Plaintiff brings this action on behalf of themselves and all similarly-situated individuals and entities who own or have owned Land Rover LR2 vehicles (the “Vehicles”) manufactured and/or sold by the Defendant, Jaguar Land Rover North America, LLC (“Land Rover” or “Defendant”) containing defective electrical systems which cause the battery to drain and cause the vehicle to have starting problems. The defective electrical system requires numerous service calls, attempted repairs, and upgrades without correcting the defect.
According to the complaint this battery drain is caused by a defective electrical system and/or entertainment system in the Vehicles (the “Defect”). The defective electrical system and/or entertainment system does not perform its essential function because it causes the battery to drain.
As alleged, the Vehicles are designed and manufactured with a uniform and inherent design defect that causes the battery to drain because the electrical and/or entertainment systems is defective. As a result of the Defect, the Vehicles do not start and the battery needs to be replaced. The damages are a result of the defective electrical and/or entertainment systems and their defective components.
Land Rover knew, or was reckless in not knowing, at or before the time it sold the first unit, that the Vehicles contained the Defect and that the Vehicles’ batteries would fail prematurely due to the Defect. Land Rover had sole and exclusive possession of this knowledge. Notwithstanding this knowledge, Land Rover made uniform and material misrepresentations and uniformly concealed material information in its marketing, advertising, and sale of the Vehicles, which Land Rover knew to be defective, both at the time of sale and on an ongoing basis.