DISTRACTED-DRIVERWHILE ON THE FREEWAY WITH MANY OTHER AUTOMOBILESAROUND. 10/05/2018: THERE HAVE BEEN NUMEROUS TIMES AT STARTUPWHEN THE CENTRAL DISPLAY SCREEN FREEZES, REMAINSBLACK, DENYING NAVIGATION ASSISTANCE AMONG OTHEROPTIONS. IT APPEARS THE ONLY WAY TO CORRECT THIS IS TORESTART THE VEHICLE. 10/09/2018: IN ADDITION THE DISPLAY SCREEN (RADIO ETC.)DOES NOT DIM. IT STAYS FULL BRIGHTNESS EVEN WITHADJUSTING IT. HONDA HAD TO FIX WHEN VEHICLE WAS BRANDNEW AFTER I HAD TO FIGHT WITH THEM THAT THIS IS ANISSUE. THE SCREEN BLINDS ME AT NIGHT BECAUSE IT IS VERYBRIGHT SO YOU CAN’T REALLY SEE THE ROAD. THIS STAYSBRIGHT STOPPED OR MOVING. 10/18/2018: PURCHASED THIS CAR FROM KEATING HONDA INCONROE, TX. SINCE DAY 1 I HAVE HAD ISSUES WITH MY LCDSCREEN THAT CONTROLS THE AUDIO AND CLIMATE. ABOUTMID SEPTEMBER I STARTED HAVING ISSUES WITH IT SHUTTINGOFF ALONG WITH THE LCD SCREEN BEHIND THE STEERINGWHEEL THAT SHOWS HOW FAST I’M GOING. DEALERSHIPAWARE BUT HAD ISSUES WITH GETTING LOANER SO UNABLETO DROP OFF FOR REPAIR. THE SCREEN WOULD FLICKER ANDSHUT OFF WHILE DRIVING OR "AUDIO ISN’T RESPONDING"ERROR SHOWS UP AND BOTH LCD SCREENS GO OUT 1CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 12 of 691DRIVING. I WOULD START THE CAR AND WOULD RECEIVE ANERROR MESSAGE LIKE "ANTI THEFT SYSTEM: THIS SYSTEM HASLOST POWER. PRESS THE POWER KEY FOR MORE THAN TWOSECONDS TO ENABLE THE SYSTEM" . PLEASE FIX YOUR SHIT! IWAS GIVEN A WARNING IN CONROE BECAUSE I WAS SPEEDINGAND UNAWARE OF MY SPEED DUE TO THIS ISSUE AND IT SEEMSTO BE A DAILY PROBLEM FOR ME.234567 11/06/2018: I HAVE BEEN HAVING ISSUES WITH INFOTAINMENTSCREEN/SYSTEM. THE SYSTEM FREEZES AND SOMETIMES GOESBLACK AND WON’T RESPOND TO TOUCHES AND ORINSTRUCTIONS. THE CAR HAS BEEN TO THE DEALER SEVERALTIMES WITH NO PERMANENT FIX. 11/25/2018: INFOTAINMENT SCREEN WILL RANDOMLY FLASH,DIM AND BEEP. THIS HAS CAUSED SEVERAL SAFETY ISSUESINCLUDING HIGH LEVEL OF DISTRACTION AND FAILURE OF THENAVIGATION SYSTEM AT ALL THE WRONG TIMES. THISHAPPENS RANDOMLY WHEN THE VEHICLE IS IN MOTION ORSTOPPED. THE PROBLEM HAS BEEN REPORTED TO THE DEALERAND THEY HAVE FAILED TO FIND A SOLUTION. THEY CLAIM NOONE ELSE HAS REPORTED SIMILAR PROBLEMS. THIS ISLAUGHABLE DUE TO ALL OF THE ONLINE COMPLAINTS ANDYOUTUBE VIDEOS DOCUMENTING THE SAME PROBLEM. THEYHAVE REFUSED TO ATTEMPT A REPAIR OR REPLACEMENT OFAFFECTED DEFECTED COMPONENTS. 11/28/2018: WHILE DRIVING THE AUDIO SYSTEM STARTSBEEPING, THE SCREEN FLASHES AND IT MAKES RANDOMPHONE CALLS. I TOOK IT TO THE DEALER AND WAS TOLD THATTHEY DID NOT HAVE A FIX FOR THIS PROBLEM. I AM AFRAIDTHAT THIS DISTRACTION COULD CAUSE AN ACCIDENT. ILOOKED ONLINE TO FIND OTHER OWNERS HAD THE SAMEPROBLEM. THIS HAPPENS ON CITY STREETS ON THE HIGHWAYAND WHILE STATIONARY. I BELIEVE THIS IS A MAJOR SAFETYHAZARD. THIS HAS HAPPENED SEVERAL ASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Filed 10/28/19 Page 13 of 691 12/10/2018: THE "INFOTAINMENT" OR NAVIGATION SCREENMALFUNCTIONS AND TURNS ITSELF OFF. THIS RESULTS IN LOSSHEATING AND COOLING CONTROLS AS WELL AS OTHERIMPORTANT SAFETY FUNCTIONS. 01/14/2019: STALLING, LOSS OF ENGINE POWER, SMELL OF GASIN THE PASSENGER COMPARTMENT, AUDIO DISPLAY ERRATIC,ALL WHILE CAR IS IN MOTION. 01/21/2019: THE INFORMATION SCREEN FOR AUDIO ANDCLIMATE CONTROLS GO COMPLETELY OUT AND OR FUNCTIONERRATICALLY. THE FUNCTION ON THE DRIVING SAFETYSYSTEMS FOR ANTI BRAKE AND ANTI COLLISION ALSOFUNCTION ERRATICALLY. LOSING CRITICAL FUNCTIONS OFTHE CAR WHILE THE CAR IS STILL OPERATING. I HAVE VIDEOAND MORE PHOTOS. 02/05/2019: TOUCH SCREEN DASHBOARD SOMETIMES GOESBLANK AND NON RESPONSIVE. 02/06/2019: THESE PROBLEMS HAVE BEEN GOING ON FOR THEPAST YEAR. MULTIMEDIA INFORMATION DISPLAYOCCASSIONALLY CHANGES BRIGHTNESS ON ITS OWN. IT ALSOSOMETIMES ACTIVATES ON SCREEN BUTTONS BY ITSELF.TODAY (2/6/2019), WHILE PLAYING AUDIO THROUGH THE CAR’SBLUETOOTH SYSTEM AND USING THE GPS, THE DISPLAYBLANKED OUT FOR 3 - 5 MINUTES. ALSO, THE BOTTOM HALF OFTHE TACHOMETER DISPLAY, VIEWED THROUGH THE STEERINGWHEEL, BLANKED OUT AND SHOWED A SPINNING WAITCURSOR. AFTER THAT WAIT TIME, THE MULTIMEDIA DISPLAYTURNED BLACK. THEN ABOUT 30 SECONDS LATER, IT SHOWEDTHE HONDA SYMBOL. INDICATING THAT IS WAS BOOTING. IHAD BROUGHT THE VEHICLE TO MY DEALER LAST FRIDAY FORMAINTENANCE WORK AND THEY HAD RESET THE MULTIMEDIADISPLAY. IT SEEMS TOO SOON FOR PROBLEMS TO OCCUR YETAGAIN. ALL OF THESE PROBLEMS OCCURRED WHILE DRIVING.THE RANDOM BRIGHTNESS CHANGES ARE QUITE 6272813CLASS ACTION COMPLAINT
Case 4:19-cv-07042-DMR Document 1 Fi
lawsuit against American Honda Motor Co., Inc. (hereafter “Defendant” or “Honda”) on their own behalf and on behalf of a proposed class of past and present owners and lessees of the following 2017-2019 Honda CR-V models: the EX, EX-L and the Touring (the “Class Vehicles”). 2.
Aug 19, 2019 · KELLEY, on behalf of themselves and others similarly situated; HOTZE HEALTH & WELLNESS CENTER, on behalf of themselves and others similarly situated; BRAIDWOOD MANAGEMENT, INCORPORATED, Plaintiffs - Appellees . v. STATE OF NEVADA, Appellant. On Appeal from . United States District Court for the Northern District of Texas . 4:18-CV-825-O
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Artificial Intelligence in Supply Chains Martin Zapke, 3806 A Field Lab carried out on the Master in Management Program, under the supervision of: Professor José Crespo de Carvalho 4th January 2019 . ii Disclaimer With this disclaimer, Martin Zapke, ensures that the following work project to obtain the Master of Science degree in Management is conducted by himself. The mentioned references .