Question 1

Why did I get a Notice?

Accepted Answer

A Court authorized the Notice because you have a right to know about a proposed
Settlement of a class action lawsuit, the benefits of the Settlement, and about
your options, before the Court decides whether to approve the Settlement.

United States Magistrate Gina L. Simms of the United States District Court for
the District of Maryland is overseeing the lawsuit. The lawsuit is known as
Kline et al. v. Hyundai Motor America, Inc. and the case number is
23-cv-245-GLS. The individuals who filed the lawsuit, and are appointed as Class
Representatives, Samuel Kline and Lauren Kline, Howard Nordberg, Timothy
Pritchett, Ioannis C. Tzamouranis, Clara K. Smith, and Ann Lyons (for herself
and as Personal Representative for her late husband, Michael Bozzuto), are
called Plaintiffs, and the company that was sued, Hyundai Motor America, Inc.
(“Hyundai” or “HMA”) is called the Defendant.

You may be part of this class action lawsuit if you purchased or leased a Class
Vehicle in the United States. This website explains the lawsuit, the Settlement,
and your legal rights. You are NOT being sued. The Court still has to decide
whether to finally approve the Settlement. Please be patient and check the
website identified in this Notice regularly. Please do not contact the Court.
All questions should be directed at the Settlement Administrator, identified
below. You may also contact Class Counsel listed below.

Access to the court docket is available for a fee via PACER (Public Access to
Court Electronic Records) at pacer.uscourts.gov or through the computers at the
Clerk’s Office, where Class Members may view the docket and read documents.
Please note there is a fee of $0.10 per page to obtain a copy of any documents
from the Clerk’s Office.

Question 2

What is this lawsuit about?

Accepted Answer

This case involves claims arising from Plaintiffs’ purchases or leases of
certain “Class Vehicles” which, for purposes of this Settlement are 2016-2019
model year Hyundai Sonata Plug-In Hybrid Vehicles that needed a Battery Repair
(a repair or replacement of a Class Vehicle’s HV Battery during the applicable
express warranty period and for which repair parts were not available and the
car could not be repaired for a minimum of sixty (60) days). Plaintiffs allege
Hyundai did not honor the high-voltage battery (“HV Battery”) warranty for the
Class Vehicles when the batteries in some of these vehicles failed and needed
replacement. Plaintiffs claim Hyundai could not repair or replace the failed HV
Batteries in their cars for extended periods of time and, as a result, owners of
such vehicles were denied full use of their vehicles pending repairs. The
relevant period for most Class Members, when their cars were out of service, is
late 2021 through the summer of 2023.

Hyundai expressly denies any wrongdoing or liability for the claims alleged,
denies the Class Vehicles or their HV Batteries are defective, and contends that
any alleged delays in replacing the HV Batteries in the Class Vehicles that
required battery replacements were caused by circumstances beyond Hyundai’s
control such as supply chain disruptions during the COVID-19 pandemic and other
third-party supplier delays. Plaintiffs and Hyundai have agreed to a Settlement
to avoid the time, expense and uncertainties of litigation. You can read the
class action complaint and find more details about the case on the Important
Documents page.

This Settlement does not involve claims for personal injury, wrongful death, or
damage to other physical property (if any) arising from the Class Vehicles.

Question 3

What vehicles are included in the Settlement?

Accepted Answer

The Settlement includes any 2016-2019 model year Hyundai Sonata Plug-In Hybrid
Vehicle that needed a Battery Repair (as defined in “What is this lawsuit
about?” above).

Question 4

What is a class action and who is involved?

Accepted Answer

In a class action lawsuit, people called the “Class Representatives” sue on
behalf of themselves and other people who have similar claims. All of the people
together are called a “Class” or “Class Members.” The company the Class
Representatives have sued (in this case Hyundai) is called the Defendant. One
court resolves the issues for everyone in the Class, except for those people who
choose to exclude themselves from the Class.

Question 5

Why is there a Settlement?

Accepted Answer

Both sides in the lawsuit, with the assistance of a neutral and experienced
mediator, agreed to this Settlement to avoid the cost and risk of further
litigation, including a potential trial. The Settlement does not mean that
Hyundai broke any laws or did anything wrong, and the Court did not decide which
side was right. This Settlement has been preliminarily approved by the Court,
which authorized the issuance of this website. The Class Representatives and the
lawyers representing them (Class Counsel) believe that the Settlement is in the
best interests of all Class Members and is fair, reasonable, and adequate.

The essential terms of the Settlement are summarized in this website. The
Settlement Agreement along with all exhibits and addenda sets forth in greater
detail the rights and obligations of the parties. If there is any conflict
between this Notice and the Settlement Agreement, the Settlement Agreement
governs. The Settlement Agreement is available on the Important Documents page.

FAQs

Background Information

Who Is in the Class

Settlement Benefits

How to Get Payment

Excluding Yourself from the Settlement

The Attorneys Representing You

Objecting to the Settlement

The Final Approval Hearing

If You Do Nothing

Getting More Information

Background Information

1. Why did I get a Notice?

2. What is this lawsuit about?

3. What vehicles are included in the Settlement?

4. What is a class action and who is involved?

5. Why is there a Settlement?

Who Is in the Class

6. Am I in the Settlement Class?

7. I am still not sure if I am included.

Settlement Benefits

8. What benefits does the Settlement provide?

9. What am I giving up to get a payment or stay in the Settlement?

How to Get Payment

10. How can I get a payment?

11. When will I get my payment?

Excluding Yourself from the Settlement

12. How do I get out of the Settlement?

13. If I don't exclude myself, can I sue the Defendant for the same thing later?

14. If I exclude myself, can I still get the Settlement Benefits?

The Attorneys Representing You

15. Do I have lawyers in this case?

16. How will these lawyers get paid?

17. Should I get my own lawyer?

Objecting to the Settlement

18. How do I tell the Court if I do not like the Settlement?

19. What is the difference between objecting to the Settlement versus opting out (excluding) from the Settlement?

The Final Approval Hearing

20. When and where will the Court decide whether to approve the Settlement?

21. Do I have to come to the Final Approval Hearing?

22. May I speak at the hearing?

If You Do Nothing

23. What happens if I do nothing?

Getting More Information

24. How do I get more information?