Repair-It

The Plaintiffs allege that the HVAC systems in certain Mercedes-Benz vehicles are defectively designed such that they
accumulate mold or mildew and emit related odors.

The Court did not decide in favor of Plaintiffs or Defendants. Instead, both sides agreed to a Settlement they believe is
adequate, after considering the risks and costs of continued litigation. The Plaintiffs and Class Counsel believe the
proposed Settlement confers substantial benefits on the Class and represents a fair, reasonable, and adequate resolution
of the lawsuit.
Defendants deny the claims in the lawsuit; deny all allegations of wrongdoing, fault, liability, or damage to the Plaintiffs
and the Class; and deny that the HVAC systems in the covered vehicles are defective; and deny that they acted
improperly or wrongfully in any way. Defendants nevertheless recognize the expense and time that would be required to
defend the lawsuit through trial and have taken this into account in agreeing to this Settlement.

A past repair is a repair that occurs before December 7, 2020 relates to a customer complaint of moldy, mildew-y, or
similar odor emanating from the vehicle’s HVAC system, including cleaning the evaporator (flushing, Wynn, Contra-Sept, and any other cleaning methods or services) and replacing the filter. Evaporator replacement is included as a past repair only if the replacement was done at an Authorized Service Center.

A future repair is any repair to clean the vehicle’s evaporator and/or replace the filter that is performed at an Authorized
Service Center on or after December 7, 2020. You do not need to bring your vehicle in for a future repair until and
unless you experience moldy, mildew-y odors emanating from the HVAC System. Only current owners and lessees are
eligible for future repairs. For more details on how to receive a future repair, see question 13

You do not need to take any action now to qualify for coverage for future repairs.

If and when a moldy, mildew-y HVAC odor arises, you simply bring your vehicle to an Authorized Service Center to
receive a future repair. All covered vehicles are eligible for unlimited future repairs until 10 years after their in-service
date or 125,000 miles, whichever comes first.

To determine coverage, a technician will perform an odor diagnostic test and verify that the source of the odor in the
vehicle is mold or mildew odors originating from the HVAC system. To qualify for coverage, you must present the
following items of proof to the Authorized Service Center at the time that coverage is requested:

(a) Proof that the vehicle’s currently installed filter is a Mercedes-Benz brand or other approved filter. Such proof
includes, but is not limited to, an Authorized Service Center employee examining the filter and determining
whether it is an approved filter, a service center invoice indicating installation of an approved filter in the
vehicle, or a receipt of purchase of an approved filter that was self-installed.

(b) Proof that the vehicle timely received proper service in reasonable compliance with the vehicle’s maintenance
schedule for the two service intervals immediately prior to the requested repair. Such proof includes, but is not
limited to, documentation from an Authorized Service Center or Independent Service Provider indicating the
vehicle’s maintenance history, information found in the Authorized Service Center’s own service records for the
vehicle, or receipts of parts and materials used for maintenance that you performed on the vehicle.