The federal court overseeing this case authorized the Notice to inform you about a proposed class action settlement in a lawsuit known as In re: ZF-TRW Airbag Control Units Products Liability Litigation, Case No. 2:19-ml-02905-JAK. The case is pending before the Honorable John A. Kronstadt in the United States District Court for the Central District of California.

Plaintiffs Larae Angel, Bobbi Jo Birk-LaBarge, John Colbert, Brian Collins, Gerson Damens, Bonnie Dellatorre, Dylan DeMoranville, Joseph Fuller, Tina Fuller, Lawrence Graziano, Michael Hernandez, Kinyata Jones, Diana King, Richard Kintzel, Carl Paul Maurilus, Kenneth Ogorek, Burton Reckles, Dan Sutterfield, Amanda Swanson, and Lore Van Houten (together, the “Settlement Class Representatives”) allege that Hyundai and Kia designed and sold vehicles with a defective ZF-TRW ACU. The ZF-TRW ACU is an electrical component that controls the functions of various safety features, including airbags.

The Settlement Class Representatives allege the ZF-TRW ACUs in the Hyundai and Kia Class Vehicles are vulnerable to an electrical overstress condition that can cause the vehicles’ airbags and other passenger safety systems to malfunction during a collision, which may result in airbag non-deployment or other safety failures. See FAQ 2 below for a list of the Hyundai and Kia Class Vehicles.

No party has been found liable for any claims alleged in the lawsuit. The Settling Defendants deny all claims and allegations of wrongdoing in the lawsuit. The Court has not decided who is right. Instead, the Parties have agreed to this Settlement to avoid the costs, risk, and delays associated with continuing this complex and time-consuming litigation.

The Notice explains the litigation, the Settlement, and your legal rights and options under it. If you have any questions, please contact the Settlement Notice Administrator at 1-866-287-0740 or HKinfo@ACUSettlement.com

The Class consists of all persons or entities who or which, on April 14, 2025, own or lease, or previously owned or leased, Hyundai and Kia Class Vehicles that were originally sold or leased in the United States or any of its territories or possessions.

To check whether you have a Hyundai or Kia Class Vehicle, please enter your Vehicle Identification Number (“VIN”) in the VIN lookup tool.

If you do not know your VIN, please check the driver’s side dashboard and/or driver’s side door post, which will contain the 17-digit VIN for your vehicle. You should take a photo of the VIN with your phone so you have easy access to the number when you’re filing a claim.

Eligibility will be determined by VIN. The Hyundai and Kia Class Vehicles are the:

• 2011-2019 Hyundai Sonata;
• 2011-2019 Hyundai Sonata Hybrid;
• 2018-2023 Hyundai Kona;
• 2022-2023 Hyundai Kona N;
• 2019-2021 Hyundai Veloster;
• 2010-2013 Kia Forte;
• 2010-2013 Kia Forte Koup;
• 2011-2020 Kia Optima;
• 2011-2016 Kia Optima Hybrid; and
• 2011-2012, 2014 Kia Sedona.

If you are not sure whether you are a Class Member, or have any other questions about the Settlement, please contact the Settlement Notice Administrator at 1-866-287-0740 or HKinfo@ACUSettlement.com

The following entities and individuals are excluded from the Settlement Class:

• Hyundai and Kia, their officers, directors, employees, and outside counsel; their affiliates and affiliates’ officers, directors, and employees; their distributors and distributors’ officers and directors; and Hyundai’s and Kia’s Dealers and their officers and directors;
• Hyundai Mobis Co., Ltd. and Mobis Parts America, LLC, their officers, directors employees, and outside counsel, and their affiliates and affiliates’ officers, directors, and employees;
• Settlement Class Counsel, Plaintiffs’ counsel, and their employees;
• Judicial officers and their immediate family members and associated court staff assigned to this case;
• Persons or entities who previously released their economic loss claims with respect to the issues raised in the Action in an individual settlement with Hyundai and Kia, with Hyundai Mobis Co., Ltd. or Mobis Parts America, LLC, or with any of them; and
• Persons or entities who or which timely and properly exclude themselves from the Class.

For more information, please review the Settlement Agreement.

If approved, this Settlement will provide $62,100,100 in payments and credits (the “Settlement Amount”). The Settlement Amount will fund numerous Settlement benefits for eligible Class Members.

The Settlement benefits include:

1. Reimbursement for certain reasonable out-of-pocket expenses related to the Recalls;
2. Residual distribution payments of up to $350 for Recalled Vehicles and $150 for Unrecalled Vehicles for Class Members who submitted out-of-pocket claims or filed a claim for a residual payment, including those who own or lease Unrecalled Vehicles;
3. A New Parts Warranty for the new parts installed pursuant to the Recalls to address potential airbag non-deployment due to electrical overstress for ten (10) years from the date of the Preliminary Approval Order.
4. A robust inspection program.
5. An outreach program designed to increase Recall Remedy completion rates; and
6. A future rental car reimbursement, loaner vehicle, and outreach program.

Hyundai recalled the following Hyundai Class Vehicles in NHTSA Recall No. 18V-137:

• Certain 2011-2013 Hyundai Sonata; and
• Certain 2011-2012 Hyundai Sonata Hybrid.

Kia recalled the following Kia Class Vehicles in NHTSA Recall No. 18V-363:

• 2010-2012 and certain 2013 Kia Forte;
• 2010-2012 and certain 2013 Kia Forte Koup;
• 2011-2012 and certain 2013 Kia Optima;
• 2011-2012 Kia Optima Hybrid; and
• 2011-2012 Kia Sedona.

If you own(ed) or lease(d) one of these Recalled Vehicles you may seek reimbursement for certain reasonable out-of-pocket expenses that you incurred to complete the Recalls, as follows:

• Unreimbursed rental car expenses for a rental car comparable to your Recalled Vehicle, or other transportation expenses you incurred, while awaiting completion of the Recall Remedy from a Hyundai or Kia Dealer;
• Towing charges to a Hyundai or Kia Dealer for completion of the Recall Remedy;
• Childcare expenses incurred while the Recall Remedy was or is being performed on your Recalled Vehicle by the Hyundai and Kia Dealer;
• Unreimbursed out-of-pocket costs associated with repairing ZF-TRW ACUs; and
• Lost wages resulting from lost time from work directly associated with the drop off and/or pickup of your Recalled Vehicle to/from a Hyundai or Kia Dealer for performance of the Recall Remedy.

You must submit a claim by March 29, 2027 to seek reimbursement for your out-of-pocket expenses. After you submit your claim, the court-appointed Settlement Special Administrator will review your claim to verify your out-of-pocket expenses and determine the reimbursement payment you will be eligible to receive. The Settlement Special Administrator’s decisions regarding claims for reimbursement of out-of-pocket expenses shall be final and not appealable.

For more information about how to submit a claim, please review FAQ 6 below.

You cannot submit a claim for reimbursement of out-of-pocket expenses if your Hyundai and Kia Class Vehicle has not been recalled due to the ZF-TRW ACU. Hyundai and Kia have not initiated a ZF-TRW ACU recall for following Hyundai and Kia Class Vehicles:

• Certain 2011-2013 and all 2014-2019 Hyundai Sonata;
• Certain 2011-2012 and all 2013-2019 Hyundai Sonata Hybrid;
• 2018-2023 Hyundai Kona;
• 2022-2023 Hyundai Kona N;
• 2019-2021 Hyundai Veloster;
• Certain 2013 Kia Forte;
• Certain 2013 Kia Forte Koup;
• Certain 2013 and all 2014-2020 Kia Optima;
• 2013-2016 Kia Optima Hybrid; and
• 2014 Kia Sedona.

If you have one of the above Unrecalled Vehicles, you will become eligible to submit a claim for reimbursement of reasonable out-of-pocket expenses if a recall is issued for the ZF-TRW ACU in your Hyundai or Kia Class Vehicle before the Claims Period expires.

Even if there is no ZF-TRW ACU recall for your Hyundai or Kia Class Vehicle, you may still submit a claim for a residual distribution payment under the Settlement. All Class Members may submit a Residual Distribution claim, regardless of whether their Hyundai or Kia Class Vehicle was recalled.  Please review FAQ 11 for more information.

The claims process is easy to complete and will require supporting documentation to show your out-of-pocket expenses, such as a receipt or invoice, or a signed affidavit if you don’t have a receipt or invoice. To submit your claim, please use the Online Claim Form, input your VIN, and fill out the Claim Form.

If you would prefer to submit your Claim Form and supporting documentation by mail, you can download and print forms from the Important Documents page or request a hardcopy form to be mailed to you by calling 1-866-287-0740. For faster claims processing, you should submit your claim online, rather than by mail.

The Settlement Notice Administrator will issue payments for approved out-of-pocket expenses after the Effective Date.

The “Effective Date” will depend on when the Court enters its order finally approving the Settlement and its Judgment, and whether there is an appeal of the Judgment.

Please check this website for updates on Settlement payments.

You may submit a claim for out-of-pocket expenses for each Recalled Vehicle you own(ed) or lease(d), as long your out-of-pocket expenses are not duplicative.

For example, if you have two Recalled Vehicles you may submit a separate claim for the expenses you incurred to complete the Recall for each vehicle, but you may not seek reimbursement twice for the same out-of-pocket expense.

Class Members must submit their claims for reimbursement of out-of-pocket expenses within 18 months of the Final Approval Order. 

Under the current schedule, the claims deadline is no earlier than March 29, 2027.  Please check back regularly for updates on the claims deadline, which may change.

After all out-of-pocket expense payments and other settlement costs have been paid, the remaining funds will be distributed on a per capita basis to each Class Member who (a) submitted out-of-pocket claims, or (b) submitted a claim only for a residual distribution payment.

All Class Members may submit a claim for a residual distribution payment, regardless of whether their Hyundai or Kia Class Vehicle was included in the Recalls.

Residual payments shall be up to $350 for Recalled Vehicles and $150 for Unrecalled Vehicles, unless the Parties agree to higher caps and jointly recommend the higher amount to the Settlement Special Administrator for approval.

If there are any funds remaining in the Settlement Fund after making the payments described in Out-of-Pocket Process section above, and if it is not feasible and/or economically reasonable to distribute the remaining funds to Class Members who submitted claims for a residual distribution payment, then the balance shall be distributed cy pres.

See FAQ 16 below for more information regarding cy pres distribution.

Once the Court grants final approval of the Settlement, the Settling Defendants shall institute a Settlement Inspection Program to inspect Hyundai and Kia Class Vehicles when (1) a Hyundai or Kia Class Vehicle was involved in a moderate or severe frontal crash and (2) Hyundai or Kia was notified that a ZF-TRW ACU, seatbelt pretensioner, and/or airbag did not deploy as intended.

For more information, please review the Settlement Inspection Program Protocol that is attached as Exhibit 3 to the Settlement Agreement. 

Once the Court grants final approval of the Settlement, the Settling Defendants will provide a warranty for the new parts installed pursuant to the Recalls (the “New Parts Warranty”). The New Parts Warranty will last for 10 years. The 10-year period of the New Parts Warranty begins on April 14, 2025.

The New Parts Warranty will cover repairs or replacement (including parts and labor) that become necessary due to a defect in a new part installed pursuant to the Recalls. For example, if a problem with a part installed pursuant to the Recalls causes the airbag warning light to illuminate, the New Parts Warranty shall cover the repair or replacement of that part.

A Class Member’s rights under the New Parts Warranty are transferred with the vehicle, which means that the coverage follows the vehicle if it is sold to another owner. Inoperable or junkyard vehicles with a scrapped, rebuilt, or flood-damaged title, vehicles with altered mileage, racing or similarly modified vehicles intended for non-street use or vehicles that are dismantled, crushed, or fire damaged, are not eligible for the New Parts Warranty.

If the ZF-TRW ACUs in Unrecalled Vehicles are recalled in the future, Hyundai and Kia shall extend the New Parts Warranty’s coverage for the parts installed pursuant to that future ZF-TRW ACU recall.

Once the Court grants final approval of the Settlement, Hyundai and Kia will implement an outreach program designed to increase Recall Remedy completion rates for Recalled Vehicles (the “Outreach Program”).

The Outreach Program is intended to be a program that will adjust and change its methods of outreach as is necessary to achieve its goal of maximizing completion of the Recall Remedy.

The goal of the Outreach Program is to maximize the completion of the Recall Remedy. To do so, Hyundai and Kia will implement various methods of outreach to encourage owners of Recalled Vehicles to complete the Recall, and will evaluate and modify these outreach methods as needed.

The budget for the Outreach Program is $3,500,000. To the extent the Outreach Program expenditures are less than $3,500,000, Hyundai and Kia will deposit the difference into the Settlement Fund for distribution with the residual payments.

Subject to dealer availability, Hyundai and Kia shall provide loaner vehicles to Class Members who, after the Effective Date, seek a Recall Remedy from a Hyundai and Kia Dealer during the Claims Period and request a courtesy loaner vehicle while the Recall Remedy is being performed. Class Members may alternatively submit a claim for reimbursement from the Settlement Fund for reasonable rental car costs if the Class Member does not receive a loaner vehicle.

If there is a ZF-TRW ACU recall for Unrecalled Vehicles, Class Members of such Unrecalled Vehicles may request a courtesy loaner vehicle while the Recall Remedy is being performed or alternatively may submit a claim for reimbursement of reasonable rental car costs from the Settlement Fund during the Claims Period. Hyundai and Kia shall also provide outreach related to any such recalls for the Unrecalled Vehicles.

Hyundai and Kia shall collectively receive a credit of $10,000,000 against the Settlement Amount for providing Future Loaner Vehicles and Future Outreach Programs.

If there are any Settlement funds that remain after paying all eligible claims and other settlement costs, and making all residual distribution payments (as described in FAQ 8, FAQ 9, FAQ 10, and FAQ 11 above), and if it is not feasible and/or economically reasonable to distribute the remaining funds to Class Members who submitted claims, then the remaining balance shall be distributed “cy pres,” which means it is paid to charitable causes that indirectly benefit the Class.

The cy pres recipient(s) in this case, if any, is subject to the agreement of the Parties and Court approval. Please check this website after March 29, 2027 for updates about any cy pres distribution.

In a class action, one or more people called “class representatives” sue on behalf of other people who have similar claims. All these people are known as a “Class” or “Class Members.” When a class action is settled, the Court resolves the issues in the lawsuit for all Class Members, except for those who request to be excluded from (or “opt out” of) the Class. Opting out means that you will not receive benefits under the Settlement. The opt out process is described in FAQ 21 and FAQ 22 below.

If the Settlement becomes final and you do not exclude yourself, you will release the Settling Defendants and the Released Parties from liability and will not be able to sue them about the issues in the lawsuit.

Under the Settlement, you are not releasing and are expressly reserving all rights relating to claims for personal injury, wrongful death, or actual physical property damage arising from an incident involving a Hyundai or Kia Class Vehicle, including the deployment or non-deployment of an airbag.

The Settlement Agreement at Section VII describes the released claims in necessary legal terminology, so read it carefully. 

You can talk to one of the lawyers listed in FAQ 23 below for free or you can, of course, talk to your own lawyer at your own expense if you have questions about the released claims or what they mean.

If you are a Class Member and choose to do nothing, you will not receive certain benefits provided under this Settlement. You will also be bound by all terms of the Settlement, which means you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against the Settling Defendants and the Released Parties about the legal issues in this case.

If you do not want to receive the Settlement benefits described above and/or you want to retain the right to sue the Settling Defendants and/or the Released Parties about the legal issues in this case, then you must take steps to remove yourself from the Settlement. You may do this by asking to be excluded from the Settlement—sometimes referred to as “opting out.”

To opt out of the Settlement, you must mail a written request to the Settlement Notice Administrator at the address provided in this question below. Your request must include:

• Your name, address, and telephone number;
• The VIN(s) and the dates of your ownership or lease of the Hyundai and/or Kia Class Vehicle(s);
• A statement saying “I wish to exclude myself from the Class in In re: ZF-TRW Airbag Control Units Products Liability Litigation, Case No. 2:19-ml-02905-JAK (C.D. Cal.); and
• Your handwritten, personal signature (electronic signatures, including DocuSign, are invalid and will not be considered personal signatures).

You cannot ask to be excluded over the phone or on the Settlement Website. You must mail your letter with your exclusion request postmarked no later than August 25, 2025 to:

Hyundai-Kia Airbag Control Unit Settlement
c/o JND Legal Administration
PO Box 91478
Seattle, WA 98111
HKinfo@ACUSettlement.com

Your letter with your exclusion request must be postmarked on or before August 25, 2025, to be considered by the Court. The deadlines found in the Notice may be changed by the Court. Please check this website regularly for updates regarding the Settlement.

No. If you do not timely submit your request for exclusion or fail to include the required information in your request for exclusion, you will remain a Class Member and will not be able to sue the Settling Defendants and/or the Released Parties about the claims that the Settlement resolves.

If you do not exclude yourself from the Settlement, you will be bound like all other Class Members by the Court’s orders and judgments in this class action lawsuit, even if you do not file a claim.

You will not get money or any other benefits from the Settlement if you exclude yourself. If you exclude yourself from the Settlement, do not send in a Claim Form asking for benefits from the Settlement.

The Court has appointed lawyers from the law firms Baron & Budd, P.C. and Lieff Cabraser Heimann & Bernstein, LLP to represent you and other Class Members. These lawyers are called “Co-Lead Counsel.” Their contact information is as follows:

If you want to be represented by your own lawyer, you may hire one at your own expense.

Co-Lead Counsel will ask the Court to award the attorneys representing the Class up to 33% percent of the Settlement Amount (i.e., up to $20,493,033.30) to compensate them for their attorneys’ fees and costs in litigating this case and securing this nationwide Settlement for the Class. Co-Lead Counsel will also ask the Court to award each of the Settlement Class Representatives a service award of up to $2,500 each for their work in this litigation.

The Court must approve Co-Lead Counsel’s requests for fees, costs, and Settlement Class Representative Service Awards before they are paid from the Settlement Fund. Under the current schedule, Co-Lead Counsel will submit their request by July 15, 2025, and that document will be available on the Important Documents page shortly after it is filed with the Court. Class Members will have an opportunity to comment on and/or object to the requests for attorneys’ fees, costs and Settlement Class Representative Service Awards, as explained further in FAQ 25 and FAQ 26 below. Please check this website regularly for updates regarding Co-Lead Counsel’s request for attorneys’ fees, costs, and Settlement Class Representative Service Awards.

If you do not exclude yourself from the Settlement, you may object to it. The Court will consider your views in deciding whether to approve or reject the Settlement. If the Court does not approve the Settlement, no Settlement benefits will be made available to the Class, and the lawsuit will continue.

To object to the Settlement or to Co-Lead Counsel’s request for attorneys’ fees, costs, and Settlement Class Representative Service Awards, you or your attorney must deliver to Co-Lead Counsel and to Defendants’ Counsel, and file with the Court, on or before August 25, 2025, a written statement with the following information:

• The MDL case name (In re ZF-TRW Airbag Control Units Products Liability Litigation);
• Your name, actual address, and telephone number;
• The VIN(s) of your Hyundai and/or Kia Class Vehicle(s);
• The date(s) of purchase or lease of any Hyundai and/or Kia Class Vehicle(s);
• A written statement of your objections. Your objections must also state whether they apply only to you, to a specific subset of the Class, or to the entire Class, and state with specificity the grounds for the objections. The statement must also indicate whether you are represented by a lawyer in submitting your objection; and
• Your personal signature.

Any documents supporting your objection must also be attached to the objection.

If an objection is made through a lawyer, the objection must also include (in addition to the above items):

• The number of times the objector has objected to a class action settlement within the five years preceding the date that the objector files the objection;
• The caption of each case in which the objector has made such objection; and
• A statement of the nature of the objection.

The lawyer(s) asserting the objection must also:

• File a notice of appearance with the Court before the deadline to submit objections;
• File a sworn declaration attesting to his or her representation of each Class Member on whose behalf the objection is being filed, and specify the number of times during the prior five-year period that the lawyer or their law firm has objected to a class action settlement; and
• Comply with the written objection requirements described in Section VI.A. of the Settlement Agreement.

You must deliver your written objection to Co-Lead Counsel and Defendants’ Counsel, and file with the Court, on or before August 25, 2025.

Excluding yourself is telling the Court that you do not want to be part of the Class and do not want to receive any benefits under the Settlement or release any of the claims resolved by the Settlement. If you exclude yourself, you have no basis to object because the Settlement no longer affects you.

Objecting is telling the Court that you do not like something about the Settlement, the requested fees, costs, and/or Settlement Class Representative Service Awards. You may object only if you stay in the Class. You do not need to submit a claim to object, but if you object, you must still submit a claim to receive compensation under the Settlement.

The Court will hold a Fairness Hearing on September 29, 2025 at 8:30 a.m. PST, at the United States District Courthouse, Central District of California, First Street Courthouse, 350 W. First Street, Courtroom 10B, Los Angeles, CA 90012.

At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate, and whether to approve the request for attorneys’ fees, costs, and the request for Settlement Class Representative Service Awards. If there are objections, the Court will consider them and may listen to people who have asked to speak at the hearing (see FAQ 29 below). The Court will decide whether to grant final approval of the Settlement, and, if so, how much to pay the lawyers representing you and the Class. We do not know how long these decisions will take.

The Court may reschedule the Fairness Hearing, so check this website for further updates.

No, you do not need to attend the Fairness Hearing. Co-Lead Counsel will answer any questions the Court may have. If you wish to attend the hearing, you are welcome to come at your own expense. If you submit an objection to the Settlement, you do not have to come to Court to talk about it, but you have the option to do so if you provide advance notice of your intention to appear (see FAQ 29 below). As long as you submitted a written objection with all of the required information on time with the Court, the Court will consider it. You may have your own lawyer attend at your expense, but it is not required.

You or your attorney can ask the Court for permission to speak at the Fairness Hearing. To do this, you must file with the Court a written notice of your intent to appear at least 10 days before the hearing. Based on the Court’s current schedule (see FAQ 27 above), the deadline to file a written notice of your intent to appear is September 19, 2025. You must also send a copy of your notice to Co-Lead Counsel and to the Settling Defendants’ Counsel at the addresses listed in FAQ 25 above.

If you’ve requested to speak, you must be present at the start of the Fairness hearing at 8:30 a.m. PST on September 29, 2025. Please note that the Court may reschedule the Fairness Hearing, so be sure to check this website for any updates.

The Notice summarizes the proposed Settlement. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement and other documents and information about the Settlement on the Important Documents page. You can also call the toll-free number, 1-866-287-0740 or write the Settlement Notice Administrator at:

Hyundai-Kia Airbag Control Unit Settlement
c/o JND Legal Administration
PO Box 91478
Seattle, WA 98111
HKinfo@ACUSettlement.com