Plaintiff brings this action for actual damages, equitable relief, including restitution, injunctive relief, and disgorgement of profits, and all other relief available on behalf of himself and all similarly situated individuals and entities (the “Class”) who own, lease or have owned or have leased model year 2016 or 2017 Jaguar XE, Jaguar XF, Jaguar XJ or Jaguar F-Pace vehicles (hereinafter, collectively, the “Vehicles”) manufactured and/or sold by Jaguar.
All of the claims asserted herein arise out of Jaguar’s design, manufacture, and warranting of the Vehicles, as well as Jaguar’s advertising, promoting, marketing, distributing, selling and leasing of the Vehicles as one of the most dependable, safe, and reliable vehicles available.
One of the features of each Vehicle is the multimedia and navigation system (commonly referred to as the “Infotainment System”) that features a touchscreen with touch and swipe controls for the operation of key vehicle functions including navigation, music, phone, climate and driver assistance systems.
The Vehicles are designed and manufactured with uniform and inherent design defects in the Infotainment Systems that cause one or more of the key vehicle functions to fail and renders them unusable (“Defect”).
As a result of the Defect, the Infotainment System and key vehicle functions fail to operate or function as designed. These resulting Vehicle failures from the Defect include, without limitation, failure of the Infotainment System screen to appear on Vehicle start-up, rear camera failing to appear or to function as designed, front parking sensors failing to activate as designed, freezing of satellite radio, failure to recognize USB media, intermittent Bluetooth connectivity and Infotainment System remaining powered after Vehicle shutdown.