Sharon Cheng, et al. v. Toyota Motor Corporation, et al. Frequently Asked Questions

A Court authorized the Notice because you have a right to know about a finally-approved Settlement of a class action lawsuit and about all of your options. The name of the lawsuit is Cheng, et al., v. Toyota Motor Corp., et al., Case No. 1:20-cv-00629-WFK-JRC (E.D.N.Y.). The defendants are Toyota Motor Corporation, Toyota Motor North America, Inc. (collectively, “Toyota”), and Denso International America, Inc. (“Denso”) (collectively, “Defendants”). The Notice explains the lawsuit, the Settlement, and your legal rights. You are NOT being sued. Please do not contact the Court. All questions should be directed to the Settlement Notice Administrator, identified below.

The class action lawsuit claims that the fuel tanks in certain Toyota and Lexus vehicles are equipped with defective Denso-manufactured fuel pumps. The lawsuit pursues claims for violations of various state consumer protection statutes, among other claims. You can read the class action complaint here. Toyota and Denso deny that they have violated any law and deny that they engaged in any wrongdoing. The parties agreed to resolve these matters before these issues were decided by the Court.

This Settlement does not involve claims of personal injury, wrongful death, or actual physical property damage arising from the Covered Vehicles.

Various Toyota and Lexus vehicles which were equipped with certain Denso fuel pumps (called the “Covered Vehicles”) distributed for sale or lease in the United States, the District of Columbia, Puerto Rico and all other United States territories and/or possessions are included in the Settlement.

“Additional Vehicles” means those vehicles that are equipped with Denso low-pressure fuel pumps with part number prefixes 23220- and/or 23221- that are identified in the Long Form Notice and/or in this exhibit.

 “Subject Vehicles” means those vehicles that were identified as part of the Recall, all of which are equipped with Denso low-pressure fuel pumps with part number prefixes 23220- and/or 23221-, and/or are recalled vehicles that are listed in Long Form Notice and/or in this exhibit.

 “SSC Vehicles” means the vehicles identified as part of the Special Service Campaigns 21LC01 and 21TC03, all of which are equipped with Denso low-pressure fuel pumps with part number prefix 04009, and are listed in Long Form Notice and/or in this exhibit. 

In a class action, people called “class representatives” sue on behalf of other people who have similar claims. All of these people together are the “Class” or “Class Members” if the Court approves this procedure. Once approved, the Court resolves the issues for all Class Members, except for those who exclude themselves from the Class.

Both sides in the lawsuit agreed to a Settlement to avoid the cost and risk of further litigation, including a potential trial, and so that the Class Members can get benefits, in exchange for releasing Toyota and Denso from liability. The Settlement does not mean that Toyota and Denso broke any laws or did anything wrong, and the Court did not decide which side was right. This Settlement has been finally approved by the Court, which authorized the issuance of this Website. The Class Representatives and the lawyers representing them called Plaintiffs’ Counsel, including Class Counsel, believe that the Settlement is in the best interests of all Class Members.

You are part of the Settlement if you are a person, entity or organization who, at any time as of September 19, 2022, own or owned, purchase(d) or lease(d) Covered Vehicles distributed for sale or lease in any of the fifty States, the District of Columbia, Puerto Rico and all other United States territories and/or possessions. This is called the “Class.”

Excluded from the Class are: (a) Toyota, its officers, directors and employees; its affiliates and affiliates’ officers, directors and employees; its distributors and distributors’ officers, directors and employees; and Toyota Dealers and Toyota Dealers’ officers and directors; (b) Denso, its officers, directors and employees; its affiliates and affiliates’ officers, directors and employees; its distributors and distributors’ officers, directors and employees; (c) Plaintiffs’ Counsel; and (d) judicial officers and their immediate family members and associated court staff assigned to this case.

If you are not sure whether you are included in the Class, you may call 1-833-512-2318 or go to the Am I a Class Member Section of this website, which contains a VIN lookup tool to determine if your vehicle is part of the Class.

If you believe that you are a Class Member, but you did not previously receive a Direct Mail Notice, you may contact Class Counsel or the Settlement Notice Administrator. You will need to provide necessary documentation for the Settlement Notice Administrator to confirm that you are Class Member eligible for the relief provided in the Settlement Agreement.

Please do not contact the Court. All questions should be directed to the Settlement Notice Administrator at 1-833-512-2318 or through the Contact Us section of this website.

If you are a Class Member, what you are eligible to receive depends on several factors. The Settlement benefits are outlined generally below, and more information can be found on this Settlement website. Please check this website regularly for updates regarding the Settlement.

The Settlement offers several benefits, depending on the vehicle, including a Customer Support Program which will provide prospective coverage of 15 years, measured from the date of original sale, for any repairs to correct defects in the fuel pumps (see Question 9 below), or an Extended New Parts Warranty of 15 years, measured from July 15, 2021, or 150,000 total odometer miles, whichever comes first (see Question 10 below). The Settlement also offers a complimentary Loaner/Towing Program for vehicles undergoing repairs; a reconsideration procedure; and settlement oversight by a Settlement Special Master.  Some of these benefits require action by Class Members by certain deadlines.

Please note that you may have to take action within certain deadlines to receive certain benefits, such as seeking repairs under the Customer Support Program or the Extended New Parts Warranty. If you do nothing, you may not receive certain benefits from the Settlement, and, as a Class Member, you will not be able to sue Toyota and Denso about the issues in the lawsuit.

To determine whether your vehicle is an Additional Vehicle, a Subject Vehicle, or an SSC vehicle, including the specific definitions for each of those terms, please see Appendix A, B, and C, respectively, at the end of the Long Form Notice or by clicking on these exhibits (Additional Vehicles, Subject Vehicles, and SSC Vehicles) or by going to the Am I a Class Member Section of this website.  

Toyota is extending the new parts warranty coverage for the fuel pump kit replaced (“replacement fuel pump kit”) on the Subject Vehicles and the SSC Vehicles.  The extended warranty will last for 15 years, measured from July 15, 2021, and up to 150,000 total odometer miles, whichever comes first. 

Subject Vehicles and SSC Vehicles: Loaner/Towing Program - Without cost to and upon request from Class Members who own or lease SSC Vehicles or Subject Vehicles whose fuel pumps are being replaced pursuant to the Extended Warranty shall be provided with the same loaner or rental vehicles and/or towing options provided to the Subject Vehicles under the Recall(s).  In appropriate circumstances, where the Class Member has a demonstrated need for a Loaner Vehicle similar to the Subject Vehicle or the SSC Vehicle, Toyota, through its dealers, shall use good faith efforts to satisfy the request.  

In the event that any of the SSC Vehicles becomes the subject of a future recall for the same underlying condition, which is the subject of the Plaintiff’s Class Action Complaint, those SSC Vehicles will be entitled to the relief provided under the settlement as defined above in this subparagraph as well as any additional benefits provided pursuant to a future recall. 

If a Class Member is denied coverage under the Customer Support Program for Additional Vehicles, or the Extended New Parts Warranty for Subject Vehicles and the SSC Vehicles, the Class Member may take the Covered Vehicle to a second Toyota Dealer for an independent determination. If the second Toyota Dealer determines that the Covered Vehicle qualifies the Customer Support Program for Additional Vehicles, or the Extended New Parts Warranty for Subject Vehicles and the SSC Vehicles, the Class Member will be provided those benefits as provided in this Settlement.

In the event there remains a dispute by a Class Member relating to entitlement to any benefit under the Customer Support Program, the Extended New Parts Warranty, and/or the Loaner/Towing Program that is not resolved after exhausting all other means of resolution available under this Settlement,  the Settlement Claims Administrator or the Settlement Notice Administrator, as the case may be, shall provide a written notice of same, together with all necessary documentation, to the Settlement Special Master, Class Counsel, Toyota’s Counsel and Denso’s Counsel within fifteen days of the final act constituting the denial of the benefit. Class Counsel, Toyota’s Counsel, and Denso’s Counsel shall confer and either make a joint recommendation to the Settlement Claims Administrator or separately relay their positions concerning the dispute to the Settlement Claims Administrator within thirty days. The Settlement Claims Administrator shall make a final determination concerning the dispute and provide written notice of same, with directions for implementation, to the Parties, or Settlement Notice Administrator within thirty days. Toyota’s Counsel, Denso’s Counsel, and/or the Settlement Notice Administrator shall implement the Settlement Claims Administrator’s determination within thirty days; provided, however, that if the determination was to allow, in full or in part, a previously denied Claim, the Settlement Notice Administrator shall pay the Claim in the next distribution of checks for allowed Claims.

Class Members who did not exclude themselves from the Class have released Toyota and Denso from liability and will not be able to sue Toyota and Denso about the issues in the lawsuit, but will not be releasing any claims for personal injury, wrongful death or physical property damage (except to the Fuel Pump in the Covered Vehicle itself) from the Covered Vehicle. The Settlement Agreement at Section VII describes the released claims in necessary legal terminology, so read it carefully. For ease of reference, we also attach the full release section in Appendix A to the Long Form Notice. The Settlement Agreement is available here. You can talk to one of the lawyers listed in Question 18 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.

Yes. The Court has appointed lawyers to represent you and other Class Members. These lawyers are called “Class Counsel”: W. Daniel “Dee” Miles III and Demet Basar of Beasley, Allen, Crow, Methvin, Portis & Miles, P.C. are Class Counsel. Their contact information is as follows:

If you want to be represented by another lawyer, you may hire one to appear in Court for you at your own expense.

The Long Form 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 documents section of this website. You can also call the toll-free number, 1-833-512-2318 or write the Settlement Administrator at:

New York, NY 10150-5324

The Settlement is now final and is in the process of being implemented. Please do not contact the Court. All questions should be directed to the Settlement Notice Administrator.