[PROPOSED] ORDER APPROVING PROTOCOL FOR DISSEMINATING NOTIFICATION TO THE CERTIFIED CLASSES, AND APPOINTING JND LEGAL ADMINISTRATION AS THE NOTICE ADMINISTRATOR

EDWARD M. CHEN, District Judge.

Plaintiffs, after having conferred with counsel for Defendant Ford Motor Company ("Defendant") and with the proposed notice administrator, JND Legal Administration ("JND"), hereby submit the following notice protocol for approval by the Court:

1. Plaintiffs will obtain, from two databases previously provided by Ford in discovery, a total of 1,342,092 VIN numbers for class vehicles purchased or leased in the United States (the "VIN List"). The Plaintiffs, through the notice administrator, will run the VIN List through the Departments of Motor Vehicles ("DMV") in each of the eight class states to identify all original and subsequent lessees/purchasers in those states.

2. Plaintiffs will give the VIN List to the notice administrator, who will work with the relevant DMVs to cross check those 1,342,092 VINs for all original and subsequent vehicle transactions made in each of the eight class states before August 9, 2013. This Court entered an order on September 14, 2017 authorizing the notice administrator to receive this information back from the DMVs for the purpose of effectuating notice. See Dkt. 332.

3. Before mailing the postcard notice, the notice administrator will first update the addresses it receives from the DMVs by running them through a national change of address database. It will then mail the Court-approved postcard notice to all of these addresses.

4. The notice administrator will also provide the information it receives back from the state DMVs to Ford so that it can provide any e-mail addresses it has that are associated with those purchasers/lessees. Any such e-mail addresses will then be provided by Ford to JND, which will send the Court-approved e-mail notice to these addresses.

5. The notice administrator will establish and maintain a dedicated website that will contain the information in the Long Form Notice that was approved by the Court. See Dkt. 330.

6. Any timely submitted opt-out or exclusion forms will be collected by the notice administrator. Shortly after the deadline for opt-outs (January 29, 2018), the notice administrator will file a declaration with the Court confirming that the above steps were undertaken, and identifying any class members who timely elect to exclude themselves.

7. Plaintiffs respectfully request that the Court approve their selection of JND as the notice administrator. JND has extensive experience administrating complex class action lawsuits, both in the context of settlements and litigation classes. A copy of JND's resume is submitted herewith as Exhibit A.

8. Counsel for Ford has reviewed and is not opposed to any of the foregoing.

ORDER

WHEREUPON, the Court having reviewed the foregoing [PROPOSED] ORDER APPROVING PROTOCOL FOR DISSEMINATING NOTIFICATION TO THE CERTIFIED CLASSES, AND APPOINTING JND LEGAL ADMINISTRATION GROUP AS THE NOTICE ADMINISTRATOR, it is hereby ORDERED that (1) the notice protocol described above is approved, and (2) Plaintiffs' selection of JND Legal Administration as the notice administrator is approved.

ATTESTATION PURSUANT TO LOCAL RULE 5-1(i)(3)

I hereby certify that on October 13, 2017, I electronically filed the foregoing document using the CM/ECF system which will send notification of such filing to the email addresses registered in the CM/ECF system.