B011321

6/3/2021
01 13 21_CLASS ACTION SETTLEMENT: N54/N54T/N55 ELECTRIC ENGINE COOLANT PUMP
SIB 01 13 21
CLASS ACTION SETTLEMENT: N54/N54T/N55 ELECTRIC ENGINE
COOLANT PUMP
2021-05-05
MODEL
Class Vehicles
E-Series
E88
E88
E90
E90
E92
E92
Model Years
2008, 2009 and 2010
2011, 2012 and 2013
2007, 2008, 2009 and 2010
2011
2007, 2008, 2009 and 2010
2008, 2009 and 2010
E92
2011, 2012 and 2013
E93
E93
E60
2007, 2008, 2009 and 2010
2011, 2012 and 2013
2008, 2009 and 2010
2011, 2012, 2013, 2014, 2015 and
2016
2008, 2009 and 2010
2010, 2011, 2012, 2013, 2014,
2015 and 2016
2013, 2014, 2015 and 2016
2014, 2015 and 2016
2012, 2013, 2014, 2015 and 2016
2014, 2015 and 2016
2012, 2013, 2014, 2015 and 2016
2014, 2015 and 2016
2011 and 2012
2013, 2014 and 2015
2013, 2014 and 2015
2013, 2014 and 2015
2011, 2012, 2013, 2014, 2015,
2016 and 2017
2015 and 2016
2016, 2017 and 2018
2007, 2008, 2009 and 2010
2011, 2012 and 2013
2008, 2009 and 2010
2011, 2012, 2013 and 2014
2015, 2016, 2017, 2018 and 2019
2011, 2012, 2013, 2014, 2015 and
2016
2009, 2010, 2011, 2012, 2013,
2014, 2015 and 2016
F10
E61
F07
F06
F06
F12
F12
F13
F13
F01, F02
F01, F02
F02
E84
F25
F26
F26
E70
E70
E71
E71
F16
E89
E89
Model Description
135i Convertible
135i Convertible
335i and 335xi Sedan
335i and 335xi Sedan
335i Coupe
335i xDrive Coupe
335is, 335i Coupe and xDrive
Coupe
335i Convertible
335is and 335i Convertible
535i Sedan and xDrive Sedan
535i Sedan, xDrive Sedan and
ActiveHybrid 5
535i xDrive Sports Wagon
535 Gran Turismo and xDrive Gran
Turismo
640i Gran Coupe
640i xDrive Gran Coupe
640i Convertible
640i xDrive Convertible
640i Coupe
640i xDrive Coupe
740i and 740Li Sedan
740i, 740Li and 740Li xDrive Sedan
ActiveHybrid 7
X1 xDrive35i
Motor
N54
N55
N54
N55
N54
N54
X3 xDrive35i
N55
X4 xDrive35i
X4 M40i
X5 xDrive30i
X5 xDrive35i
X6 xDrive35i
X6 xDrive35i
X6 sDrive 35i and xDrive35i
N55
N55
N52K
N55
N54
N55
N55
Z4 sDrive35is
N54T
Z4 sDrive35i
N54
N54T/N55
N54
N54T/N55
N54
N55
N54
N55
N55
N55
N55
N55
N55
N55
N54
N55
N55
N55
SITUATION
With the court’s FINAL approval, BMW of North America, LLC (BMW NA) has entered a nationwide settlement
with the plaintiffs in the following class action: Oliver, et al v. BMW NA, et al
This Settlement is effective on and after Wednesday May 5, 2021
Eligible Class Vehicles
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01 13 21_CLASS ACTION SETTLEMENT: N54/N54T/N55 ELECTRIC ENGINE COOLANT PUMP
This bulletin applies to Class Members who are the current owners/lessees of Class Vehicles that have not
opted-out of this Settlement, therefore, accepting the corresponding Class Member benefit.
The eligible Class Vehicles have been updated with the following VIN-specific Vehicle Comment in the
DCSnet Warranty Vehicle Inquiry.
Please see SI B01 13 21 (DC 11 51 90 02 00): The current Class Member owner or lessee
and their Class Vehicle are eligible to receive the applicable Service Benefit that is
provided through the Electric Engine Coolant Pump (N54 N54T N55 Engine) Class Action
Settlement.
Non-Eligible Class Vehicles
Certain Class Members have opted out of this Settlement. Those Class Members are excluded and not
eligible for any of the corresponding Class benefits.
The non-eligible Class Vehicles have been updated with the following VIN-specific Vehicle Comment in the
DCSnet Warranty Vehicle Inquiry.
SI B01 13 21: The current owner/lessee of this Class Vehicle has opted-out of the Electric
Engine Coolant Pump (N54 N54T N55 Engine) Class Action Settlement. By asking to be
excluded, the owner/lessee of this vehicle is not eligible to receive any of the Settlements
Class benefits.
Note: Before performing a repair and submitting a claim, first confirm that the vehicle has the Eligible Class
Vehicle opted-in Vehicle Comment above in the DCSnet Warranty Vehicle Inquiry.
Electric Engine Coolant Pump (N54, N54T,
N55 Engines).
(Item #1 Electric Water Pump and #2
Thermostat: E70 X5 xDrive35i N55
components shown)
Settlement Class Vehicles
US-specification MY 2007-2019 BMW vehicles listed above that were purchased or leased, registered, and
operated in the United States, including the District of Columbia and Puerto Rico.
Settlement Class Members
Are persons or entities who:
1. Currently own or lease a Settlement Class Vehicle that was distributed for sale or lease in the United
States, and registered and operated in the United States including the District of Columbia and Puerto
Rico; or
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01 13 21_CLASS ACTION SETTLEMENT: N54/N54T/N55 ELECTRIC ENGINE COOLANT PUMP
2. Formerly owned or leased a Settlement Class Vehicle that was distributed for sale or lease in the
United States and registered and operated in the United States including the District of Columbia and
Puerto Rico.
Service (Repair) Benefit - Component-Specific Limited Warranty Extension
A. As of the Effective Date of the Settlement (On or after May 5, 2022):
Except for as specified in B, eligible Settlement Class Members may have a qualifying electrical
engine coolant pump on a Class Vehicle replaced up to the first 7 years/84,000 miles,
whichever occurs first.
B. Up to one (1) year after the Effective Date of the Settlement (From May 5, 2021 to May 4, 2022):
If a Settlement Class Member’s Class Vehicle with an original electric engine coolant pump or a BMWapproved replacement electric engine coolant pump that was installed at a BMW Center, fails within one (1)
year from the Effective Date (regardless of the vehicle age or mileage) it will be replaced under this limited
warranty extension.
CAUSE
This Service Information Bulletin provides the information that supports the final Class Action Settlement’s
Service (Repair) Benefit for the Component Specific Limited Warranty Extension.
CORRECTION
For qualify electric water pump repairs, follow the instructions in the PROCEDURE section.
PROCEDURE
Note: This bulletin is notice of a limited warranty extension, there is no immediate repair required
unless the BMW vehicle is currently experiencing this problem.
If an applicable vehicle listed above arrives with an engine malfunction indicator (MIL/Check Engine) warning
light on and/or the engine is overheating, performing a Vehicle Test and/or diagnose the cause of the engine
overheat.
Based the fault codes stored, the results of the corresponding test modules and/or other diagnosis, replace the
engine’s electric water pump when required (including engine thermostat if also necessary).
Note: Standalone replacement of the engine thermostat is not included under this extended limited
warranty.
Inquiries
The Claims Administrator will address questions related to the Reimbursement Benefits only.
Settlement Updates will also be posted to the settlement website
(www.ElectricCoolantPumpSettlement.com) as new information becomes available.
PARTS INFORMATION
Note: This bulletin is notice of a limited warranty extension, there is no immediate repair required
unless the BMW vehicle is currently experiencing this problem.
The release of this bulletin should not require you to significantly increase your current inventory of the
corresponding replacement parts.
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01 13 21_CLASS ACTION SETTLEMENT: N54/N54T/N55 ELECTRIC ENGINE COOLANT PUMP
Only order these parts in the quantities needed to address those customers’ vehicles that have
confirmed failures.
Please refer to the Electronic Parts Catalog (ETK/EPC), using the customer’s VIN to locate the applicable
replacement part numbers.
Part Number
Refer to ETK
Refer to ETK
Refer to ETK
And, if necessary:
Refer to ETK
82 14 1 467 704
Description
Coolant pump, electric
ASA-Bolt
Hose clamp
Quantity
1
As applicable
As applicable
Thermostat
Antifreeze (1-gallon concentrate)
1
Sublet as needed
Only in conjunction with parts: When applicable, if ETK/EPC item identifies additional part(s)
that must also be replaced/installed in-conjunction with performing a covered repair, these required
additional items are also covered under the terms of this extended limited warranty.
Also refer to ETK/EPC and the repair instructions for onetime-use fasteners/screws and other
information regarding repair-related gaskets, seals, fluid and/or lubricants that also need to be
replaced/used and claimed.
WARRANTY INFORMATION
Class Member’s Class Vehicle’s electric engine coolant pumps (N54, N54T, N55) and thermostats (if damaged
due to a failure of the electric engine coolant pump) has the following component-specific limited warranty
extension:
B. Up to one (1) year after the Effective Date of the Settlement (Repair order/claim dates from May 5,
2021 to May 4, 2022)
Qualifying repairs are covered regardless of the vehicle’s time (age) or mileage
A. One (1) year after the Effective Date of the Settlement (Repair order/claim dates, on or after May 5,
2022)
Qualifying repairs are then covered up to the first 7 years/84,000 miles, whichever occurs first, as determined by the
original in-service date
This coverage above applies to eligible US-specification Class Members’ Class BMW Model vehicles that are
registered, operated, and have their covered repair performed by an authorized BMW center in the United
States (including Puerto Rico).
The existing limited warranty coverage for the whole vehicle and other components has not changed.
Qualifying Repairs – Claim Submission
Defect Code:
1151900200
Ex Fx N54 N54T N55 US Electric coolant pump
Applying the following guidelines, select and use the applicable flat rate labor operation(s) from the listing
below.
Plus work
Main
work
The vehicle is already in the workshop for another repair.
The vehicle arrives at your center for the issue and repair work covered under the terms
and conditions described in this bulletin (No other Main work will be performed/claimed
during this workshop visit).
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01 13 21_CLASS ACTION SETTLEMENT: N54/N54T/N55 ELECTRIC ENGINE COOLANT PUMP
Only one Main labor operation can be claimed per workshop repair visit (one or more claim submissions, if
applicable).
Labor Operation
11 51 000
Description
Removing/installing/replacing coolant pump (Main
work)
Labor Allowance
Refer to AIR
Or:
11 51 508
Removing/installing/replacing coolant pump (Plus
work)
Refer to AIR
Removing/installing/replacing coolant pump
(Associated work) (coolant already drain in conjunction
with performing another repair)
Refer to AIR
Or:
11 51 504
And, if also required:
Labor Operation
Inclusive Position
Description
Replacing coolant thermostat (Associated
work) (Included in 11 51 000,11 51 508,11 51 504)
Labor Allowance
N/A
And, as necessary:
With Diagnosis/Repair Work Procedures (with 11 51 508 or 11 51 504)
Labor Operation
00 00 006
Description
Performing vehicle test (with vehicle diagnosis system –
checking faults) (Main work)
Labor Allowance
Refer to AIR
Or:
00 00 556
Performing vehicle test (with vehicle diagnosis system –
checking faults) (Plus work)
Refer to AIR
Support voltage of the vehicle electrical system /
recharge vehicle electrical system battery
Refer to AIR
Performing vehicle diagnosis – test module
Work time (WT)
Troubleshooting in the electrical/electronic system
Work time (WT)
Diagnosis Worktime Flat Rate (See below)
2 FRU
And:
61 21 528
And, as applicable:
61 00 006*
And/or
61 00 009*
Or
00 58 000*
And in conjunction, if and as necessary:
Labor Operation
17 99 000
Description
Additional work related to coolant hoses, lines, and
pipes
Labor Allowance
Work time (WT)
And/or, if necessary
61 99 000
Additional work related to repairing wiring, pins and/or
connector to the water pump
Work time (WT)
Additional work related to repairing water pump
bolt/mechanical connections
Work time (WT)
And/or, if necessary
11 99 000
And/or:
With an External Leak (with 11 51 508 or 11 51 504)
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01 13 21_CLASS ACTION SETTLEMENT: N54/N54T/N55 ELECTRIC ENGINE COOLANT PUMP
Labor Operation
17 00 009
Description
Check the cooling system for watertightness with the
special tool (Main work)
Labor Allowance
Refer to AIR
Or:
17 00 509
Check the cooling system for watertightness with the
special tool (Plus work)
Refer to AIR
Refer to AIR for the corresponding flat rate unit (FRU) allowance.
Work time labor operation codes 61 00 006, 61 00 009, 00 58 000, 17 99 000, 61 99 000 and 11 99 000 are not
considered a Main labor operations.
*Based on which applies to your center, please refer to SI B01 01 20 or B01 07 20 for claiming your diagnosis
work time, job/repair work time, and for the RO/claim repair and work time explanation procedures.
796166
Bulk Materials
Sublet Code
4
See sublet
reimbursement
calculation below
Reimbursement for the repair-related bulk materials (Do not
use the BMW part numbers for claim submission)
Sublet reimbursement calculation for claiming the applicable repair-related bulk material (BMW part numbers) is
at the dealer net price amount for the quantities used plus your center’s handling.
BMW Antifreeze/Coolant: Claim the corresponding sublet dollar amount for the quantity needed to replace what
was drained with a 50/50 coolant/water solution.
Enter this material cost in sublet and itemize the amount on the repair order and in claim comment section
Consequential Repair(s) (RO and Claim Comments Required)
When additional work and/or parts are required as a direct result of addressing the issue and/or performing the
repair outlined in this Service Information bulletin, claim this additional work/items under the defect code listed
above together with the corresponding labor operations listed in the AIR.
Please explain the reason for this consequential repair work (the why and the what) on the repair order and in
the claim comments section.
Supporting Materials
picture_as_pdf B011320 WP Oliver v BMW_CF_Notice (11_2020).pdf
Copyright ©2021 BMW of North America, Inc.
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Oliver Claims Administrator
c/o Rust Consulting - 7078
PO Box 13
Minneapolis, MN 55440-0013
F O R O F F I C I A L U S E O N LY
01
I MP O R TA N T L EG AL M ATERIAL S
*clmnt_idno*
UAA <>
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Page 1 of 2
Claimant Identification Number:
<>
United States District Court for the District of New Jersey
If you are a current or former owner or lessee of a model-year 2007 to 2019 BMW
vehicles, you could get benefits from a class-action settlement.
A federal court has authorized this notice.
This is not a solicitation from a lawyer.
• A nationwide settlement has been reached in a class action lawsuit against BMW
of North America, LLC, captioned Oliver, et al v. Bayerische Motoren Werke
Aktiengesellschaft, et al., Civil Action No. 2:17-cv-12979, involving the electric
engine coolant pump in certain model-year 2007 to 2019 BMW vehicles.
• The Settlement provides an opportunity to be reimbursed for certain past
expenses.
• Your legal rights are affected whether you act or don’t act, so please read this
notice carefully.
Sample
*7078*
*CF*
*RUST*
This form must be submitted or postmarked on or within 30 days of the Effective Date, currently estimated to be no earlier than
March 20, 2021. Please see the settlement website to find out if the Effective Date has changed.
CLAIM FORM TO RECEIVE REIMBURSEMENT FOR ELIGIBLE PAST EXPENSES IN
OLIVER v. BMW OF NORTH AMERICA, LLC
Complete this form only if you wish to make a claim for reimbursement
for eligible past expenses available under the Settlement.
PLEASE TYPE OR PRINT LEGIBLY
You must supply all of the following information in order to obtain reimbursement
for eligible past expenses under this Settlement.
Name:
Address:
City:
State:
Zip:
Email address:
BMW Model Year: 20
Model:
(example: 335i)
Vehicle Identification Number:
(The VIN is 17 characters and can be found on the metal plate at the bottom of the driver’s side front windshield or on your
sale or title documents.)
Date of Purchase/Lease:
/
/
CLAIMANT DECLARATION
I declare under penalty of perjury that the information above and the documents I have supplied are true and correct.
Signed On:
/
(DD/MM/YYYY)
/
in
,
(City) 						
(State)
(Sign your name here)
(Type or print your name here)
(Capacity of person signing - if applicable)
YOU MAY BE ELIGIBLE FOR REIMBURSEMENT FOR UP TO $1,000.00 FOR COSTS (PARTS AND LABOR) OF REPLACEMENT
OF ONE FAILED ELECTRIC ENGINE COOLANT PUMP AND, IF ALSO DAMAGED , ONE FAILED ELECTRIC ENGINE COOLANT
THERMOSTAT.
PLEASE COMPLETE THIS CLAIM FORM ONLY IF YOU ARE SEEKING REIMBURSEMENT BENEFITS.
PLEASE SEE QUESTIONS 6 THROUGH 8 ON THE NOTICE FORM FOR MORE INFORMATION AND LIMITATIONS.
Page 2 of 2
CLAIMS FOR REIMBURSEMENT FOR PAST EXPENSES
To obtain reimbursement for up to $1,000.00 in total for the replacement cost of one (1) failed electric engine coolant pump and,
if also damaged, one (1) failed engine coolant thermostat you must submit documents showing:
a.
That the replacement was made at an authorized BMW dealer (e.g., a BMW Center), or at a third-party repair shop; and
b. Your Settlement Class Vehicle’s model, model year, and VIN; and
c.
The identity of the owner/lessee of the Settlement Class Vehicle; and
d. That your Settlement Class Vehicle had fewer than 7 years and 84,000 miles at the time of the replacement of the
electric engine coolant pump, as evidenced by required proofs, such as a repair order with vehicle mileage at the time of
replacement or service records from before and after the replacement; and
e.
The cost of repair, with parts and labor separated; and
f.
Proof of payment for the amount(s) sought for reimbursement (credit card receipt, credit card statement, or cancelled
check); and
g.
The nature of the repair; and
h. The part(s) description and part number(s) used in the repair; and
i.
The date of repair.
COMPLETED CLAIMS FORMS CAN BE SUBMITTED BY MAIL OR ONLINE.
IF YOU ARE SUBMITTING BY MAIL, COMPLETE THIS CLAIM FORM AND MAIL IT, POSTMARKED ON OR BEFORE the later of 30
days after the date of Final Approval of the Settlement or the Effective Date of the Settlement, to be posted on the Settlement
Website but estimated to be March 20, 2021 TO:
Oliver Claims Administrator
c/o Rust Consulting - 7078
PO Box 13
Minneapolis, MN 55440-0013
IF YOU ARE SUBMITTING ONLINE, COMPLETE AND SUBMIT THE CLAIM FORM AVAILABLE AT www.ElectricCoolantPumpSettlement.com
ON OR BEFORE the later of 30 days after the date of Final Approval of the Settlement or the Effective Date of the Settlement, to be
posted on the Settlement Website but estimated to be March 20, 2021.
QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT www.ElectricCoolantPumpSettlement.com
United States District Court for the District of New Jersey
If you are a current or former owner or lessee of a model-year 2007 to 2019 BMW vehicles,
you could get benefits from a class-action settlement.
•
•
•
•
•
A federal court has authorized this notice. This is not a solicitation from a lawyer.
A nationwide settlement has been reached in a class action lawsuit against BMW of North America, LLC, captioned
Oliver, et al v. Bayerische Motoren Werke Aktiengesellschaft, et al., Civil Action No. 2:17-cv-12979, involving the electric
engine coolant pump in certain model-year 2007 to 2019 BMW vehicles.  
The Settlement provides an opportunity to be reimbursed for certain past expenses.
Your legal rights are affected whether you act or don’t act, so please read this notice carefully.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:
SUBMIT A CLAIM FORM Make a claim to receive reimbursement for Claims must be submitted by the later
eligible past expenses potentially available to of thirty (30) days after the date of
you under the Settlement.
Final Approval of the Settlement or
the Effective Date of the Settlement,
to be posted on the Settlement Website
but estimated to be on or about March
20, 2021.  See Question 8, below.
EXCLUDE YOURSELF
Write to Settlement Class Counsel and Requests for Exclusion must be
Defendant’s Counsel to exclude yourself from postmarked by January 8, 2021.   See
(“opt out” of ) the Settlement. This is the only Question 12, below.
option that allows you to be part of any other
lawsuit, or your own lawsuit, against BMW of
North America about the legal claims released
in this Settlement.
OBJECT
Write to the judge about why you do not like Objections must be postmarked by
the Settlement.
January 8, 2021.  See Question 17, below.
GO TO A HEARING
Ask to speak in court to the judge about the The Final Approval Hearing is
Settlement.
currently scheduled for February 18,
2021 at 10:00 a.m.  See Questions 19 to
21, below.
DO NOTHING
Give up the benefits to which you may be See Question 22, below.
entitled under the Settlement and your right to
be part of any other lawsuit against BMW of
North America about the legal claims released
by the Settlement (but not your right to future
repairs under the extended warranty explained
below).  
These rights and options -- and the deadlines to exercise them -- are explained in this notice.
The Court in charge of this case still must decide whether to approve the Settlement before any benefits can be
distributed.  Please be patient and check the settlement website for updates.
QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-1-
WHAT THIS NOTICE CONTAINS
BASIC INFORMATION
1. Why have I received this notice?
2. What is the lawsuit about?
3. Why is this a class action?
4. Why is there a Settlement?
PAGE 2-3
WHO IS IN THE SETTLEMENT
PAGE 3
THE BENEFITS: WHAT YOU GET
PAGE 4-5
HOW TO GET BENEFITS
PAGE 5
EXCLUDING YOURSELF FROM THE SETTLEMENT
PAGE 5-6
THE LAWYERS REPRESENTING YOU
PAGE 6
OBJECTING TO THE SETTLEMENT
PAGE 6-7
THE COURT’S FINAL APPROVAL HEARING
PAGE 7
WHAT IF I DO NOTHING?
PAGE 7
GETTING MORE INFORMATION
PAGE 7
5. How do I know if I am part of the Settlement? What vehicles are included in the Settlement?
6. What are the benefits of the Settlement?
7. What am I giving up in exchange for the Settlement benefits?
8. How do I get the benefits of the Settlement?
9. What if my claim for benefits is denied?
10. When will I get the benefits?
11. Can I exclude myself from this Settlement?
12. If I exclude myself, can I get anything from this Settlement?
13. If I don’t exclude myself, can I sue later?
14. How do I exclude myself from the Settlement?
15. Do I have a lawyer in the case?
16. How will the lawyers be paid?
17. How do I tell the Court if I don’t like the Settlement?
18. What’s the difference between objecting and excluding?
19. When and where will the Court decide whether to approve the Settlement?
20. Do I need to go to the hearing?
21. May I speak at the hearing?
22. What happens if I do nothing?
23. Can I get more details about the Settlement?
1. Why have I received this notice?
A Court has authorized this notice because you have a right to know about the proposed settlement of this class-action
lawsuit, and your options, before the Court decides whether to give “final approval” to the Settlement.  This notice explains
the lawsuit, the proposed Settlement, and your legal rights.  You have received this notice because BMW of North America’s
records indicate that you are a current or former owner or lessee of one or more of the following vehicles purchased or leased
in the United States, including the District of Columbia and Puerto Rico (“Class Vehicles”):
QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-2-
Model Years
2008-2013
2007-2013
2008-2016
2012-2017
2010-2015
2012-2015
2011-2017
2015-2018
2007-2013
2008-2019
2009-2016
Models
135i
335i, 335i xDrive, 335is Convertible
535i, 535i xDrive, 535i Active Hybrid
640i, 640i xDrive
740i, 740Li
X1 3.0si
X3 xDrive
X4 xDrive, X4 M40i
X5 3.0si, X5 xDrive30i , X5 xDrive
X6 sDrive, X6 xDrive
Z4 sDrive
Magistrate Judge Mark Falk of the United States District Court for the District of New Jersey is overseeing this class-action
lawsuit, captioned Oliver v. Bayerische Motoren Werke Aktiengesellschaft and BMW of North America, LLC, Civil Action No.
2:17-cv-12979 (the “Action”).  Shelton Oliver, Donnie Baker, and Khader Mohiuddin, the people who sued, are called the
“Plaintiffs,” and the company that was sued, BMW of North America, LLC, is called the “Defendant.”
2. What is the lawsuit about?
This lawsuit alleges that the Class Vehicles’ electric engine coolant pump is defective, which could lead to sudden engine
failure and loss of power to the vehicles.  BMW of North America, which distributes and warrants BMW vehicles in the
U.S., denies these allegations and stands behind and supports its products.
3. Why is this a class action?
In a class action, one or more people called “Class Representatives” assert claims on behalf of people who have similar claims.  
All of these people are the “Class” or “Class Members.”  One court resolves the issues for all Class Members, except for those
who timely exclude themselves from (“opt out” of ) the Class.  The Class Representatives in the Action are the Plaintiffs
identified above.  You have received this notice because you have been identified as potentially being a Class Member.
4. Why is there a Settlement?
All parties have agreed to a Settlement to avoid further cost and risk of a trial, and so that the people affected can begin
getting benefits in exchange for releasing the Defendant from liability for the claims that were raised or could have been
raised in the Action involving the Class Vehicles’ alleged issues with the electric engine coolant pump.  The Settlement
does not mean that BMW of North America broke any laws, or otherwise did anything wrong, because Judge Falk did not
decide which side was right.  The Class Representatives and the lawyers representing them think the Settlement is fair and
reasonable for the Class.
5. How do I know if I am part of the Settlement? What vehicles are included in the Settlement?
The Settlement Class includes all persons or entities in the United States, including the District of Columbia and Puerto
Rico, who currently own or lease, or previously owned or leased, certain U.S.-specification model-year 2007-2019 BMW
vehicles purchased or leased, and registered and operated, in the United States, including the District of Columbia and
Puerto Rico, which include the following vehicles:
QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
-3-
Model Years
2008-2013
2007-2013
2008-2016
2012-2017
2010-2015
2012-2015
2011-2017
2015-2018
2007-2013
2008-2019
2009-2016
Models
135i
335i, 335i xDrive, 335is Convertible
535i, 535i xDrive, 535i Active Hybrid
640i, 640i xDrive
740i, 740Li
X1 3.0si
X3 xDrive
X4 xDrive, X4 M40i
X5 3.0si, X5 xDrive30i , X5 xDrive
X6 sDrive, X6 xDrive
Z4 sDrive
Please note that not all vehicles in the model years identified above contained the electric engine coolant pump at issue in the Action.
You have received this notice because BMW of North America’s records indicate that you have or had a BMW vehicle with the electric
engine coolant pump at issue in the Action.
6. What are the benefits of the Settlement?
If Judge Falk grants final approval of the Settlement and the Settlement becomes effective (the “Effective Date”), you may
be eligible for reimbursement of up to $1,000 in total in costs for replacement of one (1) failed electric engine coolant pump
and, if also damaged, one (1) engine coolant thermostat, per VIN, per owner/lessee if the replacement occurred prior to the
earlier of the first 7 years or 84,000 miles of the Class Vehicle’s in-service date.  If you are unsure of your Vehicle’s in-service date,
please check with your local BMW Center, which can look up the date based on your Vehicle Identification Number (VIN).
Additionally, the limited warranty period for the electric engine coolant pump in all Class Vehicles will be extended from the
4-year/50,000-mile New Passenger Vehicle Limited Warranty period to 7 years/84,000 miles, whichever comes first.  If your
original electric engine coolant pump or a BMW-approved replacement electric engine coolant pump installed at a BMW
Center fails during this extended-warranty period, it will be replaced under this limited warranty extension, subject to the
terms and conditions of BMW of North America’s New Passenger Vehicle Limited Warranty.  
Finally, if your original electric engine coolant pump, or a BMW-approved replacement electric engine coolant pump
installed at a BMW Center, fails within one (1) year from the Effective Date (regardless of vehicle age or mileage), it will
be replaced in accordance with the Settlement, subject to the terms and conditions of BMW of North America’s New
Passenger Vehicle Limited Warranty.
*          *          *
Limitations:   BMW of North America does not warrant or guarantee any repairs performed at third-party (non-BMW
Center) repair shops and, should any such repairs fail after a Settlement Class Member has made a reimbursement claim
under the Settlement, the Settlement Class Member will not be entitled to submit an additional claim or seek replacement
under the extended warranty.  BMW of North America does not warrant replacement parts that were not certified by the
original equipment manufacturer.  The limited warranty extension will not apply to vehicles whose owners or lessees opt out of
the Settlement, vehicles declared a total loss, sold for salvage purposes, or branded with a “salvage” title.  There are additional
limitations and exclusions from coverage set forth in BMW of North America’s New Passenger Vehicle Limited Warranty and
in Section III of the Settlement Agreement, which can be viewed at www.ElectricCoolantPumpSettlement.com.
In order to obtain reimbursement for eligible past out-of-pocket expenses, you must submit a Claim Form and include all
of the documentation described above and identified on the Claim Form.
7. What am I giving up in exchange for the Settlement benefits?
If the Settlement becomes final, Class Members will be releasing Defendant and related people and entities from all
of the claims described and identified in Section VII.A of the Settlement Agreement.   In essence, Class Members are
releasing all claims (except for personal injury or damage to property other than the Class Vehicle) that could arise based
on alleged defect in the electric engine coolant pump in the Class Vehicles.  The Settlement Agreement is available at www.
ElectricCoolantPumpSettlement.com.  The Settlement Agreement describes the released claims with specific descriptions,
in necessarily precise legal terminology, so read it carefully.
QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
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Judge Falk has approved specific lawyers to represent you in this lawsuit and Settlement.  You can talk to one of the lawyers
listed in Question 15 below, free of charge, if you have questions about the released claims or what they mean.  You can also
speak with your own lawyer, should you have one, about this Settlement.
8. How do I get the benefits of the Settlement?
If you are a Class Member and would like to obtain the reimbursement benefits (described in Question 6 above), you need to
complete the Claim Form that accompanies this Notice and mail it, with all the required proofs, to the address provided on
the Claim Form or file the Claim Form online through the Settlement website portal.  Additional Claim Forms are available
at www.ElectricCoolantPumpSettlement.com.  The current deadline for submitting your Claim Form is March 20, 2021.
These benefits are also subject to limitations, which are discussed in Question 6 and in the Settlement Agreement.
If you have any questions on how to complete the Claim Form or what information is needed, you can call the toll-free
number at the bottom of this notice.
9. What if my claim for benefits is denied?
There is a process in the Settlement Agreement to resolve disagreements between you and Defendant over your claim.  During
this process, the court-appointed lawyers listed in Question 15 below will represent you in any dispute regarding relief under
the terms of the Settlement, and the dispute will be handled in accordance with the procedures set forth in Section III.B. of
the Settlement Agreement.  If you have questions regarding this process, visit www.ElectricCoolantPumpSettlement.com
to see a copy of the Settlement Agreement, or contact Class Counsel below.
10. When will I get the Settlement benefits?
If you have submitted a claim, your Claim Form will be processed and payments will be issued on a continuing, rolling basis
after the Effective Date, which will be after the Court’s Final Approval hearing, scheduled for February 18, 2021, and all
appeals, if any, are resolved.
Please be patient, and feel free to check the website for current status.
11. Can I exclude myself from this Settlement?
Yes.  If you want to keep the right to sue or if you are already suing Defendant in another action over the legal issues in this
case, then you must take steps to do so.  This is called asking to be excluded from – sometimes called “opting out” of – the
Settlement.
12. If I exclude myself, can I get anything from this Settlement?
No.  If you ask to be excluded, you will not receive any of the reimbursement benefits of the Settlement or the warranty
extension and you cannot object to the Settlement.  But you may sue, continue to sue, or be part of a different lawsuit against
Defendant in the future, including for claims that this Settlement resolves.  You will not be bound by anything that happens
in this lawsuit.
13. If I don’t exclude myself, can I sue later?
No.  Unless you exclude yourself, you give up the right to sue Defendant for the claims that this Settlement resolves.
14. How do I exclude myself from the Settlement?
To exclude yourself from the Settlement, you must send a letter by mail to the Claims Administrator saying that you want to
be excluded from Oliver v. Bayerische Motoren Werke Aktiengesellschaft, Civil Action No. 2:17-cv-12979.  Be sure to include:
(1) your full name and current address; (2) the model-year, model, and VIN of your Class Vehicle(s) and the date(s) of
purchase/lease; (3) specifically and clearly state your desire to be excluded from the Settlement and from the Settlement
Class; and (4) your signature.  You cannot ask to be excluded over the phone or via the internet.  You must mail your request
to be excluded, postmarked no later than January 8, 2021, to Claims Administrator at the address listed in Question 17.
Failure to comply with any of these requirements for excluding yourself will result in you being bound by this Settlement.
QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
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15. Do I have a lawyer in the case?
The Plaintiffs and you have been represented by the law firm Kantrowitz Goldhamer & Graifman, P.C. and Thomas P.
Sobran, Esq.  Judge Falk has approved as “Class Counsel” the following lawyers to represent you and other Class Members:
Gary S. Graifman, Esq.
KANTROWITZ, GOLDHAMER & GRAIFMAN, P.C.
210 Summit Avenue
Montvale, New Jersey 07645
Thomas P. Sobran, Esq.
7 Evergreen Lane
Hingham, MA 02043
You will not be charged for these lawyers.  If you want to be represented by another lawyer, you may hire one to appear in
Court for you at your own expense.
16. How will the lawyers be paid?
As part of the resolution of the Action, Class Counsel and Defendant have agreed that Class Counsel may apply for an
award of attorneys’ fees, costs, expenses, and service payments for the three Class Representatives not to exceed a total of
$900,000.00.  Defendant has agreed not to oppose this request.  The Parties have agreed that Class Counsel will not seek
payment of any amount in excess of $900,000.00 in the aggregate.  The Parties have also agreed that Class Counsel may
ask Judge Falk to award service payments to the three Class Representatives in the amount of $1,000 each ($3,000 in
total), which will be included in the $900,000 payment.  The Class Counsel fees, expenses, and Class Representative service
payments, will be paid separate and apart from any relief provided to the Class and will not reduce the value of the benefits
distributed to Class Members.  Defendant will also separately pay the costs to administer the Settlement.  Judge Falk will
determine the amount of attorneys’ fees, costs, expenses, and service payments after evaluating Plaintiffs’ submission.
17. How do I tell the Court if I don’t like the Settlement?
If you don’t like some part of the Settlement, you can object to it.  You can give reasons why you think Judge Falk should not
approve it.  To object, you must send a letter to the Clerk of the Court saying that you object to the Settlement in Oliver v.
Bayerische Motoren Werke Aktiengesellschaft, Civil Action No. 2:17-cv-12979.  You must include: (1) your full name, current
address, current telephone number, and the name of your lawyer and your lawyer’s address if you are represented by a lawyer
other than Class Counsel; (2) the model year, model, and VIN of your Class Vehicle(s) and the date(s) of purchase or lease;
(3) whether the objection applies only to you, to a specific subset of the Class, or to the entire Class; (4) the reasons why you
object and the factual and legal reasons for your objection (including all relevant documents that pertain to your objection);
(5) copies of relevant repair history or other proof that you have owned or leased the Class Vehicle (i.e., a true copy of a
vehicle title, registration, or license receipt); (6) a statement that you have reviewed the Settlement Class definition and
understand that you are a Settlement Class Member, and you have not opted out of the Settlement Class; (7) a detailed list
of any other objections to any class action settlements you have submitted in the previous five (5) years to any court, whether
state, federal, or otherwise, in the United States; (8) a Notice of Intention to Appear at the Final Approval Hearing, if you
intend to appear in person at the hearing; and (9) your signature.  The objection must be mailed to the Court, the Claims
Administrator, Class Counsel, and Defendant’s Counsel at the addresses below.  The mailed copies must be postmarked
on or before January 8, 2021:
COURT
CLAIMS
ADMINISTRATOR
Clerk of Court
United States District Court for the District of New Jersey
Rev. Dr. Martin Luther King, Jr. Federal Building & U.S. Courthouse
50 Walnut Street
Newark, New Jersey 07102
Oliver Claims Administrator
c/o Rust Consulting - 7078
PO Box 13
Minneapolis, MN 55440-0013
QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
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CLASS COUNSEL
Gary S. Graifman, Esq.
KANTROWITZ, GOLDHAMER & GRAIFMAN, P.C.
210 Summit Avenue
Montvale, New Jersey 07645
DEFENDANT’S COUNSEL
Thomas P. Sobran, Esq.
7 Evergreen Lane
Hingham, MA 02043
Christopher J. Dalton, Esq.
Argia J. DiMarco, Esq.
Buchanan Ingersoll & Rooney PC
550 Broad Street, Suite 810
Newark, New Jersey 07102-4582
18. What’s the difference between objecting and excluding?
Objecting is simply telling Judge Falk that you don’t like something about the Settlement.  You can object only if you stay
in the Settlement.  Excluding yourself is telling Judge Falk that you don’t want to be part of the Settlement.  If you exclude
yourself, you have no basis to object because the Settlement no longer affects you.
19. When and where will Judge Falk decide whether to approve the Settlement?
Judge Falk will hold a “Final Approval Hearing” to decide whether to approve the Settlement on February 18, 2021 at 10:00
a.m., at the United States District Court for the District of New Jersey, Rev. Dr. Martin Luther King, Jr. Federal Building
& U.S. Courthouse, 50 Walnut Street, Newark, New Jersey 07102.  At this hearing, Judge Falk will determine whether the
Settlement is fair, adequate, and reasonable and whether the objections by Class Members, if any, have merit.  If you have
filed an objection on time, you may attend and ask to speak, but you don’t have to.  However, Judge Falk will only listen to
people who have asked to speak at the hearing (see Question 21 below).  At this hearing, Judge Falk will also decide the
service payments for the Class Representatives, as well as the attorney’s fees for the lawyers representing the Class Members.  
We do not know how long the Court’s decision will take, and the hearing date may change due to other court business.  You
should monitor www.ElectricCoolantPumpSettlement.com to find out if any dates have changed and to learn if Judge Falk
has approved the Settlement.
20. Do I need to go to the hearing?
No.  Class Counsel will answer any questions Judge Falk may have, but you are welcome to come at your own expense.  If
you send an objection, you don’t have to come to Court to talk about it.  As long as you mail your valid written objection on
time, Judge Falk will consider it.  You may also pay another lawyer to attend, but it’s not required.
21. May I speak at the hearing?
You may ask Judge Falk for permission to speak at the Final Approval Hearing.  To do so, you must file a “Notice of Intent
to Appear” in Oliver v. Bayerische Motoren Werke Aktiengesellschaft, Civil Action No. 2:17-cv-12979. Be sure to include your
name, address, telephone number, signature, and other requirements outlined in Question 17.  Your Notice of Intent to
Appear must be postmarked no later than January 8, 2021, and mailed to the addresses listed in Question 17.  You cannot
speak at the hearing if you have excluded yourself from the Settlement.
22. What if I do nothing?
If you do nothing, you will give up the right to be part of any other lawsuit against Defendant about the legal claims released
by the Settlement.  You will not receive any of the reimbursement benefits described in Question 6 offered by this Settlement
unless you timely submit a Claim Form.  Your vehicle will, however, still get the benefit of the extended warranty, if applicable.
23. Can I get more details about the Settlement?
This notice summarizes the proposed Settlement.   More details are in the Settlement Agreement.   You can review the
Settlement Agreement and related documents at www.ElectricCoolantPumpSettlement.com.  
QUESTIONS? CALL TOLL-FREE (866) 459-3651 OR VISIT
www.ElectricCoolantPumpSettlement.com
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