Frequently Asked Questions

  1. Why did I receive a notice?

    If you received a Notice in the mail, then according to records, you are a current or past owner or lessee of one of the following model/model year Audi vehicles with an Electric (After-Run) Coolant Pump that this Settlement applies to:

    Settlement Class Vehicles

    • Certain 2013-2016 model year Audi A4 Sedan & Allroad*
    • Certain 2013-2017 model year Audi A5 Sedan & Cabriolet*
    • Certain 2013-2017 model year Audi Q5*
    • Certain 2012-2015 model year Audi A6*

    * The Settlement does not apply to all such vehicles, only vehicles with certain Vehicle Identification Numbers (VINs). You can confirm whether your vehicle is a Settlement Class Vehicle by entering the Vehicle Identification Number (VIN) here.


    As a current or past owner or lessee of a Settlement Class Vehicle, you are considered a “Settlement Class Member."

    To view a copy of the Class Notice, click here.

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  2. What is the background of this case?

    A class action lawsuit was filed alleging a defect in the Electric (After-Run) Coolant Pumps of Settlement Class Vehicles, which are the subject of certain Recalls (referred to below). Plaintiffs also allege that the issue could potentially have some effect on the vehicles’ turbochargers. VWGoA has denied the claims in the lawsuit and maintains that no applicable warranties were breached, no statutes or laws were violated, and no wrongdoing occurred with respect to the Settlement Class Vehicles. The Court has not decided in favor of Plaintiffs or Defendant. Instead, both sides agreed to a Settlement with no decision or admission of who is right or wrong. That way, all parties avoid the risks and cost of a trial, and the people affected (the Settlement Class Members) can, to the extent eligible, receive benefits faster. The Class Representatives and Class Counsel believe that the Settlement is best for the Settlement Class.

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  3. Why is this a class action settlement?

    In a class action lawsuit, one or more persons, called Class Representatives, sue on behalf of other people who have similar claims. The people included in the class action are called the “Settlement Class” or “Settlement Class Members.” One court resolves the issues for all Settlement Class Members, except for those who choose to timely exclude themselves from the Settlement Class.

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  4. How do I know if I am part of the Settlement?

    The Court has conditionally approved the following definition of a Settlement Class Member:

    “All persons or entities who purchased or leased a Settlement Class Vehicle imported and distributed by Volkswagen Group of America, Inc. for sale or lease in the United States of America and Puerto Rico.”

    Excluded from the Settlement Class are:

    1. anyone claiming personal injury, property damage, and/or subrogation;
    2. all Judges who have presided over the Action, and their spouses;
    3. all current employees, officers, directors, agents, and representatives of Volkswagen Group Companies, and their family members;
    4. any affiliate, parent, or subsidiary of Defendants and any entity in which Defendants have a controlling interest;
    5. anyone acting as a used car dealer;
    6. anyone who purchased a Settlement Class Vehicle for the purpose of commercial resale;
    7. anyone who purchased a Settlement Class Vehicle with salvaged title and/or any insurance company who acquired a Settlement Class Vehicle as a result of a total loss;
    8. any insurer of a Settlement Class Vehicle;
    9. issuers of extended vehicle warranties and service contracts;
    10. any Settlement Class Member who, prior to April 15, 2020, settled with and released Defendants or any Released Parties from any Released Claims; and
    11. any Settlement Class Member that files a timely and proper Request for Exclusion from the Settlement Class.

    You may contact the Claim Administrator by calling 1-855-907-2083 if you have any questions as to whether you are in the Settlement Class.

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  5. What benefits does the Settlement provide?

    VWGoA has agreed to a settlement under which Settlement Class Members may be eligible for one or all of the following benefits:

    A. WARRANTY EXTENSION FOR CURRENT OWNERS AND LESSEES OF SETTLEMENT CLASS VEHICLES

    Effective on April 12, 2021, VWGoA will extend its original New Vehicle Limited Warranties applicable to the Settlement Class Vehicles to cover repair or replacement, by an authorized Audi dealer, of a failed turbocharger during the following time and mileage periods set forth in the four Categories of Settlement Class Vehicles below (hereinafter, “Warranty Extension” or “Extended Warranty”).

    The Warranty Extension does NOT apply to the Electric (After-Run) Coolant Pump; it applies to the turbocharger and any parts/labor necessary to effectuate the repair or replacement of a failed or malfunctioning turbocharger. The duration of the turbocharger Warranty Extension will vary for each individual Settlement Class Vehicle, depending on whether, and when, any of the following campaigns applicable to the Electric (After-Run) Coolant Pumps was performed on that vehicle:

    Recall 19M1 – Software Update re Electric (After-Run) Coolant Pump

    Recall 19O2 – Replacement of Electric (After-Run) Coolant Pump

    Recall 19N4 – Disconnection of Electric (After-Run) Coolant Pump

    Service Action 19N8 – Replacement of Electric (After-Run) Coolant Pump

    There is no mileage limitation on this turbocharger Warranty Extension; only an extension of the time duration. The time duration/expiration of the Warranty Extension will depend upon which of the following four categories applies to the particular Settlement Class Vehicle:

    Category 1 – If, prior to April 12, 2021, no Electric (After-Run) Coolant Pump Recall was performed on the Settlement Class Vehicle, or if, prior to April 12, 2021, only the software update pursuant to Recall 19M1 was performed, the duration of the Warranty Extension on the turbocharger of the Settlement Class Vehicle will be the greater of fourteen (14) months from April 12, 2021, or nine (9) months from the date in which the Settlement Class Vehicle’s original New Vehicle Limited Warranty period for the turbocharger expires.

    If, however, you have Recall 19O2 performed (replacement of the Electric [After-Run] Coolant Pump) on the Settlement Class Vehicle between April 12, 2021, and August 10, 2021, then the duration of the Warranty Extension on the turbocharger will be fourteen (14) months from the date which Recall 19O2 was performed on the Settlement Class Vehicle or nine (9) months from the date the Settlement Class Vehicle’s original New Vehicle Limited Warranty period for the turbocharger expires, whichever date occurs later.

    Category 2 – If, prior to April 12, 2021, Recall 19N4 (disconnection of the Electric [After-Run] Coolant Pump) was performed on the Settlement Class Vehicle, the duration of the Warranty Extension on the turbocharger will be fourteen (14) months following the expiration of the existing four (4) year warranty extension on the Settlement Class Vehicle’s turbocharger, which was provided as part of Recall 19N4. Therefore, with the fourteen (14) month added Warranty Extension provided by this Settlement, the total Warranty Extension on the turbocharger will be five (5) years and two (2) months (or 62 months), measured from the date on which the disconnection of the Settlement Class Vehicle’s Electric (After-Run) Coolant Pump was performed pursuant to Recall 19N4. This Warranty Extension will continue to apply even if the 19N8 Service Action (replacement of the Electric [After-Run] Coolant Pump) was or is subsequently performed on the Settlement Class Vehicle.

    Category 3 – If, prior to April 12, 2021, Recall 19O2 (replacement of the Electric [After-Run] Coolant Pump) was performed on the Settlement Class Vehicle, the duration of the Warranty Extension on the turbocharger will be the greater of fourteen (14) months from the date of the replacement of the Electric (After-Run) Coolant Pump under Recall 19O2 or nine (9) months from the date the Settlement Class Vehicle’s original New Vehicle Limited Warranty period for the turbocharger expires.

    Category 4 – If, prior to April 12 2021, the Settlement Class Vehicle’s Electric (After-Run) Coolant Pump underwent a repair or replacement that was not performed pursuant to any Recall or Service Action, then the duration of the Warranty Extension on the Settlement Class Vehicle’s turbocharger will be the greater of fourteen (14) months from April 12, 2021, or nine (9) months from the date the Settlement Class Vehicle’s original New Vehicle Limited Warranty period for the turbocharger expires, provided the damage to or failure of the turbocharger was not caused by a non-authorized dealer’s improper repair or use of a non-Audi replacement coolant pump.

    If, however, you have Recall 19O2 (replacement of the Electric [After-Run] Coolant Pump) performed on the Settlement Class Vehicle between April 12, 2021, and August 10, 2021, then the duration of the Warranty Extension on the turbocharger will be fourteen (14) months from the date Recall 19O2 was performed on the Settlement Class Vehicle or nine (9) months from the date in which the Settlement Class Vehicle’s original New Vehicle Limited Warranty period for the turbocharger expires, whichever date occurs later.

    A Chart that outlines the turbocharger Warranty Extension for the four categories of Settlement Class Vehicles described above is contained in the Class Notice (click here).

    General Terms and Conditions of the Turbocharger Extended Warranty:

    • The Extended Warranty is subject to the same terms and conditions set forth in the Settlement Class Vehicle’s New Vehicle Limited Warranty and Warranty Information Booklet, except that repairs to or replacement of a failed turbocharger under this Settlement are permissible pursuant to the terms and time and mileage limitations set forth above and in the Settlement Agreement, which is available here.
    • Damage resulting from abuse, alteration, modification, collision or crash, vehicle misuse or neglect, vandalism, and/or any other impact or outside force shall be excluded and not covered by the Extended Warranty.
    • The Extended Warranty will, until its expiration, be fully transferable to subsequent owners of Settlement Class Vehicles.
    • A vehicle is not eligible for an Extended Warranty if it has a branded title (including, but not limited to: “Totaled,” “Assembled,” “Dismantled,” “Flood,” “Junk,” “Rebuilt,” “Reconstructed,” “Lemon Law Buyback,” “Fleet,” “Mileage Unknown,” “Stolen,” or “Salvaged”) or if it was acquired by any person or entity from a junkyard, salvage facility, or body shop.
    • VWGoA shall not be responsible for, and shall not warranty, repair or replacement work performed on a Settlement Class Vehicle by an independent service center that is not an authorized Audi dealer.
    B. REIMBURSEMENT FOR PAST UNREIMBURSED OUT-OF-POCKET EXPENSES FOR QUALIFYING REPAIR OR REPLACEMENT OF AN Electric (After-Run) Coolant Pump THAT WAS PAID FOR PRIOR TO SEPTEMBER 14, 2018 (DATE OF COMMENCEMENT OF RECALL 19N4)

    If, prior to September 14, 2018 (Date of Commencement of Recall 19N4), a current or former owner or lessee of a Settlement Class Vehicle incurred and paid out-of-pocket expenses to repair or replace a failed Electric (After-Run) Coolant Pump in the Settlement Class Vehicle, then, upon the Effective Date of the Settlement, he/she may be entitled to reimbursement of said paid out-of-pocket expenses as follows:

    • If the repair or replacement was performed by an authorized Audi dealer, the Settlement Class Member shall be entitled to receive dollar-for-dollar reimbursement of the paid cost of the repair or replacement (parts and labor).
    • If the repair or replacement was performed by an independent service center and not an authorized Audi dealer, the Settlement Class Member shall be entitled to receive a reimbursement of the paid cost of the repair or replacement (parts and labor) limited to a maximum of $542.
    • Requirements and limitations are referenced below and listed in full in the Class Notice.
    C. REIMBURSEMENT FOR PAST UNREIMBURSED PAID ONE-DAY RENTAL CAR EXPENSE INCURRED WHILE RECALL 19O2 WAS BEING PERFORMED ON THE SETTLEMENT CLASS VEHICLE BY AN AUTHORIZED AUDI DEALER

    If, prior to April 12, 2021, a Settlement Class Member incurred and paid an out-of-pocket expense to rent a car while the Electric (After-Run) Coolant Pump in his/her Settlement Class Vehicle was being replaced at an authorized Audi dealer pursuant to Recall 19O2, and the need for the car rental was due to the fact that the authorized Audi dealer was unable to provide a free loaner vehicle that was requested by the Settlement Class Member, then, upon the Effective Date of the Settlement, the Settlement Class Member may be entitled to receive reimbursement of up to a maximum of one day of paid out-of-pocket rental car expenses incurred while Recall 19O2 was being performed. Requirements and limitations are referenced below and listed in full in the Class Notice.

    D. REQUIREMENTS FOR AND LIMITATIONS ON ENTITLEMENT TO REIMBURSEMENTS SET FORTH IN SECTIONS B AND C ABOVE

    To qualify for reimbursement of past paid out-of-pocket expenses as provided in Sections B and/or C above, Settlement Class Members must timely comply with the following requirements:

    1. Any Claim for Reimbursement must contain the required completed and signed Claim Form(s), copies of which were attached to the Class Notice and are available here, together with all required Proof of Repair Expense and/or Proof of Rental Car Expense documentation listed in the respective Claim Forms.
    2. The fully completed and signed Claim Form(s), together with all required Proof of Repair Expense and/or Proof of Rental Car Expense documentation, must be mailed to the Claim Administrator by First-Class Mail, postmarked no later than June 26, 2021.
    3. If the claimant is not a person to whom the Claim Form(s) was (were) addressed, and/or if the vehicle with respect to which a Claim is made is not the vehicle identified by VIN on the mailed Claim Form(s), the Claim must contain proof that the claimant is a Settlement Class Member and that the vehicle is a Settlement Class Vehicle.
    4. Each Claim for Reimbursement must include, in the Claim Form(s), a statement that the Settlement Class Member has not previously been reimbursed, from any other source, for all or part of the out-of-pocket expense for which reimbursement is being sought under this Settlement, or if any full or partial reimbursement was previously received, delineate the amount of the reimbursement received and the source of the reimbursement.
    5. The Claim Administrator may consider previously rejected reimbursement requests that, prior to this Settlement, were submitted by Settlement Class Members to VWGoA or Audi of America, Inc. (an operational unit of VWGoA) pursuant to the Electric (After-Run) Coolant Pump Recalls 19M1, 19O2, and/or 19N4, provided that they are timely resubmitted to the Claim Administrator, postmarked no later than the response deadline on your rejection letter, with the properly completed and signed Claim Form(s) and supporting Proof of Repair Expense and/or Proof of Rental Car Expense, in accordance with the terms and requirements set forth in the Notice and in the Settlement Agreement. If the Settlement Class Member is submitting a reimbursement claim that was previously rejected by VWGoA or Audi of America, Inc. in whole or in part, the Claim Form must set that forth, and the Settlement Class Member must provide, in addition to the Proof of Repair Expense and/or Proof of Rental Car Expense, the amount, if any, that was reimbursed pursuant to the prior request.
    6. Any reimbursement pursuant to this Settlement shall be reduced by any previous warranty, carefree maintenance, goodwill, reimbursement, refund, or other payment or concession for the Electric (After-Run) Coolant Pump repair or replacement that was paid or provided by VWGoA, an authorized Audi dealer, or any other entity (including insurers and providers of extended warranties or service contracts), including any reimbursement that was previously provided to the Settlement Class Member under any of the applicable Recalls.
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  6. Who can send in a claim for reimbursement?

    Any United States or Puerto Rico resident who purchased or leased a Settlement Class Vehicle and qualifies for reimbursement under the terms of the Settlement (see Class Notice and FAQ 5) was eligible to send in a Claim for reimbursement for qualifying past unreimbursed out-of-pocket expenses prior to June 26, 2021. Late claims are not eligible for reimbursement.

    However, the Settlement also provides an extended warranty for the turbocharger. The length of the warranty extension depends on the service history of your vehicle. You do not need to file a claim to obtain the extended warranty. The extended warranty does not provide a cash award and only applies to future repairs to the turbocharger as described by the warranty. The extended warranty is administered by Audi. Please contact your local authorized Audi dealership for further information about the turbocharger extended warranty.

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  7. How do I send in a claim for reimbursement? Do I need multiple Claim Forms for multiple vehicles?

    The Claim Filing Deadline was June 26, 2021, and late claims are not eligible for reimbursement. However, the Settlement also provides an extended warranty for the turbocharger. The length of the warranty extension depends on the service history of your vehicle. You do not need to file a claim to obtain the extended warranty. The extended warranty does not provide a cash award and only applies to future repairs to the turbocharger as described by the warranty. The extended warranty is administered by Audi. Please contact your local authorized Audi dealership for further information about the turbocharger extended warranty.

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  8. When do I get my reimbursement or learn whether I will receive a payment?

    If the Claims Administrator determines your Claim is valid, complete and should be approved, your reimbursement will be mailed to you after the “Effective Date” of the Settlement. The Court held a Final Fairness Hearing on June 16, 2021, and filed a Final Approval Order on June 22, 2021.

    The Effective Date of the Settlement will be the first business day after the Court enters a Final Order and Judgment approving the Settlement Agreement, and all appellate rights with respect to the Final Order and Judgment, other than those related solely to any award of attorneys’ fees, costs/expenses or service awards/payments, have expired or been exhausted in such a manner as to affirm the Final Order and Judgment. Information about the progress of the case will be available on this website.

    If the Claim Administrator determines your Claim should not be paid, you will be mailed a letter telling you this. If the reason for rejecting your Claim is due to a deficiency in your Claim Form and/or supporting proof, the letter will notify you of the deficiency in your Claim and what needs to be submitted and by when to correct the deficiency. To check on the status of your Claim, you can call 1-855-907-2083.

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  9. What am I giving up to stay in the Class?

    If the Settlement is approved by the Court, you will be entitled to all benefits of the Settlement to which you may be eligible under the Settlement’s terms and will be bound by the release of claims, meaning that you cannot sue, continue to sue, or be part of any other lawsuit about the same claims and issues that were asserted or could have been asserted in this case (except you will not be waiving any claims for personal injury or property damage other than damage to the Settlement Class Vehicles). It also means that all of the Court’s orders and judgments will apply to you and legally bind you. The Settlement Agreement, which you can view on this website, describes the legal claims that you will release if you remain in the Settlement.

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  10. What if i want to be excluded from this Settlement?

    The deadline to exclude yourself from the Settlement was May 12, 2021.

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  11. If I did not exclude myself, can I sue later?

    No, not for the same matters and legal claims that were asserted or could have been asserted in the Action, unless your claim is for personal injury or property damage (other than damage to the Settlement Class Vehicles).

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  12. If I excluded myself, can I get benefits from the Settlement?

    No, if you excluded yourself from the Settlement Class you will not get any benefits from this Settlement.

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  13. Do I have a lawyer in this case?

    The Court has appointed the law firm of Lemberg Law, LLC to represent the Settlement Class Members. This law firm is called “Class Counsel.” Class Counsel will represent you and others in the Settlement Class. You are not being charged for the services of these lawyers. If you want to be represented by your own lawyer, you may hire one at your own expense, but it is not necessary to have your own lawyer in order to participate in the Settlement.

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  14. How will the lawyers be paid, and will the Settlement Class Representatives receive service awards?

    Class Counsel have prosecuted this case on a contingency basis. They have not received any fees or reimbursement for costs and expenses associated with this case. Class Counsel will file an application with the Court requesting an award of reasonable attorney fees and reasonable costs and expenses (“Fees and Expenses”) in an amount not exceeding a combined total sum of $1,050,000. VWGoA has agreed not to contest Class Counsel’s application for Fees and Expenses up to and not exceeding that combined total amount, and Class Counsel has agreed not to accept any award for Fees and Expenses that exceeds that combined total amount.

    Class Counsel will also apply to the Court for service awards for the named Plaintiffs in this Action, who have conditionally been approved as Settlement Class representatives, in the following amounts, for their efforts in pursuing this litigation for the benefit of the Settlement Class: $5,000 to Plaintiff Scott D. Sager, $5,500 to Plaintiff Carmelita Nunez, and $3,500 each to Plaintiffs Edward Young, Renada Hall, Michael Marcotte, Sharon Scott, and Jack Whittington. VWGoA has agreed not to contest the application for service awards in these amounts.

    Class Counsel Fees and Expenses and Settlement Class representative service awards must be approved by the Court. However, any award for Class Counsel Fees and Expenses and any service awards are paid by Defendant and will not reduce any benefits available to you under the Settlement.

    Class Counsel’s motion for Fees and Expenses and Settlement Class representative service awards will be filed no later than April 15, 2021, and a copy is available for review on this website.

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  15. How do I tell the Court if I object to the Settlement?

    The deadline to object to the Settlement was May 12, 2021.

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  16. What is the difference between objecting and excluding myself?

    Objecting is simply telling the Court that you do not like something about the Settlement and/or Class Counsel’s requests for fees and expenses or Settlement Class Representative service awards. Excluding yourself from the Settlement is telling the Court that you do not want to be part of the Settlement Class and the Settlement. You cannot do both. If you exclude yourself from the Settlement, you cannot object because the case no longer affects you.

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

    The Court held a Final Fairness Hearing at 2:00 p.m. EDT on June 16, 2021, before Judge Esther Salas of the United States District Court for the District of New Jersey, and filed a Final Approval Order on June 22, 2021.

    Please check the “Important Updates” section on the home page of this website for the most recent case updates.

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  18. What happens if I do nothing at all?

    If you did nothing, after the Settlement Effective Date you are bound by the Settlement, and may receive the benefits of the Settlement to the extent that you are eligible under the Settlement terms. You may be eligible to qualify for one or all of the following benefits afforded by the Settlement:

    • a free warranty extension to cover repair or replacement by an authorized Audi dealer of a failed turbocharger during certain time and mileage periods. This benefit applies to all qualifying Settlement Class Vehicles and no claim form is required;
    • reimbursement for certain out-of-pocket expenses previously paid for past repair or replacement of electric (after run) coolant pumps if you submit a valid, complete and timely claim; and/or
    • reimbursement for certain past rental car expenses incurred during the time that a particular recall (Recall 19O2) was being performed on your Settlement Class Vehicle, if you submitted a valid, complete and timely claim.

    The terms and criteria for eligibility of the Settlement benefits are set forth in the Class Notice and reiterated in FAQs 4, 5 and 6.

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  19. Can I have my check reissued?

    All reissue requests must be sent in writing to the Settlement Administrator at the address listed below by 90 days after the check issue date:

    Coolant Pump Claim Administrator
    P.O. Box 4418
    Portland, OR 97208-4418

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  20. Can I have the name on the check changed?

    All reissue requests must be sent in writing to the Settlement Administrator at the address listed below. All requests must include your full name, your return address, and your signature.

    Coolant Pump Claim Administrator
    P.O. Box 4418
    Portland, OR 97208-4418

    If the name of the Class Member on the check should be changed, please send in documentation, as applicable, according to the following list:

    • Name Change – If your name has changed, please provide documentation showing this to be the case, which can include documents such as a marriage certificate, divorce decree, or court papers indicative of a name change.
    • Name Removal – In order to have a name removed from a check reissue, either have all parties on the check sign a letter requesting the name(s) to be removed, or provide documentation that shows that one party is unable to negotiate the check (i.e. death certificate).
    • Deceased Class Member – If the Class Member indicated on the check is deceased, please submit acceptable documentation showing that you are the beneficiary of his or her Estate. Acceptable documentation is a death certificate, together with the pertinent portion of the Will, or Court Order/Letters Testamentary naming you as Personal Representative, Administrator, Executor, or Executrix.
    • Incapacitated Class Member – If the Class Member cannot act on his or her own behalf, acceptable documentation is a Power of Attorney, or guardianship or custodial paperwork.
    • Closed Business – If you are the legal representative of a business which is no longer active, please include a letter with instructions for the name that should be included on the replacement check, as well as documentation proving you are authorized to act on behalf of the business. Documentation may include Articles of Incorporation, Articles of Organization, Articles of Dissolution, or any other similar legal documentation that explicitly states you are, or were, an acting party for the business.

    We will review the letter and documentation and will contact you if more information is required.

    For reasons of security, a check reissue cannot take place until either the original check is received back by us, a mailing has been returned to us as undeliverable, or until the original stale date of the check has passed or expired.

    Because one of these events must occur before we can act on your request, it is not possible for us to provide an estimated date for the reissue to take place. We thank you for your patience.

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  21. Where is my check reissue?

    Check reissues are subject to additional review. If nothing further is needed, your payment will mail within the next few weeks. If there are additional requirements, you will be notified by mail or email.

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  22. How did you calculate my payment?

    Your reimbursement check is based on the repair and/or rental amounts substantiated by the invoices and other supporting documents, including proof of payment, that you provided with your claim. All calculations were then made in accordance with the award provisions outlined in the Settlement Agreement, which is available here.

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  23. How do I get more information?

    This website and the Class Notice summarize the proposed Settlement. More details are available in the Settlement Agreement and other court documents, all of which are available on the Important Documents section of this website. You may also contact the Claim Administrator with any questions at:

    Coolant Pump Claim Administrator
    P.O. Box 4418
    Portland, OR 97208-4418
    1-855-907-2083 (Toll-Free)
    info@CoolantPumpSettlement.com

    Updates regarding the case will be available on this website.

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