Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 1 of 102 Page ID #:5 1 2 3 4 5 6 7 8 9 10 11 12 BISNAR CHASE LLP BRIAN D. CHASE (164109) bchase@bisnarchase.com JERUSALEM F. BELIGAN (211258) jbeligan@bisnarchase.com 1301 Dove Street, Suite 120 Newport Beach, CA 92626 Telephone: 949/752-2999 Facsimile: 949/752-2777 KABATECK BROWN KELLNER BRIAN S. KABATECK bsk@kbklawyers.com LINA MELIDONIAN lm@kbklawyers.com DREW R. FERRANDINI df@kbklawyers.com Engine Company No. 28 Building 644 South Figueroa Street Los Angeles, CA 90017 Telephone: 213/217-5000 Facsimile: 213/217-5010 Attorneys for Plaintiff 13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA 15 SOUTHERN DIVISION 16 17 18 19 20 21 22 23 24 25 26 27 ALBERT HEBER, on behalf of himself ) and all others similarly situated, ) ) Plaintiff, ) ) vs. ) ) TOYOTA MOTOR SALES, U.S.A., ) INC. ) ) ) ) Defendant. ) ) ) ) ) ) ) ) ) Case No.: CLASS ACTION COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF DEMAND FOR JURY TRIAL 28 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 2 of 102 Page ID #:6 1 2 NATURE OF THE ACTION 1. Plaintiff Albert Heber (“Plaintiff”), by his undersigned counsel, brings 3 this class action against Toyota Motor Sales, U.S.A., Inc. (“Toyota” or 4 “Defendant”), alleging causes of action for breach of implied and express warranty, 5 violation 6 Improvement Act (“MMA”), 15 U.S.C. §§ 2301, et. seq., for declaratory relief under 7 the Declaratory Judgment Act, 28 U.S.C. § 2201 et. seq., and violation of the 8 Indiana Deceptive Consumer Sales Act. Plaintiff brings this action on his own 9 behalf as well as on behalf of similarly situated owners and lessees of 2012 to 2016 10 model year Toyota vehicles (“Class Vehicles”) nationwide or, alternatively, on 11 behalf of a narrower statewide sub-class of such owners. As detailed below, these 12 Class Vehicles are defective in material or workmanship in that their electrical 13 wiring is coated with soy-based insulation—a type of insulation that Toyota 14 implemented relatively recently that is purportedly more environmentally friendly 15 and less expensive than traditional petroleum-based electrical insulation. A 16 continuous, unintended, and undesired consequence of this soy-based insulation 17 material is that it attracts rodents and other animals, who then proceed to chew 18 though the insulation and electrical wire that the insulation coats. Owners of the 19 Class Vehicles, like Plaintiff, are left with a disabled or otherwise improperly 20 functioning vehicle due to an electrical system whose wiring has been feasted upon. 21 2. of the Magnuson-Moss Warranty-Federal Trade Commission This was the fate of Plaintiff, whose 2012 Toyota Tundra had its soy- 22 based insulated wiring chewed through by rodents on three separate occasions. The 23 first incident occurred in or about October 2013 less than 4,000 miles or 24 approximately 10 months after date of purchase (December 29, 2012). The Toyota 25 dealership to which Plaintiff took his Tundra found rodent damage to the EVAP 26 tube and Plaintiff reported that the check engine light turned on and would not turn 27 off. Toyota refused to cover under warranty the required repair and/or replacement 28 1 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 3 of 102 Page ID #:7 1 of the wiring, even though Toyota’s New Vehicle Limited Warranty (“Warranty”) 2 provided that, during the 3-year/36,000-mile warranty term: 3 “This warranty covers repairs and adjustments needed to correct 4 defects in materials or workmanship of any part supplied by 5 Toyota ...” 6 Exhibit 1 hereto (2012 Toyota New Vehicle Limited Warranty), at 12. Additionally, 7 in Toyota’s list of exclusions to the warranty, there is no mention of electrical or 8 rodents/animals being excluded. The exclusions listed are: fire, accident, theft, 9 abuse, negligence, misuse, improper repair, tampering or alteration, lack of 10 maintenance, improper maintenance, installation of non-genuine parts, airborne 11 chemicals, water contamination, and “[n]ormal [w]ear and [t]ear.” Id. at 13. 12 3. A short eight months after the first incident, in or about June 2014, 13 Plaintiff’s Tundra suffered a similar fate, with the harness and ground straps being 14 chewed through, causing numerous lights in the dashboard to turn on. Toyota 15 refused to cover the wiring replacement and Plaintiff was left to pay out of his own 16 pocket. Plaintiff was again advised that rodents were chewing through the gas tank 17 harnesses which was causing the faults in the EVAP system. Plaintiff was advised 18 that the check engine light will remain on until the rodents stopped chewing through 19 the gas tank harnesses. 20 4. In or around June 2015, after Toyota again refused to cover the damage 21 caused by rodents chewing through the wiring in his vehicle, Plaintiff went to a 22 third-party repair shop to have the wiring repaired and for which he paid out of his 23 own pocket. On three separate occasions, Plaintiff presented his vehicle to a Toyota 24 dealership after the wiring in his Tundra had been chewed through by rodents. On 25 each occasion, Toyota refused to repair or replace the wiring under the Warranty, 26 leaving Plaintiff to pay for the repairs. Worse yet, the wiring replacement that 27 Toyota performed at Plaintiff’s expense consisted of replacing the soy-based 28 2 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 4 of 102 Page ID #:8 1 insulated wiring with more of the same wiring. When Plaintiff complained to the 2 Toyota Customer Experience Center, he was advised by Defendant that Toyota did 3 not consider this issue to constitute a defect or issue that was subject to coverage 4 under Defendant’s Warranty. 5 5. Since Toyota chose inaction by refusing to replace the defective wiring 6 material under warranty in the Class Vehicles, and because this defect is prevalent 7 and common across all Class Vehicles, Plaintiff now brings this class action 8 seeking: declaratory relief on behalf of all owners of the Class Vehicles that the soy- 9 based insulated wires in the Class Vehicles are defective in material or workmanship 10 and, therefore, are subject to coverage under Toyota’s Warranty; monetary relief as 11 redress for Toyota’s breach of its implied and express warranty for those Class 12 Vehicle owners who have suffered the same fate; monetary and equitable relief for 13 Toyota’s violation of the MMA in connection with Defendant’s failure to implement 14 or honor the terms of its Warranty; as well as an award of attorneys’ fees and costs. 15 JURISDICTION & VENUE 16 6. This Court has subject-matter jurisdiction over all counts of this 17 complaint. The Court has subject-matter jurisdiction over Count II, alleging a claim 18 for breach of express warranty, under the Class Action Fairness Act, 28 U.S.C. § 19 1332(d)(2) because the matter in controversy exceeds the sum or value of $5 20 million, exclusive of interest and costs, and is a class action in which Plaintiff is a 21 citizen of Indiana, and members of a putative class are of a diverse citizenship 22 (nationwide) from Defendant’s citizenship (California). In addition, this Court has 23 subject-matter-jurisdiction over Count III of this complaint pursuant to 28 U.S.C. § 24 1331 because that claim raises a federal question under the MMA. Counts IV and V 25 of this complaint allege claims for breach of implied warranty and violation of the 26 Indiana Deceptive Consumer Sales Act, and this Court has supplemental subject- 27 matter-jurisdiction over those counts pursuant to 28 U.S.C. § 1367 because they 28 3 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 5 of 102 Page ID #:9 1 arise from and share a common nucleus of operative facts or law with the remaining 2 counts over which this Court does have subject-matter-jurisdiction under 28 U.S.C. 3 §§ 1331 or 1332(d). 4 7. Venue in this judicial district is also proper as Defendant is a resident 5 of this judicial district, and has its principal place of business within this judicial 6 district. Toyota distributes vehicles within the stream of commerce into this district. 7 Venue in this judicial district is, therefore, proper under 28 U.S.C. § 1391. 8 8. Jurisdiction over the Indiana Plaintiff is proper pursuant to Section 28 9 U.S.C. § 1367, which provides, in relevant part, that: (a) “in any action of which the 10 district courts have original jurisdiction, the district courts shall have supplemental 11 jurisdiction over all other claims that are so related to claims in the action within 12 such original jurisdiction that they form part of the same case or controversy under 13 Article III of the United States Constitution … includ[ing] claims that involve the 14 joinder … of additional parties.” 15 16 PLAINTIFF’S FACTUAL ALLEGATIONS 9. Plaintiff is a resident of Indiana, and the original owner of a 2012 17 Toyota Tundra, which he purchased on December 29, 2012 at Bob Rohrman 18 Toyota, a Toyota-factory authorized dealership in Lafayette, Indiana. In May 2013, 19 Plaintiff took his vehicle to the dealership as his check engine light was on; the issue 20 was deemed to be a loose plug and the dealership corrected the issue without cost to 21 Plaintiff. Approximately two weeks later, Plaintiff was back at the dealership as the 22 check engine light was again illuminated. At this time, it was determined that his 23 Tundra, which had less than 2,000 miles on it, had a leak in the emissions system, 24 which again the dealership completed repairs without hesitation or cost to Plaintiff. 25 10. In less than four months, in October 2013, when Plaintiff’s Tundra had 26 approximately 3,441 miles, he discovered that his vehicle’s check engine light was 27 on again. This warranted another trip to the dealership, wherein this time he was 28 4 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 6 of 102 Page ID #:10 1 advised that rodents damaged the vapor fuel hose, which is part of the emissions 2 system. This time, however, Plaintiff was advised by the Toyota Service Advisor 3 that this repair would not be covered under warranty and would have to pay 4 $1,183.82 out of pocket. Plaintiff chose not to repair the wiring at that time due to 5 the cost he would incur. 6 11. A short eight months later, in June 2014, Plaintiff’s Tundra had 7 approximately 5,714 miles on it; again numerous lights in the dashboard, including 8 the check engine light, came on, which warranted another trip to the dealership. On 9 this trip, the service technician found broken and chewed through wiring harness 10 and ground straps. Toyota refused to cover the damages under the Warranty and 11 Plaintiff was forced to pay for the damages out of his own pocket. 12 12. In or around June 2015, Plaintiff returned to the Toyota dealership 13 again complaining about rodents chewing through the wiring in his vehicle. On this 14 last instance, Plaintiff chose not to complete the repairs at the dealership after being 15 told again that this would be an out of pocket expense. Instead, he took his vehicle 16 to a third party repair shop whom a Toyota Service Advisor recommended; they 17 repaired the wiring, but did not repair the vapor fuel tank hose per Plaintiff’s 18 request. 19 documenting the charges and the work performed is attached hereto as Exhibit 2; 20 and a copy of the invoice from the third-party repair shop is attached hereto as 21 Exhibit 3. 22 13. A copy of the dealership’s service history for Plaintiff’s vehicle Plaintiff began to research this issue of rodents eating vehicle wires; he 23 discovered that he was not alone, other people suffered with the same affliction. It 24 has become so well-known that other automobile manufacturers, such as American 25 Honda Motor Company who also uses soy-based wiring, came out with a special 26 electrical tape that has a capsaicin (the active component of chili peppers) coating 27 meant to deter rodents from eating electrical wiring. He also found numerous 28 5 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 7 of 102 Page ID #:11 1 articles about this issue, which illuminated the fact that some automakers have 2 changed the wiring used in vehicles somewhat recently. 3 14. Defendant is a corporation organized under the laws of the State of 4 California, and has its principle place of business in Torrance, California. Toyota 5 Motor Sales USA, Inc. was established in 1957 as a subsidiary of Toyota Motor 6 Company, a Japanese corporation. Defendant is responsible for injecting Toyota 7 vehicles into the U.S. stream of commerce—a task it performs through a network 8 of thousands of authorized dealers in the United States. Defendant is responsible 9 for the pre-and-post sale marketing of Toyota automobiles throughout the United 10 11 States, as well as the distribution of the same. 15. As alleged supra, Toyota does not cover the damage to its soy-based 12 insulated wiring under its Warranty, despite the fact that Toyota’s warranty provides 13 unambiguously that: 14 “This warranty covers repairs and adjustments needed to correct 15 defects in materials or workmanship of any part supplied by 16 Toyota ...” 17 18 Attached hereto as Ex. 1 [2012 Toyota New Vehicle Limited Warranty], at p.12. 16. Moreover, in preceding introductory sections of its Warranty, Toyota 19 purports to assure consumers that it’s warranty coverage is evidence of a high 20 quality vehicle so as to assure consumer satisfaction when defects in material or 21 workmanship do arise during the warranty’s term: 22 “Our excellent warranty coverage is evidence that we stand 23 behind the quality of our vehicles. We’re confident — as you 24 should be — that your Toyota will provide you with many 25 years of enjoyable driving.” 26 Id., at 4. 27 28 6 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 8 of 102 Page ID #:12 1 17. Of course, Plaintiffs resorted to the very procedures set forth in their 2 Toyota warranty booklet, but received denials at every turn from Toyota. Plaintiff 3 brought his vehicle for repair to a Toyota factory-authorized dealership, but the 4 dealers refused to make the electrical wiring repair under warranty. When Plaintiff 5 brought his vehicle in for the same problem and repair to the same dealership 6 months later and was again refused any warranty coverage, Plaintiff telephonically 7 contacted Toyota’s Automobile Customer Service Center as his warranty booklet 8 had advised. But rather than “assist you in working with the dealership to find a 9 satisfactory solution,” as Toyota’s warranty booklet had assured would happen, 10 Toyota informed Plaintiff Heber that the electrical wiring material defect was not 11 subject to coverage under Toyota’s New Vehicle Limited Warranty. 12 THE DEFECTIVE SOY-BASED ELECTRICAL WIRING AND TOYOTA’S 13 KNOWLEDGE OF THE DEFECT 14 18. Electrical wiring is ubiquitous in modern automobiles, as the wiring is 15 an integral part of the vehicles’ electrical systems that form part of the vehicles’ 16 various systems and components. Until relatively recently, such wiring used to be 17 made from conducting metal, like copper or other metal conductors, and was coated 18 or covered with a plastic or glass-based insulator in the parts of the wire that were 19 not to form electrical connections (usually all the wiring other than its terminal 20 points where connectors were placed to connect two or more wires together). This 21 plastic or glass-based insulation was derived from petroleum. 22 19. More recently, however, a number of car manufacturers, including 23 Defendant, began replacing the insulation covering its vehicles’ wiring with soy- 24 based insulators instead of the traditional plastic insulators. 25 insulated wiring was touted as being more “environmentally friendly” due to, inter 26 alia, the biodegradable nature of the soy-based insulation as compared to the 27 traditional plastic insulation. Upon information and belief, the soy-based insulated 28 7 CLASS ACTION COMPLAINT This soy-based Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 9 of 102 Page ID #:13 1 wiring was also cheaper to manufacture than the previous traditional plastic 2 insulation. No regulation in the United States requires the use of such soy-based 3 insulated wiring. 4 20. Perhaps the foremost function and quality that electrical wiring in an 5 automobile must have is that the wire must remain intact so that the circuitry that the 6 wiring is employed to complete and connect can, indeed, function. Wiring within a 7 circuit that does not remain intact, but that is instead cut or chewed through, results 8 in electrical circuits not being closed or completed and worse yet, in possible arcing 9 or other electrical malfunctions. In either case, the result is that the electrical 10 11 components which the wiring was connecting will fail to operate. 21. The selection of soy-based insulation wiring material, however, was ill- 12 suited to perform its intended function. This is because, unlike the traditional plastic 13 insulation material that had existed in vehicles for many years, the more recent soy- 14 based insulated wiring material had the unintended and undesired consequence of 15 being a material that was highly attractive to rodents and animals—the animals 16 chew through the wiring. The soy-based insulated wiring is, therefore, defective in 17 material, and it results in a defect in material, and it results in a defect in 18 workmanship because the electrical circuits that this wiring was designed to connect 19 to do not end up operating at all or as intended once the soy-based wiring is chewed 20 through. This, in fact, was the very fate suffered by Plaintiff on three separate 21 occasions when the soy-based insulated wiring of his 2012 Toyota Tundra was 22 chewed through, thereby disabling the normal operating and workmanship of the 23 vehicle. 24 22. As Toyota’s Warranty makes expressly clear, that warranty provides 25 for the repair and/or replacement at no charge to the consumer of “materials or 26 workmanship of any part supplied by Toyota, subject to the exceptions indicated 27 under ‘What Is Not Covered’ on pages 13-14.” Exhibit 1, at 12. Despite this clear 28 8 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 10 of 102 Page ID #:14 1 directive, Toyota has taken the position that its Warranty does not cover the repair 2 or replacement of soy-based insulated wiring in its cars that due to its very material, 3 has been chewed through, causing the vehicle to not work as intended. 4 23. The fact that soy-based insulated wiring used in cars poses this defect 5 in material and workmanship is widely known within the automotive industry 6 generally. 7 reported on the fate of car owners across the country whose vehicles were equipped 8 with this soy-based insulated wiring, and as a result, had the wiring chewed through. 9 As that television news report explained: Indeed, by way of example, a television newscast in August 2013, 10 It turns out a number of car brands have wiring that is tasty to 11 rodents, according to Connecticut Watchdog, CarTalk, and a 12 number of automotive blogs. 13 Mechanic Marc Duebber said many automakers have moved to 14 biodegradable, soy-based wiring insulation in the past 10 years. 15 It won’t last forever in landfills, like older plastic wiring. 16 It’s great for the environment, but even better for hungry mice 17 and squirrels. 18 “They are drawn to it, therefore they are chewing and eating it,” 19 Duebber said. “And we are finding nests created in the upper 20 plenums (fresh air intakes).” 21 He showed an air filter that mice recently turned into a nest, 22 using bits of wiring insulation. 23 Attached hereto as Exhibit 4 (WCBO 5 Cleveland News Report entitled 24 “Biodegradable, soy-based wiring insulation in some cars appealing to rodents, 25 causing trouble.”). 26 24. Perhaps most pertinent for purposes of this action, however, is that 27 news report’s additional revelation with respect to another car manufacturer, Honda, 28 9 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 11 of 102 Page ID #:15 1 that uses soy-based insulated wiring for its vehicles. That news report documented 2 that Honda dealerships have begun stocking and selling purportedly mouse-repellent 3 electrical tape to cover the wiring so that it would not be chewed through by 4 rodents: 5 Some automakers are responding. Honda dealers now sell rolls 6 of anti-rodent tape for wires, that can be used on any car, not 7 just Hondas. 8 9 Id. at 3. 25. The very notion that automobile dealers are stocking and selling 10 “mouse deterrent tape” to wrap the soy-based insulated wiring in vehicles in order to 11 prevent further mouse chewing of the soy-based insulated wiring is an 12 acknowledgement of the defective nature of this soy-based insulated wiring material 13 for its intended use. In seeing Honda take this action for similar wiring, Toyota 14 should have made an effort to correct this issue with their own vehicles. 15 26. Even a cursory online search for soy-based insulated wiring in Toyota 16 vehicles reveals a wealth of complaints by owners of Class Vehicles across the 17 country who have suffered the same fate as Plaintiff—having their vehicles’ soy- 18 based wiring chewed through by rodents, and having Toyota refuse to cover the 19 repair under warranty. 20 21 CLASS ACTION ALLEGATIONS 27. Pursuant to Federal Rule of Civil Procedure 23, Plaintiff brings this 22 action as a class action on behalf of himself and all other similarly situated owners 23 and lessees of the Class Vehicles in the United States. With respect to this class 24 action complaint, with Toyota having declared that this soy-based wiring does not 25 prevent a defect in material or workmanship that is subject to coverage under 26 Toyota’s Warranty, and with the prevalence of such wiring being chewed through, 27 all such class members are entitled to a declaratory judgement under the Declaratory 28 10 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 12 of 102 Page ID #:16 1 Judgement Act, 28 U.S.C. §§ 2201 et. seq., that Toyota’s soy-based insulated wiring 2 in its Class Vehicles is, indeed defective in material or workmanship and, therefore, 3 subject to coverage under Toyota’s Warranty. With respect to Counts II and III, 4 seeking, inter alia, monetary relief for Toyota’s breach of its express warranty (the 5 Toyota New Vehicle Limited Warranty) and for Toyota’s violation of the MMA, all 6 class members whose vehicles experienced this chewed wiring and had this damage 7 repaired at a Toyota factory-authorized dealership in the U.S. at the class members’ 8 expense during the term of the warranty, are entitled to monetary relief. 9 10 28. Plaintiff brings this action on behalf of himself and all members of the following classes (the “Classes”) comprised of: 11 a. All persons, exclusive of Defendant and its employees, who 12 purchased one or more of the Class Vehicles sold by Defendant 13 during the Class Period (the “Nationwide Class”). 14 b. All persons, exclusive of Defendants and its employees, who 15 purchased in or from Indiana one or more of the Class Vehicles 16 sold by Defendant during the Class Period (the “Indiana 17 Class”). 18 19 20 29. Plaintiff further reserves the right to seek certification of a different class definition, as discovery or other case circumstances warrant. 30. Although the exact number of class members is presently unknown, 21 Plaintiff is informed and believes that thousands of Class Vehicles have been sold or 22 leased in the United States and all such vehicles are equipped with the soy-based 23 insulated wiring, and all are subject to the New Vehicle Limited Warranty 24 containing the same pertinent language as to defects in material and workmanship 25 that is found in the Toyota warranty covering Plaintiff’s vehicle. Therefore, a class 26 comprising even a fraction of the owners or lessees of the vehicles would readily 27 28 11 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 13 of 102 Page ID #:17 1 satisfy the numerosity requirement for class certification. The members of the class 2 are so numerous that joinder of all members is impracticable. 3 31. Class certification is also appropriate because there is an identifiable 4 class on whose behalf this class action would be prosecuted. Specifically, with 5 respect to Count I, Plaintiff seeks to represent classes of all owners and lessees of 6 the Class Vehicles in the United States. Upon information and belief, all of these 7 vehicles were manufactured with the soy-based insulated wiring that is alleged to be 8 defective. All of these owners and lessees are ascertainable by reference to their 9 ownership records or vehicle registration documentation. Further, with respect to 10 Counts II and III, which seek to provide monetary redress to those class members 11 whose Class Vehicles suffered the chewed soy-based insulated wiring and paid to 12 repair that damage at a Toyota dealership during the term their Warranty was in 13 effect instead of having Toyota cover the repair free of charge under the warranty. 14 These class members are also identifiable and ascertainable based on the repair 15 invoices of Toyota’s factory authorized dealerships. As documented in Plaintiff’s 16 repair orders, the dealerships document in writing Plaintiff’s identifying information 17 and that his Class Vehicle suffered the chewed-through wiring, as well as the 18 payments that Plaintiff made for the repairs, even while his vehicle was said to be 19 covered under Toyota’s New Vehicle Limited Warranty. 20 32. Class certification is also appropriate because there are questions of 21 fact and/or law that are common to the class members, and that predominate over 22 any issues that may affect only individual members of the class. Among these 23 predominating common questions of fact and/or law are: 24 25 a. Whether Defendant is responsible for injecting allegedly defective vehicles into the United States’ stream of commerce; 26 27 28 12 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 14 of 102 Page ID #:18 1 b. Whether the Class Vehicles are equipped with soy-based insulated 2 wiring that amounts to a defect in material or workmanship that is 3 subject to coverage under Toyota’s New Vehicle Limited Warranty; 4 c. Whether Toyota has failed to honor its legal obligation to repair or 5 replace the allegedly defective soy-based insulated wiring in the 6 Class Vehicles as it was required to do under the terms of its New 7 Vehicle Limited Warranty; 8 d. Whether class members are entitled to the relief sought, and if so, 9 10 the proper scope and measure of such relief. 33. Plaintiff’s claims are typical of the claims of the absent class members 11 that claim that they are owners or lessees of a Class Vehicle whose soy-based 12 insulated wiring was defective in material and workmanship, that the defect should 13 have been subject to coverage under Warranty, and such coverage was rejected by 14 Toyota. Plaintiff is a member of the classes he seeks to represent. The claims 15 Plaintiff advances on his own behalf are identical to the claims asserted on behalf of 16 the members of the classes that Plaintiff seeks to represent. 17 34. Plaintiff is an adequate class representative in that, as a member of the 18 classes he seeks to represent, Plaintiff’s interests are entirely aligned with those of 19 the classes. There are no individual conflicts that prevent Plaintiff from adequately 20 representing the classes. Plaintiff has also retained competent counsel experienced 21 in class action litigation. 22 35. Class certification is proper because Toyota has acted or refused to act 23 on grounds generally applicable to the classes. Specifically, Toyota has injected the 24 allegedly defective Class Vehicles into the stream of commerce, but has proclaimed 25 that the alleged defect in material or workmanship of the soy-based insulated wiring 26 in these Class Vehicles is not subject to warranty coverage. Absent a class action, 27 28 13 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 15 of 102 Page ID #:19 1 there would be risk of inconsistent rulings with respect to Toyota’s duties to each of 2 the thousands of putative class members. 3 36. A class action presents a superior form of adjudication over individual 4 litigation. The costs of litigating this action against a large and sophisticated 5 defendant like Toyota in comparison to the recovery of relief sought would make 6 individual litigation impracticable. In addition, forcing individual litigation would 7 risk the result of inconsistent rulings with respect to Toyota’s duties owed to the 8 various vehicle owners and lessees. 9 37. A class action is manageable. The proposed classes represent an 10 identifiable community that can be readily identified, and the relief sought is one 11 that can be overseen by the Court. 12 COUNT I 13 Declaratory Judgment Act 14 (28 U.S.C. §§ 2201(a), et. seq.) 15 (On Behalf of Plaintiff and the Nationwide Class and Against Defendants) 16 38. Plaintiff hereby incorporates by reference each and every allegation of 17 this class action complaint with the same force and effect as if it had been fully 18 restated herein. 19 39. The Class Vehicles owned or leased by Plaintiff and the putative class 20 members all were initially sold or leased with an accompanying express warranty 21 issued by Defendant known as the Toyota New Vehicle Limited Warranty. A copy 22 of that warranty covering Plaintiff’s vehicle, which in all matters pertinent to this 23 action is identical across all Class Vehicles, is attached hereto as Exhibit 1. 24 25 40. The Toyota New Vehicle Limited Warranty provides in pertinent part that: 26 “Repairs and adjustments covered by these warranties are made 27 at no charge for parts and labor.” 28 14 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 16 of 102 Page ID #:20 1 Exhibit 1, at 11. 2 41. All Class Vehicles are equipped with soy-based insulated wiring. For 3 the reasons detailed in this class action complaint, this soy-based insulated wiring is 4 defective in material or workmanship under normal use because soy-based material 5 comprising the wiring or its insulation attracts rodents or other animals that then 6 chew through the wiring. The soy-based material comprising the wiring or its 7 insulations is therefore unfit to achieve the wiring’s purpose, and once chewed 8 through, the wiring fails in its workmanship because it no longer is able to achieve 9 its intended electrical function. 10 42. The soy-based insulated wiring in Plaintiff’s own Class Vehicle 11 experienced this defect in material and workmanship during the term of Toyota’s 12 New Vehicle Limited Warranty. 13 43. Countless other class members have experienced the same fate as 14 Plaintiff in his Class Vehicle, and countless others will experience this same fate 15 during the term of their Toyota New Vehicle Limited Warranty. 16 44. Despite Plaintiff’s experiences, that of countless other class members, 17 and despite the express terms of Toyota’s own New Vehicle Limited Warranty, 18 Toyota has taken the position, over Plaintiff’s objection, that the soy-based insulated 19 wiring in the Class Vehicles does not amount to a defect in material or workmanship 20 that is subject to coverage under Toyota’s New Vehicle Limited Warranty. 21 45. As a result, a real controversy or dispute exists between Plaintiff and 22 the class members, and Defendant, regarding Defendant’s duties and Plaintiff’s and 23 the class members’ rights with respect to obtaining coverage under the New Vehicle 24 Limited Warranty for the allegedly defective soy-based insulated wiring in the Class 25 Vehicles. 26 46. Not only will a determination and declaration of whether the soy-based 27 insulated wiring in the Class Vehicles is subject to coverage under Toyota New 28 15 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 17 of 102 Page ID #:21 1 Vehicle Limited Warranty impact the rights of class members to have their repairs 2 reimbursed or covered by Defendant, but such a determination will also impact the 3 value of each class members’ purchase or lease of a Class Vehicle. An express 4 warranty that, by its own terms, purports to cover defects in material or 5 workmanship, but is then interpreted not to cover soy-based insulated wiring that is 6 alleged to be defective is worth less than an identically worded warranty that is 7 interpreted to cover that allegedly defective soy-based wiring. 8 47. As a result of the controversy and dispute as to warranty coverage 9 between Plaintiff (and the class members) and Defendant, Plaintiff is entitled to and 10 does seek a declaratory judgement as to Plaintiff’s and the class members’ rights to 11 obtain warranty coverage from Defendant under Toyota’s New Vehicle Limited 12 Warranty for any damage, caused by the allegedly defective soy-based insulated 13 wiring in the Class Vehicles. 14 48. Pursuant to 28 U.S.C. § 2202 of the Declaratory Judgement Act, which 15 provides that “[f]urther necessary or proper relief based on a declaratory judgment 16 or decree may be granted, after reasonable notice and hearing, against any adverse 17 party whose rights have been determined by such judgement,” Plaintiff also seeks as 18 part of this Declaratory Judgement Act count, an Order declaring that Plaintiff’s 19 action has conferred a common benefit to the class members entitling Plaintiff and 20 their counsel to an award of attorneys’ costs or fees for conferring the same. 21 COUNT II 22 Breach of Express Warranty 23 (On Behalf of Plaintiff and the Nationwide Class and Against Defendants) 24 49. Plaintiff hereby incorporates by reference each and every allegation of 25 this class action complaint with the same force and effect as if it had been fully 26 restated herein. 27 28 16 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 18 of 102 Page ID #:22 1 50. The Class Vehicles owned or leased by Plaintiff and the putative class 2 members all were initially sold or leased with an accompanying express warranty 3 issued by Defendant known as the Toyota New Vehicle Limited Warranty. A copy 4 of the warranty covering Plaintiff’s vehicle, which in all matters pertinent to this 5 action are identical across all Class Vehicles, is attached hereto as Exhibit 1. 6 7 51. The Toyota New Vehicle Limited Warranty provides in pertinent part that: 8 “This warranty covers repairs and adjustments needed to correct 9 defects in materials or workmanship of any part supplied by 10 Toyota, subject to the exceptions indicated under ‘What Is Not 11 Covered’ on pages 13-14.” 12 Exhibit 1, at 12. 13 52. All Class Vehicles are equipped with soy-based insulated wiring. For 14 the reasons detailed in this class action complaint, this soy-based insulated wiring is 15 defective in material or workmanship under normal use because soy-based material 16 comprising the wiring or its insulation attracts rodents or other animals that then 17 chew through the wiring. The soy-based material comprising the wiring insulation 18 is therefore unfit to achieve the wiring’s purpose, as once chewed through, the 19 wiring fails in its workmanship because it no longer is able to achieve its intended 20 electrical function. 21 53. The soy-based insulated wiring in Plaintiff’s vehicle experienced this 22 defect in material and workmanship during the term of his Warranty. The soy-based 23 material comprising the insulated wiring in Plaintiff’s vehicle attracted rodents or 24 other animals that chewed through the wiring, leaving them partially inoperable 25 during the term of his Warranty. 26 27 28 17 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 19 of 102 Page ID #:23 1 54. Countless other class members have experienced the same fate as 2 Plaintiff in his Class Vehicle, and countless others will experience this same fate 3 during the term of their Toyota New Vehicle Limited Warranty. 4 55. Despite Plaintiff’s experiences and that of countless class members and 5 the express terms of Toyota’s own New Vehicle Limited Warranty, Toyota has 6 taken the position, over Plaintiff’s objection, that the soy-based insulated wiring in 7 the Class Vehicles does not amount to a defect in material or workmanship that is 8 subject to coverage under Toyota’s Warranty. Plaintiff, therefore, was charged and 9 paid for the repairs or replacements of the allegedly defective soy-based insulated 10 wiring in his vehicle that was chewed through by a rodent or animal and that, 11 therefore, left it inoperable or not running as intended. This, despite the fact, that 12 when this problem initially arose and Plaintiff brought his vehicle for repairs to a 13 Toyota factory-authorized dealership, the vehicles were within the age and mileage 14 limits of Toyota’s New Vehicle Limited Warranty. 15 56. Toyota’s failure to cover under warranty the repairs or replacements of 16 the allegedly defective soy-based insulated wiring when Plaintiff’s vehicle was 17 presented to a Toyota dealership for such repair during the term of the warranty, 18 amounts to a material breach of Toyota’s obligations under the Toyota New Vehicle 19 Limited Warranty. 20 57. As a direct, proximate, and foreseeable result of Toyota’s material 21 breach of its New Vehicle Limited Warranty, Plaintiff and all class members whose 22 vehicles experienced chewed through soy-based insulated wiring in their cars that 23 were brought for repairs to a Toyota dealership during the term of the warranty but 24 were not afforded coverage for that repair under that warranty were all injured by, 25 inter alia, having had to pay for that repair themselves instead of having that repair 26 made free of charge, as was called for under the Toyota New Vehicle Limited 27 Warranty. 28 18 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 20 of 102 Page ID #:24 1 COUNT III 2 Violation of the Federal Magnuson-Moss Warranty Act 3 (15 U.S.C. §§ 2301, et seq.) 4 (On Behalf of Plaintiff and the Nationwide Class and Against Defendants) 5 58. Plaintiff hereby incorporates by reference each and every allegation of 6 this class action complaint with the same force and effect as if it had been fully 7 restated herein. 8 59. 9 10 11 12 Toyota is a “warrantor” within the meaning of the federal Magnuson- Moss Warranty Act. 60. Plaintiff and each of the putative class members are “consumers” within the meaning of the federal Magnuson-Moss Warranty Act. 61. Toyota has issued a written warranty, known as the Toyota New 13 Vehicle Limited Warranty, applicable to all Class Vehicles when initially sold or 14 leased that has a duration extending to the earlier of 3 years or 36,000 miles 15 covering the Class Vehicles. Through this warranty, Toyota warrants, in pertinent 16 part, that: 17 “This warranty covers repairs and adjustments needed to correct 18 defects in materials or workmanship of any part supplied by 19 Toyota, subject to the exceptions indicated under ‘What Is Not 20 Covered’ on pages 13-14.” 21 Exhibit 1, at 12. 22 62. In fact, contrary to the representations of its New Vehicle Limited 23 Warranty, Toyota has since proclaimed publicly and told Plaintiff that the defect in 24 material or workmanship to the soy-based insulated wiring in the Class Vehicles that 25 is described in this class action complaint (and that Plaintiff experienced) is not 26 subject to coverage under Toyota’s New Vehicle Limited Warranty. 27 28 19 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 21 of 102 Page ID #:25 1 63. Prior to commencing this suit, Plaintiff notified Toyota of the alleged 2 defect by bringing his vehicle to a Toyota-authorized dealership and provided 3 Toyota an opportunity to cover the repairs under the Toyota New Vehicle Limited 4 Warranty, but Toyota repeatedly refused to do so. 5 64. Under 15 U.S.C. § 2310(d)(1), Plaintiff, as a consumer “who [is] 6 damaged by the failure of a supplier, warrantor, or service contractor to comply with 7 any obligation under this chapter, or under a written warranty, implied warranty, or 8 service contract, may bring suit for damages and other legal and equitable relief.” 9 15 U.S.C. § 2310(d)(1). Plaintiff sues pursuant to this section to recover monetary 10 damages and for legal and equitable relief on behalf of himself and the class 11 members. 12 65. Likewise, pursuant to 15 U.S.C. § 2310(d)(1), upon prevailing in this 13 action, Plaintiff is entitled to receive an award of attorneys’ fees and expenses and 14 pray for the same. 15 COUNT IV 16 Breach of Implied Warranty 17 (On Behalf of Plaintiff and the Nationwide Class and Against Defendants) 18 66. Plaintiff hereby incorporates by reference each and every allegation of 19 this class action complaint with the same force and effect as if it had been fully 20 restated herein. 21 67. 22 23 Plaintiff purchased the Class Vehicle from one of Toyota’s authorized retailers in the United States. 68. Pursuant to agreements for resale of the Class Vehicles between Toyota 24 and nationwide authorized dealers, Plaintiff and other purchasers of the Class 25 Vehicles are third-party beneficiaries of such contracts. 26 27 28 69. At the time of sale, and currently, Defendant is in the business of manufacturing, distributing and selling the Class Vehicles. 20 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 22 of 102 Page ID #:26 1 2 3 70. Toyota impliedly warranted that its Class Vehicles were of good and merchantable quality—fit and safe for their ordinary intended use. 71. Defendant knowingly and/or recklessly sold a defective product without 4 conspicuously informing consumers about the design and/or manufacturing defects 5 in the Class Vehicles manufactured, distributed and/or sold by Toyota to dealerships 6 throughout the United States. Defendant possessed actual, superior knowledge of 7 the Class Vehicles’ defective soy-based insulation wiring based on consumer 8 complaints, Toyota’s customer service representatives, and internal investigations. 9 72. Defendant’s waiver and/or limits on implied warranties are 10 unconscionable and unenforceable since Plaintiff and the class members had no 11 meaningful choice in determining those time limitations, the warranties are written 12 by Defendant without input from consumers, a gross disparity in bargaining power 13 exists as between Defendant and Plaintiff and class members, and class members 14 had no way of knowing the unilateral limitations placed on the implied warranty by 15 Defendant until they had already purchased the Class Vehicles. Defendant knew or 16 should have known that the Class Vehicles were defective at the time of sale and 17 have a propensity to fail before the warranty period lapses, and Plaintiff and class 18 members were unfairly surprised by the concealment of the material facts of the 19 defects relating to the soy-based wiring insulation. 20 73. Plaintiff and class members’ Class Vehicles became unfit for their 21 ordinary purpose of safely performing during the implied warranty period and posed 22 a safety concern to consumers and the public. 23 74. The inherent design/manufacturing defects in the Class Vehicles existed 24 when they left Defendant’s and its authorized dealers’ possession and renders the 25 Class Vehicles unfit for their intended use and purpose. 26 75. As a direct and proximate result of Defendant's breach of its implied 27 warranty, Plaintiff and class members have sustained damages and other losses in an 28 21 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 23 of 102 Page ID #:27 1 amount to be determined at trial. Plaintiff and class members are entitled to recover 2 legal and equitable relief against Defendant, including damages, attorneys’ fees, 3 litigation costs and other relief provided by law and that the Court deems proper. 4 COUNT V 5 Indiana Deceptive Consumer Sales Act 6 (IC 24-5-0.5-1, et seq.) 7 (On Behalf of the Indiana Plaintiff and the Indiana Class and Against 8 Defendants) 9 76. Plaintiff hereby incorporates by reference each and every allegation of 10 this class action complaint with the same force and effect as if it had been fully 11 restated herein. 12 77. This cause of action is brought pursuant to the Indiana Deceptive 13 Consumer Sales Act (the “IDCSA”), which allows a person to bring an action for 14 damages from “relying upon an uncured or incurable deceptive act.” IC 24-5-0.5- 15 4(a). Additionally, the IDCSA expressly allows persons damaged by a “deceptive 16 act” to bring a class action. IC 24-5-0.5-4(b). 17 78. The IDCSA defines a “deceptive act” as when a supplier commits an 18 “unfair, abusive, or deceptive act, omission, or practice in connection with a 19 consumer transaction” whether such conduct occurred before, during, or after the 20 transaction. IC 24-5-0.5-3(a). Further, deceptive acts “include both implicit and 21 explicit misrepresentations.” Id. The IDCSA enumerates some “representations as 22 to the subject matter of the consumer transaction, made orally, in writing, or by 23 electronic communication, by a supplier” that are considered per se deceptive acts. 24 IC 24-5-0.5-3(b) (emphasis added). Pertinent here are the following deceptive acts 25 which Defendant has violated: 26 27 28 IC 24-5-0.5-3(b)(1): That such subject of a consumer transaction has sponsorship, approval, performance, characteristics, accessories, uses, or benefits it does not have which the supplier knows or should reasonably know 22 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 24 of 102 Page ID #:28 1 it does not have. 2 IC 24-5-0.5-3(b)(2): That such subject of a consumer transaction is of a particular standard, quality, grade, style, or model, if it is not and if the supplier knows or should reasonably know that it is not. 3 4 5 6 7 IC 24-5-0.5-3(b)(8): That such consumer transaction involves or does not involve a warranty, a disclaimer of warranties, or other rights, remedies, or obligations, if the representation is false and if the supplier knows or should reasonably know that the representation is false. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 79. Defendant represents in its Warranty that it is “dedicated to building products of the highest quality and reliability.” Exhibit 1, at 4. Defendant represents that its “excellent warranty coverage is evidence that [Toyota] stand[s] behind the quality of our vehicles.” Id. Defendant further represents that it is confident that its Toyotas will provide its customers “with many years of enjoyable driving.” Id. But Defendant sold Class Vehicles to Plaintiff and the Indiana Class that did not have the performance, characteristics, uses, benefits or quality that Defendant represented its Class Vehicles had. Instead, Defendant sold to Plaintiff and members of the Indiana Class vehicles with soy-based wiring which were and continue to be chewed through by rodents. This defect is incurable and cannot be remedied unless Defendant replaces the wiring with a non-soy-based wiring that will not attract rodents. Defendant has and will continue to refuse to replace this defective wiring because it contends that the defect is not covered by the Warranty. 80. In addition, Defendant issued an express warranty to Plaintiff and members of the Indiana Class agreeing to repair—at Toyota’s expense—“defects in materials or workmanship” in the Class Vehicles. As alleged supra, the soybased wiring utilized in the Class Vehicles is a defect and should have been covered under Toyota’s Warranty. Defendant, however, has refused and continues to cover the defect under the Warranty. Defendant also did not exclude the defect relating to 23 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 25 of 102 Page ID #:29 1 the soy-based wiring under the exclusion portion of the Warranty. 2 Defendant has breached its express warranty and has misled and deceived 3 consumers about the scope of its Warranty. Defendant has engaged in multiple 4 deceptive acts in violation of the IDCSA. 5 injunctive relief and monetary damages against Defendants pursuant to the IDCSA, 6 §§ 2 and 4. 7 81. Therefore, Therefore, Indiana Plaintiff seek both As a result, Plaintiff and members of the Indiana Class have suffered 8 irreparable harm. Plaintiff and the other Indiana Class members’ injuries were 9 proximately caused by Defendant’s conduct as alleged herein. Plaintiff, individually 10 and on behalf of all other Indiana Class members, seeks an award of damages for 11 Defendant’s willful violations of the IDCSA § 2, costs and attorneys’ fees, and such 12 other relief as deemed appropriate and proper by the Court. 13 14 15 16 PRAYER FOR RELIEF WHEREFORE, Plaintiff and the class members pray for judgement against Defendant as follows: A. That the Court determine that this action may be litigated as a class 17 action, and that Plaintiff and his counsel be appointed class 18 representatives and class counsel, respectively; 19 B. 20 21 That judgement be entered against Defendant and in favor of Plaintiff and the class members on all counts; C. That Defendant be ordered to bear the cost of notifying the absent class 22 members of this class action, and of the class members’ rights 23 respecting the same; 24 D. That Defendant be ordered to pay the actual damages and losses 25 sustained by Plaintiff and the class members, as well as any and all 26 statutory damages that Plaintiff and the class members are entitled to 27 under law; 28 24 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 26 of 102 Page ID #:30 1 E. That the Court order the creation of a common fund from which 2 Plaintiff and his counsel shall be awarded their reasonable costs of suit, 3 including reasonable attorneys’ fees and expenses incurred in 4 prosecuting this class action and in conferring a common benefit upon 5 the class members; 6 F. That the Court enter a Declaratory Judgement ordering and 7 adjudicating with finality that the alleged defect in the soy-based 8 insulated wiring in the Class Vehicles that is alleged in this class action 9 complaint is subject to coverage under Defendant’s New Vehicle 10 Limited Warranty; 11 G. That as part of its Declaratory Judgement, the Court adjudicate that 12 Plaintiff and his counsel have conferred a common benefit to the class 13 members, entitling them to an award of attorneys’ fees and costs for 14 prosecuting this action, and awarding such fees and costs to Plaintiff’s 15 counsel to be paid by Defendant; 16 H. 17 That Plaintiff and the class members be awarded all such other relief as this Court deems just and proper. 18 19 20 21 22 23 24 25 /// 26 /// 27 /// 28 25 CLASS ACTION COMPLAINT Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 27 of 102 Page ID #:31 1 2 JURY DEMAND Plaintiff respectfully requests a trial by jury on all claims and causes of action 3 properly triable before a jury. 4 Dated: August 16, 2016 5 6 7 8 9 10 11 12 13 14 15 16 BISNAR CHASE LLP By: /s/ Jerusalem F. Beligan BRIAN D. CHASE bchase@bisnarchase.com JERUSALEM F. BELIGAN jbeligan@bisnarchase.com 1301 Dove Street, Suite 120 Newport Beach, CA 92660 Telephone: 949/752-2999 Facsimile: 949/752-2777 KABATECK BROWN KELLNER BRIAN S. KABATECK bsk@kbklawyers.com LINA MELIDONIAN lm@kbklawyers.com DREW R. FERRANDINI df@kbklawyers.com Engine Company No. 28 Building 644 South Figueroa Street Los Angeles, CA 90017 Telephone: 213/217-5000 Facsimile: 213/217-5010 17 18 19 20 21 22 23 24 25 26 27 28 26 CLASS ACTION COMPLAINT Docum?ntS 'Filed 08/18/16 Page 28 of 102 Page ID #:32 Exhibit 1 Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 29 of 102 Page ID #:33 If your name or address has changed or you purchased your Toyota as a used vehicle, please complete and mail the attached card, even if your warranty coverage has expired. This will enable Toyota to contact you with important product or safety updates concerning your vehicle. If the card is no longer attached, please call the Toyota Customer Experience Center at (800) 331-4331. Mr. – Mrs. First name City Ms. – Primary phone number Miss Dr. M.I. Company name Street address or P.O. Box Mo. Last name / Zip code – / EVV Year Apt. or suite number Check here if address below is for company Day New owner, purchased vehicle used – Effective date of this information State Alternate phone number – Same owner, additional driver who should receive product/safety updates Same owner, name and/or address has changed Owner Information Change Form MAINTENANCE GUIDE Vehicle Identification Number (required to process change) Check one: warranty & This information is obtained solely for the use of Toyota Motor Sales, U.S.A., Inc. E-mail address 2 0 1 2 Toyota occasionally sends special promotional offers to registered owners. Check here if you prefer not to receive these offers. 8/5/11 4:12 PM 124757_11-TCS-04845_WMG_Tundra.indd 1 00505-12WMG-TUN Printed in U.S.A. 8/11 11-TCS-04845 tundra www.toyota.com 8:16-cv-01525-AG-JCG JOBNAME: Case 934392-2012-tunWG-EN PAGE: 1 SESS:Document 12 OUTPUT:3Fri Filed Aug 5 08/18/16 09:25:45 2011Page /tweddle/toyota/sched-maint/934392-en-tun/wg 30 of 102 Page ID #:34 Welcome to the Toyota Family 2012 (TUN) 2012 (TUN) hank you for purchasing a Toyota vehicle. We know you have many options when considering which vehicle to buy, and we appreciate your decision to select Toyota. T For more information about our vehicles, our company or the products and services available for your vehicle, please visit Toyota’s official Web site, www.toyota.com. We want you to enjoy owning your Toyota as much as you enjoy driving it. This booklet is designed to help. Here you’ll find information on Toyota’s warranty coverage and maintenance recommendations for your vehicle. There are two easy-to-follow sections: one for warranty and one for maintenance. The tab on the side of each page identifies the section you are in. We wish you many miles of safe and pleasurable driving, and we look forward to serving you in the years ahead. Welcome to the Toyota family! 1 8:16-cv-01525-AG-JCG JOBNAME: Case 934392-2012-tunWG-EN PAGE: 2 SESS:Document 12 OUTPUT:3Fri Filed Aug 5 08/18/16 09:25:45 2011Page /tweddle/toyota/sched-maint/934392-en-tun/wg 31 of 102 Page ID #:35 Table of Contents WARRANTY INFORMATION Introduction Satisfaction Down the Road 4 The Immobilizer Key 5 Transportation Assistance 7 If You Need Assistance Warranty Coverages at a Glance 8 10 Your Warranties in Detail General Warranty Provisions 11 New Vehicle Limited Warranty 12 Federal Emission Control Warranty 16 California Emission Control Warranty 22 Tire Limited Warranty 28 Your Responsibilities Operation and Maintenance 29 Obtaining Warranty Service 31 2 8:16-cv-01525-AG-JCG JOBNAME: Case 934392-2012-tunWG-EN PAGE: 3 SESS:Document 12 OUTPUT:3Fri Filed Aug 5 08/18/16 09:25:45 2011Page /tweddle/toyota/sched-maint/934392-en-tun/wg 32 of 102 Page ID #:36 Table of Contents MAINTENANCE INFORMATION Introduction The Importance of Scheduled Maintenance 33 Maintaining Your Warranty 34 Maintenance Log Using the Maintenance Log Charts 35 Off-Road Daily Maintenance 37 Maintenance Log 38 Explanation of Maintenance Items 54 Vehicle Identification 58 3 8:16-cv-01525-AG-JCG JOBNAME: Case 934392-2012-tunWG-EN PAGE: 4 SESS:Document 12 OUTPUT:3Fri Filed Aug 5 08/18/16 09:25:45 2011Page /tweddle/toyota/sched-maint/934392-en-tun/wg 33 of 102 Page ID #:37 WARRANTY Satisfaction Down the Road A t Toyota, our top priority is always our customers. We know your Toyota is an important part of your life and something you depend on every day. That’s why we’re dedicated to building products of the highest quality and reliability. Our excellent warranty coverage is evidence that we stand behind the quality of our vehicles. We’re confident — as you should be — that your Toyota will provide you with many years of enjoyable driving. To further demonstrate our commitment to our customers’ satisfaction, occasionally we may establish a special policy adjustment to pay for specific repairs that are no longer covered by warranty. When we establish such a policy adjustment, we mail details to all applicable owners we have on record. That’s why it’s important to send in the card at the back of this booklet if you change your address or if you’ve purchased this vehicle from a previous owner. To provide you with added protection against unexpected service costs, we offer Toyota Extra Care vehicle service agreements and Toyota Auto Care pre-paid maintenance programs. Both offer plans to meet a wide variety of needs. Your dealership can help you select the plan that’s best for you. 4 Introduction Our goal is for every Toyota customer to enjoy outstanding quality, dependability and peace of mind throughout their ownership experience. We want you to be a satisfied member of the Toyota family for many miles to come. Pages 5–31 of this booklet describe the terms of Toyota warranty coverage as well as general owner responsibilities. The scheduled maintenance section describes your vehicle’s maintenance requirements. Be sure to review this information carefully, since proper maintenance is required to ensure that warranty coverage remains intact. All information in this booklet is the latest available at the time of publication and, with the exception of the emission control warranties, is subject to change without notice. 8:16-cv-01525-AG-JCG JOBNAME: Case 934392-2012-tunWG-EN PAGE: 5 SESS:Document 12 OUTPUT:3Fri Filed Aug 5 08/18/16 09:25:45 2011Page /tweddle/toyota/sched-maint/934392-en-tun/wg 34 of 102 Page ID #:38 The Immobilizer Key THE NEW WORLD OF ANTI-THEFT TECHNOLOGY For security purposes, access to key codes and service procedures for electronically registering replacement keys is restricted. Only a Toyota dealer or certain bonded/registered independent locksmiths can generate replacement keys. Introduction 5 WARRANTY This Toyota vehicle may be equipped with an electronic “immobilizer” anti-theft system. When the key is inserted into the ignition switch it transmits an electronic code to an immobilizer computer. The engine will only start if the code in the key matches the code in the immobilizer. If the code does not match, the immobilizer disables the ignition and fuel systems. While an exact physical copy of the key will open the door and allow retrieval of items locked in the vehicle, it won’t start the vehicle unless the key has the same code as the immobilizer. SECURITY 8:16-cv-01525-AG-JCG JOBNAME: Case 934392-2012-tunWG-EN PAGE: 6 SESS:Document 12 OUTPUT:3Fri Filed Aug 5 08/18/16 09:25:45 2011Page /tweddle/toyota/sched-maint/934392-en-tun/wg 35 of 102 Page ID #:39 WARRANTY The Immobilizer Key REPLACING THE KEY KEEPING THE KEY SAFE Upon purchase, each vehicle should have two master keys, one valet key and an aluminum tag with a key-code imprinted on it. Replacing an immobilizer key may be costly. It is advisable to keep a spare master key and the aluminum key-code tag in a safe place. If you record the key-code in more than one place, do not record it in a way that can be easily identified and associated with the vehicle. For example, don’t leave the code somewhere that can be accessed by a valet. It is wise to keep a copy of the key-code outside of the vehicle. To generate a fully functional replacement key (one that will both open the doors and start the engine), one of the master keys is required. To make a key that will open the door for retrieval of items locked inside the vehicle, the valet key or aluminum key-code tag can be used. If a master key or the aluminum key-code tag is not available, a Toyota dealer or certain registered locksmiths can obtain the key code from a restricted-access database. These businesses can also access a service utility to reprogram the immobilizer if all registered master keys have been lost. If a Toyota dealer is not available, please refer to www.aloa.org to find a bonded/registered locksmith who performs high security key service. 6 Introduction If the vehicle was delivered with less than all three keys and the aluminum key-code tag, consider having the Toyota dealer or a qualified independent automotive locksmith make a duplicate key before you need it. 8:16-cv-01525-AG-JCG JOBNAME: Case 934392-2012-tunWG-EN PAGE: 7 SESS:Document 12 OUTPUT:3Fri Filed Aug 5 08/18/16 09:25:45 2011Page /tweddle/toyota/sched-maint/934392-en-tun/wg 36 of 102 Page ID #:40 Transportation Assistance Under this policy, you are eligible for transportation assistance if your Toyota must be kept overnight for warranty-covered repairs. The policy applies when your vehicle must be kept overnight for any of the following reasons: The policy does not apply when warranty repairs can be completed in one day but the vehicle must be kept overnight due to dealer or owner scheduling conflicts. The Transportation Assistance Policy applies for the duration of the New Vehicle Limited Warranty. The policy applies to all 2012 model-year Toyotas sold and serviced by authorized Toyota dealerships in the mainland United States and Alaska. For further details, please consult your Toyota dealer. • The warranty repairs will take longer than one day to complete. • The warrantable condition requires extensive diagnosis. • The parts needed for the warranty repairs are not readily available and your vehicle is inoperative or unsafe to drive. Introduction 7 WARRANTY W e realize that your confidence in the quality and reliability of our products was a key factor in your decision to buy a Toyota. We also know how disruptive the loss of transportation can be to your daily routine. That’s why we’re pleased to offer you the benefits of our Transportation Assistance Policy. 8:16-cv-01525-AG-JCG JOBNAME: Case 934392-2012-tunWG-EN PAGE: 8 SESS:Document 12 OUTPUT:3Fri Filed Aug 5 08/18/16 09:25:45 2011Page /tweddle/toyota/sched-maint/934392-en-tun/wg 37 of 102 Page ID #:41 WARRANTY If You Need Assistance B oth Toyota and your Toyota dealer are dedicated to serving your automotive needs. Your complete satisfaction is our first priority. Should you have a problem or concern — either during or after the warranty period — please take the following steps to ensure the quickest possible response: Step 1 Discuss the situation with a dealership manager, such as the service manager or customer relations manager. In most cases, a satisfactory solution can be reached at this step. Step 2 If the dealership does not address your concern to your satisfaction, call the Toyota Customer Experience Center at (800) 331-4331. Please have the following information ready when you call: • Your Toyota’s vehicle identification number (located on the driver’s side corner of the dashboard, under the window) • Current mileage on your vehicle • Name of your Toyota dealership A Toyota customer relations representative will assist you in working with the dealership to find a satisfactory solution. 8 Introduction Step 3 If your concern has still not been resolved to your satisfaction, Toyota offers additional assistance through the Dispute Settlement Program, a dispute resolution program administered by the National Center for Dispute Settlement. The purpose of the Dispute Settlement Program is to resolve disputes through arbitration — a process by which two parties authorize an independent third party to hear and resolve a dispute. The program is informal and free of charge. To request that your case be reviewed through the program, complete the customer claim form in the Owner’s Warranty Rights Notification booklet (found in your glove box) and mail it to: National Center for Dispute Settlement P.O. Box 688 Mt. Clemens, MI 48046 If you would like to request a customer claim form, call the Toyota Customer Experience Center at (800) 331-4331. When you call, please have your vehicle identification number, the current mileage on your Toyota and the names of your selling and servicing dealerships. 8:16-cv-01525-AG-JCG JOBNAME: Case 934392-2012-tunWG-EN PAGE: 9 SESS:Document 12 OUTPUT:3Fri Filed Aug 5 08/18/16 09:25:45 2011Page /tweddle/toyota/sched-maint/934392-en-tun/wg 38 of 102 Page ID #:42 If You Need Assistance This information about the Dispute Settlement Programs is correct as of the date of printing. However, the programs may be changed without notice. For the most current information about the programs, call the Toyota Customer Experience Center at (800) 331-4331. WARRANTY California residents: Toyota offers you assistance through an arbitration program called the California Dispute Settlement Program (CDSP). A brochure about the program is found in your glove box. For additional information, call the Toyota Customer Experience Center at (800) 331-4331. You may also contact the CDSP directly at (888) 300-6237. Failure to use the CDSP may affect your rights and remedies under California’s “Lemon Laws.” Important: You must use the Dispute Settlement Program (or, in California, the CDSP) before seeking remedies through a court action pursuant to the Magnuson-Moss Warranty Act. You may also be required to use the Dispute Settlement Program or CDSP before seeking remedies under the “Lemon Laws” of your state. Please check the appropriate page of the Owner’s Warranty Rights Notification booklet for the requirements applicable to your state. Introduction 9 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 10 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg WARRANTY Warranty Coverages at a Glance 10 Introduction 39 of 102 Page ID #:43 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 11 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 40 of 102 Page ID #:44 General Warranty Provisions Repairs Made at No Charge The warrantor for these limited warranties is Toyota Motor Sales, U.S.A., Inc. (“Toyota”), 19001 South Western Avenue, Torrance, California 90509-2991, a California corporation. Repairs and adjustments covered by these warranties are made at no charge for parts and labor. Which Vehicles Are Covered These warranties apply to all 2012 model year Tundra vehicles distributed by Toyota that are originally sold by an authorized dealer in the United States and normally operated or touring in the United States, U.S. territories or Canada. Warranty coverage is automatically transferred at no cost to subsequent vehicle owners. Multiple Warranty Conditions This booklet contains warranty terms and conditions that may vary depending on the part covered. A warranty for specific parts or systems, such as the Powertrain Warranty or Emission Performance Warranty, is governed by the coverage set forth in that warranty as well as the General Warranty Provisions. When Warranty Begins The warranty period begins on the vehicle’s in-service date, which is the first date the vehicle is either delivered to an ultimate purchaser, leased, or used as a company car or demonstrator. Parts Replacement Any needed parts replacement will be made using new or remanufactured parts. The decision whether a part should be repaired or replaced will be made by the servicing Toyota dealership and/or Toyota. Parts scheduled to be replaced as required maintenance are warranted until their first replacement only. Limitations The performance of necessary repairs and adjustments is the exclusive remedy under these warranties or any implied warranties. Toyota does not authorize any person to create for it any other obligation or liability in connection with this vehicle. Any implied warranty of merchantability or fitness for a particular purpose is limited to the duration of these written warranties. Some states do not allow restrictions on how long an implied warranty lasts, so this limitation may not apply to you. Your Rights Under State Law These warranties give you specific legal rights. You may also have other rights that vary from state to state. Your Warranties in Detail 11 WARRANTY Who Is the Warrantor 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 12 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 41 of 102 Page ID #:45 New Vehicle Limited Warranty WARRANTY WHAT IS COVERED AND HOW LONG Basic Warranty Transmission and Transaxle This warranty covers repairs and adjustments needed to correct defects in materials or workmanship of any part supplied by Toyota, subject to the exceptions indicated under “What Is Not Covered” on pages 13-14. Case and all internal parts, torque converter, clutch cover, transmission mounts, transfer case and all internal parts, engine control computer, seals and gaskets. Coverage is for 36 months or 36,000 miles, whichever occurs first, with the exception of wheel alignment and wheel balancing, which are covered for 12 months or 20,000 miles, whichever occurs first. Powertrain Warranty This warranty covers repairs needed to correct defects in materials or workmanship of any component listed below and in the next column and supplied by Toyota, subject to the exceptions indicated under “What Is Not Covered” on pages 13-14. Coverage is for 60 months or 60,000 miles, whichever occurs first. Engine Cylinder block and head and all internal parts, timing gears and gaskets, timing chain/belt and cover, flywheel, valve covers, oil pan, oil pump, engine mounts, turbocharger housing and all internal parts, supercharger housing and all internal parts, engine control computer, water pump, fuel pump, seals and gaskets. 12 Your Warranties in Detail Front-Wheel-Drive System Final drive housing and all internal parts, axle shafts, drive shafts, constant velocity joints, front hub and bearings, seals and gaskets. Rear-Wheel-Drive System Axle housing and all internal parts, propeller shafts, U-joints, axle shafts, drive shafts, bearings, supports, seals and gaskets. Restraint Systems Warranty This warranty covers repairs needed to correct defects in materials or workmanship of any seatbelt or air bag system supplied by Toyota, subject to the exceptions indicated under “What Is Not Covered” on pages 13-14. Coverage is for 60 months or 60,000 miles, whichever occurs first. For vehicles sold and registered in the state of Kansas, the warranty for seatbelts and related components is 10 years, regardless of mileage. 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 13 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 42 of 102 Page ID #:46 New Vehicle Limited Warranty WHAT IS NOT COVERED Corrosion Perforation Warranty Coverage is for 60 months, regardless of mileage. For information on how to protect your vehicle from corrosion, see the section entitled “Corrosion Prevention and Appearance Care” in the Owner’s Manual. Towing When your vehicle is inoperable due to failure of a warranted part, towing service to the nearest authorized Toyota dealership is covered. • Fire, accidents or theft • Abuse or negligence • Misuse — for example, racing or overloading • Improper repairs • Alteration or tampering, including installation of non-Genuine Toyota Accessories • Lack of or improper maintenance, including use of fluids other than those specified in the Owner’s Manual • Installation of non-Genuine Toyota Parts • Airborne chemicals, tree sap, road debris (including stone chips), rail dust, salt, hail, floods, wind storms, lightning and other environmental conditions • Water contamination This warranty also does not cover the following: Tires Tires are covered by a separate warranty provided by the tire manufacturer. See page 28. Normal Wear and Tear Noise, vibration, cosmetic conditions and other deterioration caused by normal wear and tear. Your Warranties in Detail 13 WARRANTY This warranty covers repair or replacement of any original body panel that develops perforation from corrosion (rust-through), subject to the exceptions indicated under “What Is Not Covered” on pages 13-14. This warranty does not cover damage or failures resulting directly or indirectly from any of the following: 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 14 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 43 of 102 Page ID #:47 WARRANTY New Vehicle Limited Warranty Maintenance Expense Incidental Damages Normal maintenance services such as: Incidental or consequential damages associated with a vehicle failure. Such damages include but are not limited to inconvenience; the cost of transportation, telephone calls and lodging; the loss of personal or commercial property; and the loss of pay or revenue. • Engine tune-ups • Replacement of fluids and filters • Lubrication • Cleaning and polishing • Replacement of spark plugs and fuses • Replacement of worn wiper blades, brake pads/linings and clutch linings Vehicles With Altered Odometer Failure of a vehicle on which the odometer has been altered so that actual vehicle mileage cannot be readily determined. Salvage or Total-Loss Vehicles Any vehicle that has ever been issued a “salvage” title or similar title under any state’s law; or has ever been declared a “total loss” or equivalent by a financial institution or insurer, such as by payment for a claim in lieu of repairs because the cost of repairs exceeded the cash value of the vehicle. This exclusion does not apply to the emission control warranties. 14 Your Warranties in Detail Disclaimer of Extra Expenses and Damages The performance of necessary repairs and adjustments is the exclusive remedy under this warranty or any implied warranty. Toyota does not authorize any person to create for it any other obligation or liability in connection with this vehicle. Toyota shall not be liable for incidental or consequential damages resulting from breach of this written warranty or any implied warranty. Any implied warranty of merchantability or fitness for a particular purpose is limited to the duration of this written warranty, except in states where this limitation is not allowed. 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 15 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 44 of 102 Page ID #:48 New Vehicle Limited Warranty DISPUTE RESOLUTION WARRANTY If a dispute arises regarding your warranty coverage, please follow the steps described under “If You Need Assistance” on pages 8-9. Please note that you must use the Dispute Settlement Program (or, in California, the CDSP) before seeking remedies through a court action pursuant to the Magnuson-Moss Warranty Act. You may also be required to use the Dispute Settlement Program or CDSP before seeking remedies under the “Lemon Laws” of your state. Please check the appropriate page of the Owner’s Warranty Rights Notification booklet (located in your glove box) for the requirements applicable to your state. Your Warranties in Detail 15 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 16 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 45 of 102 Page ID #:49 Federal Emission Control Warranty WARRANTY WHAT IS COVERED AND HOW LONG Emission Defect Warranty Emission Performance Warranty Toyota warrants that your vehicle: Some states and localities have established vehicle inspection and maintenance (I/M) programs to encourage proper vehicle maintenance. If an EPA-approved I/M program is in force in your area, you are eligible for Emission Performance Warranty coverage. • Was designed, built and equipped to conform at the time of sale with applicable federal emissions standards. • Is free from defects in materials and workmanship that may cause the vehicle to fail to meet these standards. Federal regulations require that this warranty be in effect for two years or 24,000 miles from the vehicle’s in-service date, whichever occurs first. However, under the terms of the Basic Warranty, Toyota provides coverage of three years or 36,000 miles, whichever occurs first. Specific components may have longer coverage under the terms of the Powertrain Warranty. Additionally, components marked “8/80” in the parts list on pages 17–18 have coverage of eight years or 80,000 miles, whichever occurs first. 16 Your Warranties in Detail Under the terms of the Emission Performance Warranty and federal regulations, Toyota will make all necessary repairs if both of the following occur: • Your vehicle fails to meet applicable emissions standards as determined by an EPA-approved emissions test. • This failure results or will result in some penalty to you — such as a fine or denial of the right to use your vehicle — under local, state or federal law. This warranty is in effect for two years or 24,000 miles from the vehicle’s in-service date, whichever occurs first. Additionally, components marked “8/80” in the parts list on pages 17–18 have coverage of eight years or 80,000 miles, whichever occurs first. 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 17 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 46 of 102 Page ID #:50 Federal Emission Control Warranty WARRANTY PARTS LIST These warranty obligations do not apply to failures or noncompliance caused by: Air Conditioning System • The use of replacement parts not certified in accordance with aftermarket parts certification regulations. • Condenser • The use of replacement parts not equivalent in quality or design to original equipment parts. Air/Fuel Metering System Provisions under the “What Is Not Covered” section of the New Vehicle Limited Warranty also apply to this warranty. • Deceleration control system • Compressor • Evaporator • Associated Parts • Air/fuel ratio feedback control system • Cold-start enrichment system • Electronic fuel injection system components – Airflow sensor – Engine control module (8/80) – Throttle body – Other components Air Induction System • Intake manifold and intake air surge tank Catalyst System • Catalytic converter and protector (8/80) • Constricted fuel filler neck • Exhaust manifold • Exhaust pipe (manifold to catalyst and/or catalyst to catalyst) Evaporative Control System • Charcoal canister • Diaphragm valve • Fuel filler cap • Fuel tank • Vapor liquid separator 8/80 = Covered for eight years or 80,000 miles, whichever occurs first. Your Warranties in Detail 17 WARRANTY WHAT IS NOT COVERED 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 18 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 47 of 102 Page ID #:51 Federal Emission Control Warranty MAINTENANCE WARRANTY Exhaust Gas Recirculation (EGR) System • EGR gas temperature sensor • EGR valve • Associated parts Ignition System • Distributor and internal parts • Ignition coil and ignitor • Ignition wires • Spark plugs* Positive Crankcase Ventilation (PCV) System • Oil filler cap • PCV valve or orifice Other Parts Used in Above Systems You are responsible for performance of the required maintenance indicated in the Owner’s Manual and this booklet. Toyota will not deny a warranty claim solely because you do not have records to show that you maintained your vehicle. However, any failure or noncompliance caused by lack of maintenance is not covered by this warranty. When maintenance and repairs are paid for by you, these services may be performed by you or by any automotive service provider you choose. Toyota will not deny a warranty claim solely because you used a service provider other than a Toyota dealership for maintenance and repairs. However, any failure or noncompliance caused by improper maintenance or repairs is not covered by this warranty. • Data link connector (8/80) • Hoses, clamps, fittings, tubing and mounting hardware • Malfunction indicator light and bulb (8/80) • Pulleys, belts and idlers • Sealing gaskets and devices • Sensors, solenoids, switches and valves * Warranted until first required maintenance under terms of the California Emission Control Warranty. 8/80 = Covered for eight years or 80,000 miles, whichever occurs first. 18 Your Warranties in Detail 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 19 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 48 of 102 Page ID #:52 Federal Emission Control Warranty REPLACEMENT PARTS Warranty coverage is not dependent upon the use of any particular brand of replacement parts and you may elect to use non-Genuine Toyota Parts for maintenance and repairs. However, use of replacement parts that are not equivalent in quality to Genuine Toyota Parts may impair the effectiveness of the emission control systems. If you use replacement parts that have maintenance or replacement schedules different from those of Genuine Toyota Parts, you must follow the maintenance and replacement schedules for the parts you are using. In addition, you should ensure that such parts are warranted by their manufacturers to be equivalent to Genuine Toyota Parts. If your vehicle fails an EPA-approved emissions test, you may make a claim under the Emission Performance Warranty. To do so, take your vehicle to an authorized Toyota dealership and present a copy of the emissions test report. Also, take your maintenance records in case they are needed. If your claim qualifies for coverage, the dealership will repair your vehicle within 30 days (unless a shorter period is required by law). If your claim is denied, Toyota will notify you in writing of the reason within the same period. If we fail to do so, we will repair your vehicle free of charge. The only exceptions allowed are when you request or agree to a delay, or when a delay is caused by factors beyond the control of Toyota or the dealership. For information on how to obtain service under the Emission Defect Warranty, see page 31, “Obtaining Warranty Service.” Your Warranties in Detail 19 WARRANTY To ensure optimum performance and maintain the quality built into your vehicle’s emission control systems, Toyota recommends the use of Genuine Toyota Parts when servicing or repairing the systems. IF YOUR VEHICLE FAILS AN EMISSIONS TEST 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 20 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 49 of 102 Page ID #:53 Federal Emission Control Warranty WARRANTY IF YOU HAVE QUESTIONS If you have questions or concerns about your federal emission warranty coverage, please refer to “If You Need Assistance” on pages 8-9. In the case of the Emission Performance Warranty, you may also request information from or report complaints to: U.S. Environmental Protection Agency Vehicle Programs & Compliance Division (6405J) Attn: Warranty Complaints 401 M Street SW Washington, D.C. 20460 20 Your Warranties in Detail Vehicles equipped with a California Certified Emission Control System that are sold, registered and operated in California or any state that adopts California emission warranty provisions are also covered by the California Emission Control Warranty (see page 22). Currently, Arizona, Connecticut, Maine, Maryland, Massachusetts, New Jersey, Oregon, Pennsylvania, Rhode Island, Vermont and Washington are the other states to which the California Emission Control Warranty applies. 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 21 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 50 of 102 Page ID #:54 Federal Emission Control Warranty DEALER CERTIFICATE 1) On the basis of written notification furnished by Toyota, we have knowledge that the vehicle is covered by an EPA Certificate of Conformity. 2) We have visually inspected those emission control devices or portions thereof that are visible without removing or adjusting any components or systems, emissions-related or otherwise. On the basis of this inspection, there are no apparent deficiencies in the installation of emission control devices by Toyota. (For purposes of this certificate, “emission control devices” is limited to devices installed on a vehicle for the sole or primary purpose of controlling emissions and which were not in general use before 1968.) 3) We have performed all emission control system preparations required by Toyota prior to the sale of the vehicle as set forth in Toyota’s current pre-delivery service manual. 4) Except as may be provided in Paragraph 5, if this vehicle fails an EPA-approved emissions test within three months or 4,000 miles (whichever comes first) of delivery to the ultimate purchaser, and the vehicle has been maintained and used in accordance with the written instructions for proper maintenance and use, Toyota will remedy the nonconformity free of charge under the terms of the Emission Performance Warranty. 5) If the vehicle was used as a company car or demonstrator, check the box and complete the following: ❑ The vehicle with which this statement is delivered was placed into service as a company car or demonstrator prior to delivery. The Emission Performance Warranty period commenced on the date the vehicle was first placed into service, which was: Month Day Year Note: The dealership makes no representation or warranty that the emission control system or any part thereof is without defect or that the system will perform properly. The Emission Performance Warranty referred to in Paragraph 4 and furnished with the vehicle is solely that of the manufacturer. This statement is required by section 207 of the Clean Air Act (42 U.S.C. 7541) and the EPA regulations issued thereunder. Dealership Name Your Warranties in Detail 21 WARRANTY We (the dealership) want you to know that at the time your new Toyota vehicle is being delivered: 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 22 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 51 of 102 Page ID #:55 California Emission Control Warranty WARRANTY YOUR WARRANTY RIGHTS AND OBLIGATIONS Vehicles equipped with a California Certified Emission Control System that are sold, registered and operated in California or any state that adopts California emission warranty provisions are covered by this warranty. Currently, Arizona, Connecticut, Maine, Maryland, Massachusetts, New Jersey, Oregon, Pennsylvania, Rhode Island, Vermont and Washington are the other states to which this warranty applies. Vehicles covered by this warranty are also covered by the Federal Emission Control Warranty (see page 16). The California Air Resources Board (CARB) and Toyota are pleased to explain the emission control system warranty for your 2012 vehicle. In California, new motor vehicles must be designed, built and equipped to meet the state’s stringent anti-smog standards. CARB regulations require that Toyota must warrant the emission control system on your vehicle for the time periods indicated on the next page, provided there has been no abuse, neglect or improper maintenance of your vehicle. Your emission control system may include parts such as the fuel injection system, ignition system, catalytic converter and engine computer. Also included may be hoses, belts, connectors and other emissions-related assemblies. Where a warrantable condition exists, Toyota will repair your vehicle at no cost to you, including diagnosis, parts and labor. 22 Your Warranties in Detail 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 23 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 52 of 102 Page ID #:56 California Emission Control Warranty OWNER’S WARRANTY RESPONSIBILITIES 1) For three years or 50,000 miles, whichever occurs first: You are responsible for performance of the required maintenance indicated in the Owner’s Manual and this booklet. Toyota recommends that you retain all receipts covering maintenance on your vehicle, but Toyota cannot deny warranty coverage solely for the lack of receipts or your failure to ensure the performance of all scheduled maintenance. • If your vehicle fails a smog-check test, all necessary repairs and adjustments will be made by Toyota to ensure that your vehicle passes the test. This is your Emission Control System PERFORMANCE WARRANTY. • If an emissions-related part listed on pages 17–18 is defective, the part will be repaired or replaced by Toyota. This is your SHORT-TERM Emission Control System DEFECT WARRANTY. Specific components may have longer coverage under the terms of the Powertrain Warranty. 2) For seven years or 70,000 miles, whichever occurs first: • If an emissions-related part listed on page 24 is defective, the part will be repaired or replaced by Toyota. This is your LONG-TERM Emission Control System DEFECT WARRANTY. You are responsible for presenting your vehicle to a Toyota dealership as soon as a problem exists. The warranty repairs should be completed in a reasonable amount of time, not to exceed 30 days. You should also be aware that Toyota may deny you warranty coverage if your vehicle or a part has failed due to abuse, neglect, improper maintenance or unapproved modifications. If you have any questions regarding your warranty rights and responsibilities, you should contact the Toyota Customer Experience Center at (800) 331-4331 or the California Air Resources Board, Mobile Source Control Division, at 9528 Telstar Avenue, P.O. Box 8001, El Monte, CA 91734-8001. Your Warranties in Detail 23 WARRANTY MANUFACTURER’S WARRANTY COVERAGE 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 24 SESS: 13 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 53 of 102 Page ID #:57 California Emission Control Warranty WHAT IS NOT COVERED WARRANTY These warranty obligations do not apply to failures or noncompliance caused by: • The use of replacement parts not certified in accordance with aftermarket parts certification regulations. • The use of replacement parts not equivalent in quality or design to original equipment parts. Provisions under the “What Is Not Covered” section of the New Vehicle Limited Warranty also apply to this warranty. PARTS LIST: LONG-TERM EMISSION DEFECT WARRANTY The parts listed here are covered for seven years or 70,000 miles from the vehicle’s in-service date, whichever occurs first. Air Conditioner System • A/C tube and accessory • Compressor • Condenser • Cooler unit • Front expansion valve no. 1 • Front evaporator Air/Fuel Metering System • Air pump • Engine control computer (engine control module) • Fuel pump • Throttle body Air Induction System • Intake manifold and intake air surge tank Catalyst System • Exhaust front pipe (including catalytic converter) • Exhaust front pipe no. 2 (including catalytic converter) • Exhaust manifold on models equipped with 1UR-FE and 3UR-FE • Exhaust manifold gasket on models equipped with 1UR-FE and 3UR-FE EGR System • EGR cooler on models equipped with 1UR-FE 24 Your Warranties in Detail 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 25 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 54 of 102 Page ID #:58 California Emission Control Warranty MAINTENANCE Evaporative Control System • Fuel tank Ignition System • Knock sensor Other Parts Used in Above Systems • Transmission solenoid When maintenance and repairs are paid for by you, these services may be performed by you or by any automotive service provider you choose. Toyota will not deny a warranty claim solely because you used a service provider other than a Toyota dealership for maintenance and repairs. However, any failure or noncompliance caused by improper maintenance or repairs is not covered by this warranty. Your Warranties in Detail 25 WARRANTY • Charcoal canister You are responsible for performance of the required maintenance indicated in the Owner’s Manual and this booklet. Toyota will not deny a warranty claim solely because you do not have records to show that you maintained your vehicle. However, any failure or noncompliance caused by lack of maintenance is not covered by this warranty. 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 26 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 55 of 102 Page ID #:59 California Emission Control Warranty WARRANTY REPLACEMENT PARTS To ensure optimum performance and maintain the quality built into your vehicle’s emission control systems, Toyota recommends the use of Genuine Toyota Parts when servicing or repairing the systems. Warranty coverage is not dependent upon the use of any particular brand of replacement parts and you may elect to use non-Genuine Toyota Parts for maintenance and repairs. However, use of replacement parts that are not equivalent in quality to Genuine Toyota Parts may impair the effectiveness of the emission control systems. If you use replacement parts that have maintenance or replacement schedules different from those of Genuine Toyota Parts, you must follow the maintenance and replacement schedules for the parts you are using. In addition, you should ensure that such parts are warranted by their manufacturers to be equivalent to Genuine Toyota Parts. 26 Your Warranties in Detail IF YOUR VEHICLE FAILS A SMOG-CHECK TEST If your vehicle fails a smog-check test, you may make a claim under the Emission Performance Warranty. To do so, take your vehicle to an authorized Toyota dealership and present a copy of the smog-check test report. Also, take your maintenance records in case they are needed. If your claim qualifies for coverage, the dealership will repair your vehicle within 30 days (unless a shorter period is required by law). If your claim is denied, Toyota will notify you in writing of the reason within the same period. If we fail to do so, we will repair your vehicle free of charge. The only exceptions allowed are when you request or agree to a delay, or when a delay is caused by factors beyond the control of Toyota or the dealership. For information on how to obtain service under the Emission Defect Warranty, see page 31, “Obtaining Warranty Service.” 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 27 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 56 of 102 Page ID #:60 California Emission Control Warranty IF YOU HAVE QUESTIONS If a Toyota dealership is unable to complete repairs on your vehicle within 30 days, you may have the repairs made under Toyota’s provisions for emergency warranty repairs. See page 31 for details. If you have questions or concerns about your vehicle’s California emission warranty coverage, please follow the steps described under “If You Need Assistance” on pages 8-9. You may also request information from or report complaints to: California Air Resources Board Mobile Source Control Division 9528 Telstar Avenue P.O. Box 8001 El Monte, CA 91734-8001 (800) 242-4450 Your Warranties in Detail 27 WARRANTY REPAIR DELAYS 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 28 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg WARRANTY Tire Limited Warranty OBTAINING WARRANTY SERVICE ORIGINAL EQUIPMENT TIRE MANUFACTURERS The tires that come as original equipment on your vehicle are warranted by their manufacturer and not Toyota. A separate warranty statement for the tires is in your glove box. Bridgestone/Firestone 535 Marriott Drive Nashville, TN 37214 Bridgestone: (800) 847-3272 Firestone: (800) 356–4644 To obtain service for a tire defect, take the tire to an authorized dealer of the tire manufacturer. (Refer to your local phone directory for dealer locations.) Your Toyota dealer may also be able to assist you in obtaining warranty service from the manufacturer. Dunlop Tires 1144 East Market Street Akron, OH 44316 (800) 321-2136 For additional warranty information or service assistance, contact the tire manufacturer directly. 28 Your Warranties in Detail Michelin North America One Park Way South P.O. Box 19001 Greenville, SC 29602 (800) 847–3435 57 of 102 Page ID #:61 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 29 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 58 of 102 Page ID #:62 Operation and Maintenance GENERAL INFORMATION You should keep detailed records of vehicle maintenance, since under some circumstances they may be required for warranty coverage. These records should include date of service, mileage at time of service and a description of service performed and/or parts installed. For your convenience, a maintenance log is included in this booklet. If you sell your vehicle, you should give your maintenance records to the new owner. Toyota will not deny a warranty claim solely because you do not have records to show that you maintained your vehicle. However, damage or failures caused by lack of proper maintenance are not covered under warranty. You may have maintenance performed on your vehicle by any qualified person or facility. However, Toyota recommends having maintenance performed by an authorized Toyota dealership. Toyota dealership technicians are specially trained to maintain and repair Toyota vehicles. They stay current on the latest service information through Toyota technical bulletins, service publications and training courses. Many are also certified through the Toyota Certification Program, which involves a series of rigorous written examinations. Feel free to ask any Toyota dealership to show you their technicians’ credentials. You can be confident you’re getting the best possible service for your vehicle when you take it to a Toyota dealership. Your Responsibilities 29 WARRANTY You are responsible for ensuring that your Toyota is operated and maintained according to the instructions in the Owner’s Manual and this booklet. WHERE TO GO FOR MAINTENANCE 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 30 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg Operation and Maintenance WARRANTY REPLACEMENT PARTS Warranty coverage is not dependent upon the use of any particular brand of replacement parts. However, Toyota recommends using only Genuine Toyota Parts when you need to replace a part on your vehicle. Like all Toyota products, Genuine Toyota Parts are built to the highest standards of quality, durability and performance. They are also designed to fit your vehicle’s exact specifications. Your Toyota dealership maintains an extensive inventory of Genuine Toyota Parts to meet your vehicle service needs. And because it is linked electronically to Toyota’s Parts Distribution Centers, the dealership has quick access to any parts it may not have in stock. Genuine Toyota Parts are covered by their own warranty (see your dealer for details) or the remainder of any applicable New Vehicle Limited Warranty, whichever is longer. Non-Genuine Toyota Parts, or any damage or failures resulting from their use, are not covered by any Toyota warranty. 30 Your Responsibilities 59 of 102 Page ID #:63 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 31 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 60 of 102 Page ID #:64 Obtaining Warranty Service EMERGENCY REPAIRS In the United States, U.S. Territories and Canada If your vehicle is inoperable or unsafe to drive and there is no Toyota dealership reasonably available to make repairs, you may perform the repairs yourself or have them performed by another automotive service provider. Toyota will reimburse you for any of the repairs that are covered by warranty. To receive reimbursement, present to an authorized Toyota dealership your paid repair invoices and any parts that were removed from the vehicle. You will be reimbursed for warranted parts at the manufacturer’s suggested retail price and warranted labor at a geographically appropriate hourly rate multiplied by Toyota’s recommended time allowance for the repair. To obtain warranty service in the United States, U.S. territories or Canada, take your vehicle to an authorized Toyota dealership. If your vehicle cannot be driven, contact your nearest Toyota dealership for towing assistance. You do not have to pay for towing to the nearest Toyota dealership if your vehicle is inoperable due to failure of a warranted part. Outside the United States, U.S. Territories and Canada If you are using your vehicle outside the United States, U.S. territories and Canada and need warranty service, contact a local Toyota dealership. Please note, however, that your vehicle may not be repaired free of charge because the local Toyota distributor may have no obligation to provide warranty service for your vehicle, and/or your vehicle may not comply with local regulatory or environmental requirements. If your vehicle requires emergency repair, Toyota assumes no liability for subsequent failures caused by improper repairs or the use of non-Genuine Toyota Parts unless you have the vehicle properly repaired in a timely manner. To ensure that warranty coverage remains intact, have your vehicle inspected by an authorized Toyota dealership as soon as possible after an emergency repair. Your Responsibilities 31 WARRANTY BY GEOGRAPHIC REGION 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 32 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg WARRANTY Notes 32 Your Responsibilities 61 of 102 Page ID #:65 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 33 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 62 of 102 Page ID #:66 The Importance of Scheduled Maintenance R egular maintenance is essential to obtaining the highest level of performance, safety and reliability from your Toyota. It can also increase your vehicle’s resale value. The following pages are designed to help you make sure your vehicle receives proper and timely maintenance. Along with other important information related to vehicle service, you’ll find factory-recommended maintenance guidelines and a log in which to document your vehicle’s maintenance history. In addition to scheduled maintenance, your vehicle requires ongoing general maintenance such as fluid checks and visual inspections. These procedures are explained in the “Vehicle Maintenance and Care” section of the Owner’s Manual. Be sure to perform these procedures regularly to ensure the most trouble-free operation of your vehicle. With proper maintenance and care, your vehicle will last longer and deliver more dependable, economical performance. Follow this booklet’s recommendations and you’ll enjoy maximum reliability and peace of mind from your Toyota for many years to come. MAINTENANCE Maintenance Log 33 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 34 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 63 of 102 Page ID #:67 Maintaining Your Warranty MAINTENANCE IMPORTANT MAINTENANCE INFORMATION It is especially important to both routinely check your vehicle’s engine oil level (once a month) and regularly replace the engine oil and oil filter (see the Maintenance Log section of this booklet to determine how often you should change your vehicle’s oil and filter). Failure to do so can cause oil starvation and or oil gelling, which can result in severe damage to your vehicle and require costly repairs that are not covered by the New Vehicle Limited Warranty. Maintenance Providers Maintenance Records Your dealer may recommend more frequent maintenance intervals or more maintenance services than those listed in the scheduled maintenance log. These additional services are not required to maintain your warranty coverage. Ask your dealer to explain any recommended maintenance not included in the scheduled maintenance log. Maintaining your vehicle according to the recommendations in this booklet is required to ensure that your warranty coverage remains intact. You should keep detailed records of vehicle maintenance, including date of service, mileage at time of service and a description of service and/or parts installation performed. The scheduled maintenance log in this booklet can help you document this information. If you sell your vehicle, be sure to give your maintenance records to the new owner. Toyota will not deny a warranty claim solely because you do not have records to show that you maintained your vehicle. However, damage or failure caused by lack of proper maintenance are not covered under warranty. 34 Maintenance Log Maintenance and repair services may be performed by you or by any automotive service provider you choose. Toyota will not deny a warranty claim solely because you used a service provider other than a Toyota dealership for maintenance and repairs. However, damage or failure caused by improper maintenance or repairs are not covered under warranty. Dealer-Recommended Maintenance For a complete description of Toyota warranty coverages, see the Warranty Information portion of this booklet. 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 35 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 64 of 102 Page ID #:68 Using the Maintenance Log Charts R egular maintenance is essential to obtaining the highest level of performance from your Toyota. It can also increase your vehicle’s resale value. This booklet presents Toyota’s maintenance recommendations in convenient checklists, so you can easily see what type of maintenance your vehicle needs and document that the work was performed. To ensure that your vehicle receives first-quality service and parts, Toyota recommends having maintenance performed by an authorized Toyota dealership. Toyota dealership technicians are experts on Toyota vehicles, and they use Genuine Toyota Parts designed to your vehicle’s exact specifications. When you go to a Toyota dealership, you can be confident that they will use Genuine Toyota parts and have Toyota-trained technicians. • If at six months you have driven less than 5,000 miles, you should obtain maintenance at six months - don’t wait until 5,000 miles. Be sure to keep an eye on your mileage so that you obtain maintenance when recommended. If you are a low-mileage driver, mark your calendar to remind yourself to obtain maintenance every six months. Documenting Your Investment To help you verify that you’ve invested in proper maintenance, each maintenance checklist includes space for your Toyota dealership to certify that you obtained Genuine Toyota Service for your vehicle. The dealership will mark the dealer service verification area with the following stamp (which may be customized with the dealership’s name): Miles or Months? MAINTENANCE Toyota recommends obtaining scheduled maintenance for your vehicle every 5,000 miles or six months, whichever comes first. For example: • If you drive 5,000 miles in less than six months, you should obtain maintenance at 5,000 miles - don’t wait until six months. Maintenance Log 35 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 36 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 65 of 102 Page ID #:69 Using the Maintenance Log Charts Special Operating Conditions In addition to standard maintenance items, the maintenance log indicates services that should be performed on vehicles that are driven under especially demanding conditions. These “special operating conditions” and their required maintenance items are clearly indicated in each chart. NOTE: You should perform these additional maintenance services only if the majority of your driving is done under the special operating conditions indicated. If you only occasionally drive under these circumstances, it is not necessary to perform the additional services. Engine Oil Selection Please refer to your Owner’s Manual for the specific oil viscosity rating recommended for your vehicle/engine type. MAINTENANCE Additional Maintenance In addition to scheduled maintenance, your Toyota requires ongoing general maintenance such as fluid checks and visual inspections. These procedures are explained in the ⬙Vehicle Maintenance and Care⬙ section of the Owner’s Manual. Be sure to perform these procedures regularly to ensure the most trouble-free operation of your vehicle. 36 Maintenance Log SuperChrome and Alloy Wheel Care If you purchased genuine Toyota accessory Aluminum Alloy Wheels, follow these cleaning guidelines to maintain the appearance of your alloy wheels: • If wheels are hot, wait for them to cool before washing. • Use a soft sponge or cotton cloth to apply the same mild car-wash soap as used for the vehicle body. Quickly rinse off with water. Use a soft cloth to apply the same car wax as used for the vehicle body. • DO NOT USE: Any kind of chemical based cleaners, alcohol, solvents, gasoline, steam cleaners, scouring pads, wire brushes, or coarse abrasives to clean your wheels. 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 37 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 66 of 102 Page ID #:70 Off-Road Daily Maintenance I n addition to the maintenance items indicated for each mileage/month interval, you should perform certain inspections daily when you drive off-road. Whenever you take your vehicle off-road through deep sand, mud or water, perform these inspections every day: • Check ball joints and dust covers • Check brake lines and hoses • Check brake pads/disc • Check differential oil • Check drive shaft boots • Check engine air filter • Check nuts and bolts on chassis and body • Check steering linkage and boots • Check transfer case oil (4WD models) • Check transmission fluid or oil • Lubricate propeller shaft (4WD models) MAINTENANCE Maintenance Log 37 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 38 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 67 of 102 Page ID #:71 Maintenance Log 5,000 miles or 6 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Rotate tires Visually inspect brake linings/drums and brake pads/discs Additional Maintenance Items for Special Operating Conditions 2 10,000 miles or 12 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Replace engine oil and oil filter 1 Rotate tires Visually inspect brake linings/drums and brake pads/discs Additional Maintenance Items for Special Operating Conditions 2 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: MAINTENANCE Replace engine oil and oil filter 1 Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: Replace engine oil and oil filter 1 DEALER SERVICE VERIFICATION: DEALER SERVICE VERIFICATION: DATE: MILEAGE: DATE: MILEAGE: 38 Maintenance Log 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 39 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 68 of 102 Page ID #:72 Maintenance Log 15,000 miles or 18 months Check installation of driver’s floor mat Clean cabin air filter Inspect and adjust all fluid levels Lubricate propeller shaft (4WD) Re-torque propeller shaft bolt Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Inspect the following: __ __ __ __ __ __ __ __ __ __ Ball joints and dust covers Brake lines and hoses Drive shaft boots (4WD) Engine coolant 4 Exhaust pipes and mountings Front differential oil (4WD) Radiator and condenser Rear differential oil Steering gear box Steering linkage and boots Note: Driving in heavy traffic, on dirt roads or in urban, dusty or desert areas may shorten the life of the cabin air filter. Replacement may be needed if you notice reduced air flow from the air conditioner and heater or if the windows fog easily when you use the ⬙Fresh⬙ mode. Consult your dealer if any of these conditions occur. Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect engine air filter Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Replace engine oil and oil filter 1 Replace front differential oil (4WD) Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: Replace engine oil and oil filter 1 Replace engine oil and oil filter MAINTENANCE Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: 1 DEALER SERVICE VERIFICATION: DATE: MILEAGE: 1 2 3 4 Reset the oil replacement reminder light (“MAINT REQD”) or the message “OIL MAINTENANCE REQUIRED” on the multi-information display after maintenance at every 5,000 miles. Perform these service items only if you drive primarily under the conditions indicated. Includes operating on roads which road salt has been applied. Refer to “Engine Coolant” in the “Explanation of Maintenance Items” section in the back of this guide for more information. Maintenance Log 39 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 40 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 69 of 102 Page ID #:73 Maintenance Log 20,000 miles or 24 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Replace engine oil and oil filter 1 Rotate tires Visually inspect brake linings/drums and brake pads/discs Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body 25,000 miles or 30 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: MAINTENANCE Replace engine oil and oil filter 1 Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: Replace engine oil and oil filter DEALER SERVICE VERIFICATION: DEALER SERVICE VERIFICATION: DATE: MILEAGE: DATE: MILEAGE: 40 Maintenance Log 1 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 41 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 70 of 102 Page ID #:74 Maintenance Log 30,000 miles or 36 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Lubricate propeller shaft (4WD) Re-torque propeller shaft bolt Replace cabin air filter Replace engine air filter Replace engine oil and oil filter 1 Rotate tires Inspect the following: __ __ __ __ __ __ __ __ Automatic transmission fluid Ball joints and dust covers Brake lines and hoses Brake linings/drums and brake pads/discs 4 Drive shaft boots (4WD) Engine coolant 5 Exhaust pipes and mountings Front differential oil (4WD) __ Fuel lines and connections, fuel tank band and fuel tank vapor vent system hoses __ Fuel tank cap gasket __ Radiator and condenser __ Rear differential oil __ Steering gear box __ Steering linkage and boots __ Transfer case oil (4WD) Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Replace transfer case oil (4WD) Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Replace front differential oil (4WD) Replace rear differential oil Replace transfer case oil (4WD) Tighten nuts and bolts on chassis and body MAINTENANCE DEALER SERVICE VERIFICATION: DATE: MILEAGE: 1 2 3 4 5 Reset the oil replacement reminder light (“MAINT REQD”) or the message “OIL MAINTENANCE REQUIRED” on the multi-information display after maintenance at every 5,000 miles. Perform these service items only if you drive primarily under the conditions indicated. Includes operating on roads which road salt has been applied. Inspect thickness measurement and disc runout. Refer to “Engine Coolant” in the “Explanation of Maintenance Items” section in the back of this guide for more information. Maintenance Log 41 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 42 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 71 of 102 Page ID #:75 Maintenance Log 35,000 miles or 42 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body 40,000 miles or 48 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Replace engine oil and oil filter 1 Rotate tires Visually inspect brake linings/drums and brake pads/discs Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: MAINTENANCE Replace engine oil and oil filter 1 Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: Replace engine oil and oil filter 1 DEALER SERVICE VERIFICATION: DEALER SERVICE VERIFICATION: DATE: MILEAGE: DATE: MILEAGE: 42 Maintenance Log 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 43 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 72 of 102 Page ID #:76 Maintenance Log 45,000 miles or 54 months Check installation of driver’s floor mat Clean cabin air filter Inspect and adjust all fluid levels Lubricate propeller shaft (4WD) Re-torque propeller shaft bolt Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Inspect the following: __ __ __ __ __ __ __ __ __ __ Ball joints and dust covers Brake lines and hoses Drive shaft boots (4WD) Engine coolant 4 Exhaust pipes and mountings Front differential oil (4WD) Radiator and condenser Rear differential oil Steering gear box Steering linkage and boots Note: Driving in heavy traffic, on dirt roads or in urban, dusty or desert areas may shorten the life of the cabin air filter. Replacement may be needed if you notice reduced air flow from the air conditioner and heater or if the windows fog easily when you use the ⬙Fresh⬙ mode. Consult your dealer if any of these conditions occur. Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect engine air filter Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Replace engine oil and oil filter 1 Replace front differential oil (4WD) Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: Replace engine oil and oil filter 1 Replace engine oil and oil filter MAINTENANCE Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: 1 DEALER SERVICE VERIFICATION: DATE: MILEAGE: 1 2 3 4 Reset the oil replacement reminder light (“MAINT REQD”) or the message “OIL MAINTENANCE REQUIRED” on the multi-information display after maintenance at every 5,000 miles. Perform these service items only if you drive primarily under the conditions indicated. Includes operating on roads which road salt has been applied. Refer to “Engine Coolant” in the “Explanation of Maintenance Items” section in the back of this guide for more information. Maintenance Log 43 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 44 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 73 of 102 Page ID #:77 Maintenance Log 50,000 miles or 60 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Replace engine oil and oil filter 1 Rotate tires Visually inspect brake linings/drums and brake pads/discs Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body 55,000 miles or 66 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: MAINTENANCE Replace engine oil and oil filter 1 Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: Replace engine oil and oil filter DEALER SERVICE VERIFICATION: DEALER SERVICE VERIFICATION: DATE: MILEAGE: DATE: MILEAGE: 44 Maintenance Log 1 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 45 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 74 of 102 Page ID #:78 Maintenance Log 60,000 miles or 72 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Lubricate propeller shaft (4WD) Re-torque propeller shaft bolt Replace cabin air filter Replace engine air filter Replace engine oil and oil filter 1 Rotate tires Inspect the following: __ __ __ __ __ __ __ __ __ Automatic transmission fluid Ball joints and dust covers Brake lines and hoses Brake linings/drums and brake pads/discs 4 Drive belts 5 Drive shaft boots (4WD) Engine coolant 6 Exhaust pipes and mountings Front differential oil (4WD) __ Fuel lines and connections, fuel tank band and fuel tank vapor vent system hoses __ Fuel tank cap gasket __ Radiator and condenser __ Rear differential oil __ Steering gear box __ Steering linkage and boots __ Transfer case oil (4WD) Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Replace transfer case oil (4WD) Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: MAINTENANCE Replace automatic transmission fluid Replace front differential oil (4WD) Replace rear differential oil Replace transfer case oil (4WD) Tighten nuts and bolts on chassis and body DEALER SERVICE VERIFICATION: DATE: MILEAGE: 1 2 3 4 5 6 Reset the oil replacement reminder light (“MAINT REQD”) or the message “OIL MAINTENANCE REQUIRED” on the multi-information display after maintenance at every 5,000 miles. Perform these service items only if you drive primarily under the conditions indicated. Includes operating on roads which road salt has been applied. Inspect thickness measurement and disc runout. Initial inspection at 60,000 miles/72 months. Inspect every 15,000 miles/18 months thereafter. Refer to “Engine Coolant” in the “Explanation of Maintenance Items” section in the back of this guide for more information. Maintenance Log 45 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 46 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 75 of 102 Page ID #:79 Maintenance Log 65,000 miles or 78 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body 70,000 miles or 84 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Replace engine oil and oil filter 1 Rotate tires Visually inspect brake linings/drums and brake pads/discs Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: MAINTENANCE Replace engine oil and oil filter 1 Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: Replace engine oil and oil filter 1 DEALER SERVICE VERIFICATION: DEALER SERVICE VERIFICATION: DATE: MILEAGE: DATE: MILEAGE: 46 Maintenance Log 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 47 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 76 of 102 Page ID #:80 Maintenance Log 75,000 miles or 90 months Check installation of driver’s floor mat Clean cabin air filter Inspect and adjust all fluid levels Lubricate propeller shaft (4WD) Re-torque propeller shaft bolt Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Inspect the following: __ __ __ __ __ __ __ __ __ __ __ Ball joints and dust covers Brake lines and hoses Drive belts Drive shaft boots (4WD) Engine coolant 4 Exhaust pipes and mountings Front differential oil (4WD) Radiator and condenser Rear differential oil Steering gear box Steering linkage and boots Note: Driving in heavy traffic, on dirt roads or in urban, dusty or desert areas may shorten the life of the cabin air filter. Replacement may be needed if you notice reduced air flow from the air conditioner and heater or if the windows fog easily when you use the ⬙Fresh⬙ mode. Consult your dealer if any of these conditions occur. Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect engine air filter Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Replace engine oil and oil filter 1 Replace front differential oil (4WD) Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: Replace engine oil and oil filter 1 Replace engine oil and oil filter MAINTENANCE Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: 1 DEALER SERVICE VERIFICATION: DATE: MILEAGE: 1 2 3 4 Reset the oil replacement reminder light (“MAINT REQD”) or the message “OIL MAINTENANCE REQUIRED” on the multi-information display after maintenance at every 5,000 miles. Perform these service items only if you drive primarily under the conditions indicated. Includes operating on roads which road salt has been applied. Refer to “Engine Coolant” in the “Explanation of Maintenance Items” section in the back of this guide for more information. Maintenance Log 47 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 48 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 77 of 102 Page ID #:81 Maintenance Log 80,000 miles or 96 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Replace engine oil and oil filter 1 Rotate tires Visually inspect brake linings/drums and brake pads/discs Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body 85,000 miles or 102 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: MAINTENANCE Replace engine oil and oil filter 1 Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: Replace engine oil and oil filter DEALER SERVICE VERIFICATION: DEALER SERVICE VERIFICATION: DATE: MILEAGE: DATE: MILEAGE: 48 Maintenance Log 1 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 49 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 78 of 102 Page ID #:82 Maintenance Log 90,000 miles or 108 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Lubricate propeller shaft (4WD) Re-torque propeller shaft bolt Replace cabin air filter Replace engine air filter Replace engine oil and oil filter 1 Rotate tires Inspect the following: __ __ __ __ __ __ __ __ __ Automatic transmission fluid Ball joints and dust covers Brake lines and hoses Brake linings/drums and brake pads/discs 4 Drive belts Drive shaft boots (4WD) Engine coolant 5 Exhaust pipes and mountings Front differential oil (4WD) __ Fuel lines and connections, fuel tank band and fuel tank vapor vent system hoses __ Fuel tank cap gasket __ Radiator and condenser __ Rear differential oil __ Steering gear box __ Steering linkage and boots __ Transfer case oil (4WD) Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Replace transfer case oil (4WD) Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Replace front differential oil (4WD) Replace rear differential oil Replace transfer case oil (4WD) Tighten nuts and bolts on chassis and body MAINTENANCE DEALER SERVICE VERIFICATION: DATE: MILEAGE: 1 2 3 4 5 Reset the oil replacement reminder light (“MAINT REQD”) or the message “OIL MAINTENANCE REQUIRED” on the multi-information display after maintenance at every 5,000 miles. Perform these service items only if you drive primarily under the conditions indicated. Includes operating on roads which road salt has been applied. Inspect thickness measurement and disc runout. Refer to “Engine Coolant” in the “Explanation of Maintenance Items” section in the back of this guide for more information. Maintenance Log 49 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 50 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 79 of 102 Page ID #:83 Maintenance Log 95,000 miles or 114 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body 100,000 miles or 120 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Replace engine coolant 4 Replace engine oil and oil filter 1 Rotate tires Visually inspect brake linings/drums and brake pads/discs Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: MAINTENANCE Replace engine oil and oil filter 1 Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: Replace engine oil and oil filter 1 DEALER SERVICE VERIFICATION: DEALER SERVICE VERIFICATION: DATE: MILEAGE: DATE: MILEAGE: 50 Maintenance Log 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 51 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 80 of 102 Page ID #:84 Maintenance Log 105,000 miles or 126 months Check installation of driver’s floor mat Clean cabin air filter Inspect and adjust all fluid levels Lubricate propeller shaft (4WD) Re-torque propeller shaft bolt Rotate tires Visually inspect brake linings/drums and brake pads/discs Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Inspect the following: __ __ __ __ __ __ __ __ __ __ __ Ball joints and dust covers Brake lines and hoses Drive belts Drive shaft boots (4WD) Engine coolant 5 Exhaust pipes and mountings Front differential oil (4WD) Radiator and condenser Rear differential oil Steering gear box Steering linkage and boots Note: Driving in heavy traffic, on dirt roads or in urban, dusty or desert areas may shorten the life of the cabin air filter. Replacement may be needed if you notice reduced air flow from the air conditioner and heater or if the windows fog easily when you use the ⬙Fresh⬙ mode. Consult your dealer if any of these conditions occur. Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect engine air filter Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Replace engine oil and oil filter 1 Replace front differential oil (4WD) Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: Replace engine oil and oil filter 1 Replace engine oil and oil filter MAINTENANCE Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: 1 DEALER SERVICE VERIFICATION: DATE: MILEAGE: 1 2 3 4 5 Reset the oil replacement reminder light (“MAINT REQD”) or the message “OIL MAINTENANCE REQUIRED” on the multi-information display after maintenance at every 5,000 miles. Perform these service items only if you drive primarily under the conditions indicated. Includes operating on roads which road salt has been applied. Initial replacement at 100,000 miles/120 months. Replace every 50,000 miles/60 months thereafter. Refer to “Engine Coolant” in the “Explantion of Maintenance Items” section in the back of this guide for more information. Refer to “Engine Coolant” in the “Explanation of Maintenance Items” section in the back of this guide for more information. Maintenance Log 51 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 52 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 81 of 102 Page ID #:85 Maintenance Log 110,000 miles or 132 months 115,000 miles or 138 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Replace engine oil and oil filter 1 Rotate tires Visually inspect brake linings/drums and brake pads/discs Check installation of driver’s floor mat Inspect and adjust all fluid levels Rotate tires Visually inspect brake linings/drums and brake pads/discs Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Tighten nuts and bolts on chassis and body Note: If 0W-20 oil WAS NOT used at the last oil change, replace engine oil and oil filter.1 Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Inspect ball joints and dust covers Inspect drive shaft boots (4WD) Inspect engine air filter Inspect steering linkage and boots Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: Lubricate propeller shaft (4WD) 3 Re-torque propeller shaft bolt 3 Replace engine oil and oil filter 1 Tighten nuts and bolts on chassis and body Repeated trips of less than five miles in temperatures below 32°F / 0°C: MAINTENANCE Replace engine oil and oil filter 1 Extensive idling and/or low speed driving for a long distance such as police, taxi or door-to-door delivery use: Replace engine oil and oil filter DEALER SERVICE VERIFICATION: DEALER SERVICE VERIFICATION: DATE: MILEAGE: DATE: MILEAGE: 52 Maintenance Log 1 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 53 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 82 of 102 Page ID #:86 Maintenance Log 120,000 miles or 144 months Check installation of driver’s floor mat Inspect and adjust all fluid levels Lubricate propeller shaft (4WD) Re-torque propeller shaft bolt Replace cabin air filter Replace engine air filter Replace engine oil and oil filter 1 Replace spark plugs 4 Rotate tires Inspect the following: __ __ __ __ __ __ __ __ __ Automatic transmission fluid Ball joints and dust covers Brake lines and hoses Brake linings/drums and brake pads/discs 5 Drive belts Drive shaft boots (4WD) Engine coolant 6 Exhaust pipes and mountings Front differential oil (4WD) __ Fuel lines and connections, fuel tank band and fuel tank vapor vent system hoses __ Fuel tank cap gasket __ Radiator and condenser __ Rear differential oil __ Steering gear box __ Steering linkage and boots __ Transfer case oil (4WD) Additional Maintenance Items for Special Operating Conditions 2 Driving on dirt roads or dusty roads: Replace transfer case oil (4WD) Tighten nuts and bolts on chassis and body Driving while towing, using a car-top carrier, or heavy vehicle loading: MAINTENANCE Replace automatic transmission fluid Replace front differential oil (4WD) Replace rear differential oil Replace transfer case oil (4WD) Tighten nuts and bolts on chassis and body DEALER SERVICE VERIFICATION: DATE: MILEAGE: 1 2 3 4 5 6 Reset the oil replacement reminder light (“MAINT REQD”) or the message “OIL MAINTENANCE REQUIRED” on the multi-information display after maintenance at every 5,000 miles. Perform these service items only if you drive primarily under the conditions indicated. Includes operating on roads which road salt has been applied. Maintenance services of spark plugs are required under the terms of the Emissions Control Warranty. Inspect thickness measurement and disc runout. Refer to “Engine Coolant” in the “Explanation of Maintenance Items” section in the back of this guide for more information. Maintenance Log 53 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 54 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 83 of 102 Page ID #:87 Explanation of Maintenance Items T he following descriptions are provided to give you a better understanding of the maintenance items that should be performed on your vehicle. The scheduled maintenance log indicates at which mileage/time intervals each item should be performed. Please note that many maintenance items should be performed only by a qualified technician. For further information on maintenance items you can perform yourself, see the “Vehicle Maintenance and Care” and “Do-It-Yourself Maintenance” sections of the Owner’s Manual. Automatic Transmission Fluid Inspect or replace at specified intervals. When performing inspections, check each component for signs of leakage. If you discover any leakage, have it repaired by a qualified technician immediately. MAINTENANCE Ball Joints and Dust Covers Check the suspension and steering linkage ball joints for looseness and damage. Check all dust covers for deterioration and damage. Replace any deteriorated or damaged parts. A qualified technician should perform these operations. 54 Maintenance Log Brake Lines and Hoses Visually inspect for proper installation. Check for chafing, cracks, deterioration and signs of leakage. Replace any deteriorated or damaged parts. A qualified technician should perform these operations. Brake Linings/Drums and Brake Pads/Discs Check the brake linings (shoes) and drums for scoring, burning, fluid leakage, broken parts and excessive wear. Check the pads for excessive wear and the discs for runout, excessive wear and fluid leakage. Replace any deteriorated or damaged parts. A qualified technician should perform these operations. Cabin Air Filter Clean or replace at specified intervals. Driving in heavy traffic, on dirt roads or in urban, desert or dusty areas may shorten filter’s life. More frequent replacement may be necessary. Drive Belts Inspect for cracks, excessive wear and oiliness. Check the belt tension and adjust if necessary. Replace the belts if they are damaged. 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 55 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 84 of 102 Page ID #:88 Explanation of Maintenance Items Drive Shaft Boots Engine Coolant Check the drive shaft boots and clamps for cracks, deterioration and damage. Replace any deteriorated or damaged parts and, if necessary, repack the grease. A qualified technician should perform these operations. Drain the cooling system and refill with an ethylene-glycol type coolant. Inspect hoses and connections for corrosion and leaks. Tighten connections and replace parts when necessary. A qualified technician should perform these operations. (For further details, refer to ⬙Radiator, Condenser and Hoses⬙ in the ⬙Vehicle Maintenance and Care⬙ section of the Owner’s Manual). Driver’s Floor Mat • Only use the driver’s floor mat designed specifically for the model and model year of your vehicle. • Always properly secure the driver’s floor mat using the retaining hooks. • Never install another floor mat on top of the existing driver’s floor mat. • Never install the driver’s floor mat upside down. Engine Air Filter Replace at specified intervals. When performing inspections, check for damage, excessive wear and oiliness, and replace if necessary. Your Toyota is equipped with Genuine Toyota Super Long-Life Coolant. The replacement intervals for engine coolant recommended in this booklet are based on replacement with Genuine Toyota Super Long-Life Coolant or similar high-quality non-silicate, non-amine, non-borate ethylene-glycol coolant with long-life hybrid organic acid technology (i.e., a combination of low phosphates and organic acids). If another type of ethylene-glycol coolant is used, replacement intervals may be different. MAINTENANCE Maintenance Log 55 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 56 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 85 of 102 Page ID #:89 Explanation of Maintenance Items Engine Oil and Oil Filter Replace the oil filter and drain and refill the engine oil at specified intervals. For recommended oil grade and viscosity, refer to the Owner’s Manual. NOTE: Your vehicle is certified with Genuine Toyota 0W20 motor oil. For VEHICLES CERTIFIED FOR 0W20 motor oil, the oil change interval is 10,000 miles or 12 months IF 0W20 MOTOR OIL IS BEING USED. If 0W20 is not available, 5W20 mineral oil may be used. However, it must be replaced at A 5,000 miles or 6 month INTERVAL with 0W20 motor oil. For customers who primarily drive their vehicle under any of the listed Special Operating Conditions, the motor oil and filter should be replaced at 5,000 miles or 6 months, REGARDLESS OF THE OIL USED (OR CERTIFICATION OF THE VEHICLE). MAINTENANCE Exhaust Pipes and Mountings Visually inspect the exhaust pipes, muffler and hangers for cracks, deterioration and damage. Start the engine and listen carefully for any exhaust gas leakage. Tighten connections or replace parts as necessary. Front and Rear Differential Oil Inspect or replace at specified intervals. When performing inspections, check each component for signs of leakage. If you discover any leakage, have it repaired by a qualified technician immediately. 56 Maintenance Log Fuel Lines and Connections, Fuel Tank Band and Fuel Tank Vapor Vent System Hoses Visually inspect for corrosion, damage, cracks, and loose or leaking connections. Tighten connections or replace parts as necessary. Fuel Tank Cap Gasket Visually inspect for cracks, deterioration and damage and replace if necessary. Nuts and Bolts on Chassis and Body Re-tighten the seat-mounting bolts and front/rear suspension member retaining bolts to specified torque. Propeller Shaft Lubricate the propeller shaft spiders and slide yokes with lithium-base chassis grease and the double cardan joint with molybdenum-disulfide lithium-base chassis grease, and re-torque the bolt. Only a qualified technician should perform this operation Radiator and Condenser Inspect for debris, corrosion and signs of damage. Have any problem repaired immediately by a qualified technician. Spark Plugs Replace at specified intervals. Install new plugs of the same type as originally equipped. A qualified technician should perform this operation. 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 57 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg 86 of 102 Page ID #:90 Explanation of Maintenance Items Steering Gear Box Inspect for signs of leakage. If you discover any leakage, have it repaired immediately by a qualified technician. Steering Linkage and Boots With the vehicle stopped, check for excessive freeplay in the steering wheel. Inspect the linkage for bending and damage and the dust boots for deterioration, cracks and damage. Replace any damaged parts. A qualified technician should perform these operations. Tire Rotation Tires should be rotated according to the instructions in the Owner’s Manual. When rotating tires, check for damage and uneven wear. Replace if necessary. Transfer Case Oil Inspect or replace at specified intervals. When performing inspections, check for signs of leakage. If you discover any leakage, have it repaired by a qualified technician immediately. MAINTENANCE Maintenance Log 57 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 58 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg Vehicle Identification Model In-service date Selling dealership Key number Body style Mileage at delivery Selling dealership phone number MAINTENANCE Vehicle Identification Number 58 Maintenance Log 87 of 102 Page ID #:91 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 32 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg Notes 88 of 102 Page ID #:92 8:16-cv-01525-AG-JCG Document 3 FriFiled Page JOBNAME: Case 934392-2012-tunWG-EN PAGE: 32 SESS: 12 OUTPUT: Aug 508/18/16 09:25:45 2011 /tweddle/toyota/sched-maint/934392-en-tun/wg Notes 89 of 102 Page ID #:93 CUSTOMER LOYALTY WC13 TOYOTA MOTOR SALES USA INC PO BOX 2991 TORRANCE CA 90509-9809 Case 8:16-cv-01525-AG-JCG Document 3 Filed 08/18/16 Page 90 of 102 Page ID #:94 124757_11-TCS-04845_WMG_Tundra.indd 2 8/5/11 4:14 PM Case Document 3 Filed 08/18/16 Page 91 of 102 Page ID #:95 ,Exhibit 2 I gase 8' ,6-cv- 152 -AG-JCG Document3 Filed 08/18/16 Page 92 of 102 Page ID #:96 erv100 lstory age Page] of 4 Service Histo for VIN: GED TOYOTA Servnce Lane Service History for 2012 Tundra TUNDRA GRD (8339) V8 - 1UR-FE, 0202-BLACK Warranty . NSH . 1, Print Customer Pay I Warranty Pay InternaLgeEALER) Goodwill Total Amount $300 $282.76 $0 $0 $582.76 Data"w Mileage Dealer RONumberA?mount Claim Pa BOB ROHRMA WARRANTY WARRANTY 6683 (13027) 1026664 095614 Claim Goodwill 995614 Part Part Desc. Re+aced Part.Y Indicator: ,Op Code: . 15KSYN Repair.15,000 MILE VEHICL SERVICE - NO COST MAINT T1: T2: T3: Condition Desc: - Cause Desc: Remedy Desc: Date Source Mileage Dealer R0 Number R0 Total Service Advisor 12/22/2014 NSH 6683 BOB ROHRMA 1026664 (13.027) . Condition: 1- Op Code: PRIME ITEM Pay Type: WARRANTY PAY Op Code Desc: PERFORM 15000 MILE FACTORY SERVICE INCLUDING TIRE ROTATION, MULTI-POINT INSPECTION, CLEAN OR REPLA 15000 MILE FACTORY SERVICE INCLUDING TIRE ROTATION, MULTI-POINT INSPECTION, CLEAN OR REPLACE CABIN AIR FILTER (IF APPLICABLE), AND RESET OF MAITANCE LIGHT AS REQUIRED STOMER DECLINED DIAGNOSTIC ON CHECK ENGINE AN 4LOW AND No Part nfo Available mu ?Mann?u w. Date Source Mileage Dealer R0, Number Service Advisor 06/24/2014 NSH 5764 302338;?" 1017485 Condition: 1- Op Code: 250 Pay . CUSTOMER PAY Op Code Desc: TECH REPLACED REAR SPEED SENSOR RR SPEED SENSOR HA SOP CUSTOMERS WERE NOTIFIED THAT CHECK ENGINE LIGHT WILL REMAIN ON DUE TO EVAP SYSTEM FAULTS, CHEWING THROUGH GAS TANK HARNESSES. LIGHT WILL REMAIN ON UNTIL FIXED. . . Part Claim Part Qty. 1 895160C050 \Part Desc. WIRE, KID CONTROL 5 Condition: 2- Op Code: 250 Pay Type: CUSTOMER PAY Op Code Desc: TECH MADE NEW GROUND STRAP AND REPLACED, REPAIRD VAC LINE T0 T-CASE GROUND STRAP FROM TRANS BODY No Part Info Available . Date a -uu'uukan AWN-.IJ . a ?w - Source Mileage Dealer R0 Number Amount Claim Pay Type Printed at 13027 by GAGNONR on Monday, 02l08l2016 11:55 AM EST 2?16 T?y?ta M?t?r sa'es' ://tis.toyota.com/ serviceLane/faces/pages/asm/ serviceHistory/ serviceHistoryPrintEase 8' -AG-JCG Document3 Filed 08/18/16 Page 93 of 102 Page ID #:97 erv10e Istory age Page 2 of 4 Service Histo for VIN: TOYOTA Servuce Lane 06/17/2014 WARRANTY 5714 1017168 $90.45 990316 Claim .. abodm." 990316 Part Part Desc. Replaced Part.N Indicator: $31338: Repair:10,000 MILE OIL CHANGE - NO COST MAINT lT1: T2: T3: Condition Desc: Cause Desc: Remedy Desc: . 1 R0 - .l SelrvicehAdvisor r? ., Date Source Mileage 5 Dealer R0 Number 06/17/2014 NSH 5714 1017168 Condition: 1- Op Code: 200 Op Code Desc: TECH FOUND HARNESS AND USTOMER CH OF LIGHTS ON THE DASH ARE ON HAS HISTORY OF SQUIRREL DAMAGE CHECK AND ADVISE - No Part Info Available Condition: 2- Op Code: 10KSYN Pay Type: WARRANTY PAY I Op Code Desc: 10K MAINT 10000 MILE FACTORY SERVICE INCLUDING OIL AND FILTER CHANGE, TIRE ROTATION, MULTI-POINT INSPECTION, AND RESET OF MAINTENANCE LIGHT AS REQUIRED PLAN . Part Claim 101716 Part Qty. 1 04152YZZA4 Part Desc. REPLACEABLE ELEMENT . Part Part Qty. 1 9043012031 Part Desc. GASKET Part Part Qty: 8 Part Desc: OWZO-SINGLE QUART (W 002790WQTE01 Condition: 3- Op Code: MPI Pay Type: INTERNAL (DEALER) PAY Op Code Desc: PERFORM MULTI-POINT COURTESY INSPECTION MULTI-POINT COURTESY INSPECTION No Part Info Available 10/02/2013 WARRANTY 3441 1005587 983614 Part Part Desc: R- placed Part:Y Indicator: Repair:5,000 MILE VEHICLE SERVICE - COMP MAINT T1: T2: T3: Condition Desc: Cause Desc: Remedy Desc: . . Date Source Mileage Dealer R0 Number RO Total' Service Advisor 10/02/2013 NSH 3441 BOB ROHRMA 1005587 $25.8 *4 .- us-?I-n Printed at 13027 by GAGNONR on Monday, 02/08/2016 11:55 AM EST 2016 Toyota Motor Sales, USA, Incf1 2 ID 98 ?ervsiece8nis?ory915 nTPage -AG- JCG Document3 Filed 08/18/16 Page 940 0 ageP age 3 of 4 GB) TOYOTA Service Lane 3255;232:299: A . . . . (1.3027) Condition: 1- Op Code: MPI Pay Type: CUSTOMER PAY Op Code Desc: PERFORM MULTIPOINT COURTESY INSPECTION MULTIPOINT COURTESY INSPECTION No Part Info Available Condition: 2- Op Code: 150 Pay Type: CUSTOMER PAY Op Code Desc: SEE STORY STATES CHECK ENGINE LIGHT I HISTORY, SH OR LOOSE GAS CAP, SYSTEM WILL NOT CLEAR . ITSELF OUT AFTER MANY RESTART CYCLES), PLEASE ADVISE ~ ~3441 CODES P0441 AND P04 TEST AND SMOKE TEST. FOUND RODENT DAMAGE TO EVAP TUB 1,1 I No Part Info Available 3 Condition: 3- Op Code: Pay Type: WARRANTY PAY Op Code Desc: PERFORM 5000 MILE FACTORY SERVICE INCLUDING TIRE ROTATION, MULTI-POINT INSPECTIO 5000 MILE FACTORY SERVICE INCLUDING TIRE ROTATION, MULTI-POINT INSPECTION, AND RESET OF MAINTANCE LIGHT As - REQUIRED PLAN . No Part Info Available whisk-ri-hin-?buir- A . . 4.1 Ami-r? Hanna-win 4? mu Date Source Mileage Dealer R0 Number' Amount Clalm# Pa BOB ROHRMA WARRANTY 06/12/2013 WARRANTY 1933 . . (13027.) 1000979 . 981190 PAY Claim Goodwill 981190 Part Part Desc. eplaced Part: Indicator: Op Code: . DP0499 Repair.DIAG OTHERS T1: 8A T2: 99 T3: Condition Desc: P0455 P0441 Cause Desc: P0455 P0441 Remedy Desc: TECH EVAP EMISSION CONTROL SYSTEM LEAK .4 W. Date Source Mileage Dealer RO Number RO Total Service Advisor BOB ROHRMA 06/12/2013 NSH 1933 (13027) 1000979 $42.5 . . Condition 1- Op Code: DP0499 Pay Type: WARRANTY PAY Op Code Desc: EVAP EMISSION CONTROL SYSTEM LEAK STATES AFTER REPAIR, CHECK ENGINE LIGHT STILL COMING ON AFTER PERVIOUS REPAIR. PLEASE ADVISE 441 No Part Info Available an.? nay-Eggnouwnmuw nu .0. My" 'uwh? -- 'n ?ya?r L- In nun-A lnA-A Date Source Mileage Dealer R0 Number Amount Claim 05/30/2013 WARRANTY 1747 1000304 980937 WARRANTY I Claim . . .. .. . 'Goodwill 980937 Part Part Desc. placed Part.Y Indicator: Op Code: . . DP0499 Repair.DIAG OTHERS T1: 8A T2: 41 T3: Printed at 13027 by GAGNONR on Monday, 02/08/2016 11:55 AM EST 2?16 T?V?ta sa'es' Inc. 2/8/2016 Document3 Filed 08/18/16 Page 95 Of 102 Pageliggfi?ggm CB TOYOTA Service Lane 5TFUM5F18CX034752 Condition Desc: CODE P0717 CONNECTOR LOOSE AT PLUG Cause Desc: CODE PO717 CONNECTOR LOOSE AT PLUG Remedy Desc: REPAIR WIRING T0 TURNINE SPEED SENSOR A .1 Date Source Mileage Dealer RD Number R0 Total Service Advisor 05/30/2013 1747 80:31:82?? 1000304 Condition: 1- Op Code: 820991 Pay Type: WARRANTY PAY Op Code Desc: WINE SPEED SENSOR A STATES CHECK ENG IGHT 4 L0 STWEWN CONNECTOR LOOSE AT PLUG No Part Info Available Older Service History i Date Source Mileage Dealer RO Number R0 Total Service Advisor 06/19/2012 . . CRAIG 0024.579. . $0 Condition: 1- Op Code: PDI Op Code Desc: PERFORM PRE-DELIVERY INSPECTION Pay Type: WARRANTY No Part Info Available Condition: 2- Op Code: 33 Pay Type: INTERNAL (DEALER) PAY Op Code Desc: VEHICLE ENHANCEMENT BASIC .4. Au?. a No Part Info Available Note: All Information presented herein is based on data available at the time of posting, is subject to Change without notice and pertains specifically to mainland U.S.A. vehicles only. Printed at 13027 by GAGNONR on Monday, 02/08/2016 11:55 AM EST 2?16 T?y?ta sa'es' 2/8/2016 4 Document 3 Filed 08/18/16 Page 96 of 102 Page #2100 Exhibit 37 Case Document 3 Filed 08/18/16 Page 97 of 102 Page ID #:101 51/ %?ma/z CUSTOMER 10859 1017168 :70ALBERT HEBER 701 Sagamore Parkway South 4057 200 LAFAYETTE. IN 47905 DELPHI, IN 46923-8734 PAGE 1 (765)4484000 HOME 765?412-4201 BUS: 765-494-1214 CELL: 765-412-4201 SERVICE ADVISOR: 3861 NICK BADGER COLOR YEAR VIN LICENSE MILEAGE lN/ OUT TAG BLACK 12 TOYOTA TUNDRA 5TFUM5F18CX034752 5713/5714 2872 DEL DATE PROD. DATE WARR. EXP. PROMISED PO NO. RATE PAYMENT INV. DATE 31DEC12 DD WAIT 17JUN14 CASH 17JUN14 R.O. OPENED READY OPTIONS: ENG: 4 5 Liter 13:54 17JUN14 16:15 17JUN14 LINE OPCODE TECH TYPE HOURS LIST NET TOTAL A PERFORM 10000 MILE FACTORY SERVICE INCLUDING OIL AND FILTER CHANGE, TIRE ROTATION, MULTI- POINT INSPECTION, AND RESET OF MAINTENANCE LIGHT AS REQUIRED CAUSE: MAINT PLAN 10K MAINT 7M and Madamu?wmm The factory warranty constitutes all of the warranties with respect to the sale of this item\items. The Seller hereby expressly disclaims all warranties either express or implied, including any implied warranty of merchantability or fitness for,a particular purpose. Seller neither assumes nor authorizes any other person to assume for it any liability in cannection with the sale of this item/items. 9039 W40M 0.50 1 04152-YZZA4 REPLACEABLE ELEMENT I 90430-12031 GASKET . 8 0W20-SINGLE QUART (w PARTS: 0.00 LABOR: 0.00 OTHER: 0.00 TOTAL LINE A: 0.00 PERFORM MULTI-POINT COURTESY INSPECTION MPI PERFORM MULTI-POINT COURTESY INSPECTION 2381 ISH 0.00 PARTS: 0.00 LABOR: 0.00 OTHER: 0.00 TOTAL LINE B: 0.00 -C CUSTOMER STATES A BUNCH OF THE LIGHTS ON THE DASH ARE ON HAS HISTORY OF SQUIRREL DAMAGE CHECK AND ADVISE 200 TECH FOUND HARNESS AND GROUND STRAPS THROUGH, HARNESS ORDERED 9039 1.00 . . 75.00 75 00 PARTS: 0.00 LABOR: 75 00 OTHER: 0.00 TOTAL LINE C: 75.00 EST: 50.00 17JUN14 13:54 SA: 3861 CONTACT: AH ??gl .. CUSTOMER PAY MISC. SHOP CHARGE FOR REPAIR ORDER 9? 3.STATEMENT OF DISCLAIMER DESCRIPTION TOTALS LABOR AMOUNT PARTS AMOUNT GAS, OIL, LUBE SUBLET AMOUNT MISC. CHARGES TOTAL CHARGES LESS SALES TAX PLEASE PAY THIS AMOUNT Case Document 3 Filed 08/18/16 Page 98 of 102 Page ID #2102 CUSTOMER -5. 10859 ALBERT HEBER 4057 200 DELPHI IN 46923-8734 17 1 6 8 0? ?won? L/ayala - jag/A 701 Sagamore Parkway South LAFAYETTE, IN 47905 PAGE 2 (765)448-1000 BUS: 765-494-1214 SERVICE 3861 NICK BADGER COLOR YEAR VIN LICENSE MILEAGE OUT TAG BLACK 12 TOYOTA TUNDRA 5TFUM5F18CXO34752 5713/5714 T2872 DEL DATE PROD. DATE WARR. EXP. PROMISED PO No. RATE PAYMENT INV. DATE 31DEC12 DD WAIT 17JUN14 CASH 17JUN14 Rio. OPENED READY OPTIONS: ENG 4 .6 Liter 13:54 17JUN14 16:15 17JUN14 LIST NET TOTAL LINE OPCODE TECH TYPE HOURS I TRUST WE HAVE PROVIDED YOU WITH IF FOR ANY REASON YOU FEEL YOU DID NOT RECEIVE PLEASE CONTACT MITCH SCOTT SERVICE MGR OR ANNETTE CUSTOMER RELATION MANAGER AT 765-448-1000 THANK YOU FOR YOUR BUSINESS STATEMENT OF DISCLAIMER The factory warranty constitutes all of the warranties with respect to the sale of this item\items. The Seller hereby expressly disclaims all warranties either express or implied, including any implied warranty of merchantability or fitness for a particular purpose. Seller neither assumes nor authorizes any other person t'o assume for it any liability in connection with the sale of this item/items. DESCRIPTION TOTALS LABOR AMOUNT 7 5 0 PARTS AMOUNT 0 . 00 GAS. OIL, LUBE 0 . 0 0 SUBLET AMOUNT . 00 MISC. CHARGES 3 . 7 5 TOTAL CHARGES 7 8 . 7 5 LESS 0 . 0 0 SALES TM 0 . 2 6 PLEASE PAY THIS AMOUNT 7 9 1 CUSTOMER COPY Case Document3 Filed 08/18/16 Page 99 of,102 Page 7' . Exhibit 4' 1?of3 Biodegradable soy-based Wiring in5u ati0n' In same cars appealing. to rodents, causmg 1 trouble II ,_Don' 1: Waste Your Money BY: John Matarese, newsnet5. com POSTED: 5: 03 PM, Aug. 22, 2013 UPDATED: 1: 21 PM, Aug 23, 2013 Has the push to go green gone too far? .?That- may be the case when it comes to the wiring in our ears, trucks and It turns out a new type of environmentally?friendly wiring may be toofriendly to "animals. I No Start, ,Wiring on Driveway I . and M?arY?HeI?ald'couldn't ?gure out Why their Buick Lucerne suddenly. It. i i wouldn't run. got in it," she said, "and it would just click, click and would not start." . so herfhusband popped the hood, looked around,and on the ground underneath spotted a cheWed off wiring harness. "On the ground 1s this connector with 6 inches of wire on either end of it, Herald sdid,? that the Varmints had cheWed 1n two completely." New Wiring Tasty to Rodents It turns out a number of car brands have wiring that is tasty to rodents, according to I 20f3 7? Connecticut Watchdog, CarTalk and a number of automotive blogs. I'I'Mechanlc Marc Dueubber. said many automakers have moved to biodegradable, soy?based Wiring insulation' in the past 10 years. It won't last forever in land?lls, like I older plastic wiring. It'sgreat for the environment, but even better for hungry mice and squirrels. -7"The?y are-drawn to it, therefore they are chewing and eating it," Duebber said. "And we. - are finding nests created in the upper plenums (fresh air intakes). He showed an air filter that mice recently turned into a nest, using bits of wiring insulation What You can Do i - 7 some automakers-j are reSpOnding. Honda dealers now sell rolls of anti?rodent tapefdr? 1. Wires, that can be used on any car, not just Hondas. "There are Some produCts you can put there as a rodent deterrent," Duebber said. . Mary and WOody Herald bought a product called Rodent Repellent for use under the . 'f . hood They have also put bits of mothballs around the wiring just to be sure. They say they simply wish they had been warned, before their $400 repair "Theywant to go green, but they'should warn the public," Mary Hetaldseiid.? If you. suspect a critter has gotten under the hood of your car, you need to take action immediately because he will. berback. And he may bring his friends and family neXt time. I .As alWays, don't waste your money. 8/15/2016 3:27 PM A a m. .. Don Waste Your Money is a registered trademark ofthe EWScripps Co. "Like"; ohn Matarese en Facebook Copyright 2013 ?Scrip?pe Media, Inc. All rights reserved. This material may not be published, broadcast, rewritten, or redistributed. 30f3 - I I