A court authorized notice because you have the right to know about the proposed Settlement of this class action lawsuit and about all of your rights and options before the Court decides whether to grant final approval of the Settlement. The notice explains the lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for them, and how to get them.

The case is known as Duffy, et al. v. Mazda Motor of America, Inc., Case No. 3:24-cv-388-BJB (W.D. Ky.), before Judge Benjamin Beaton. The people who filed this lawsuit are called the “Plaintiffs” and the company they sued, Mazda Motor of America, Inc., is called the “Defendant.” The Plaintiffs and the Defendant agreed to this Settlement. The court has not made a decision about whether either side is right or wrong.

The following vehicles are covered by the Settlement:

• Mazda2 model years 2016–2022;
• Mazda3 model years 2014-2018;
• Mazda6 model years 2016-2021;
• CX-3 model years 2016-2021;
• CX-5 model years 2016-2020;
• CX-9 model years 2016-2020; and
• MX-5 model years 2016-2023.

Plaintiffs allege that the Mazda Connect Infotainment system in the Class Vehicles has technical glitches that cause it to reboot, freeze, become non-responsive, get stuck in a never-ending bootloop process, have unexpected audio or video errors, or otherwise malfunction. Mazda denies these allegations and denies that the Mazda Connect system is defective.

Under the Settlement, Mazda has agreed to provide (1) a Limited Warranty Extension (LWE); and (2) reimbursements for Out-of-Pocket Expenses. Mazda has also agreed to pay for the costs of the settlement administration and class notice, Court-approved Service Awards for the named Plaintiffs, Class Counsel’s attorneys’ fees, and Class Counsel’s litigation costs and expenses.

In a class action, one or more people called the “class representatives” sue on behalf of all people who have similar claims. Together all these people are called a “Class” or “Class Members.” One court resolves the issues for all Class Members, except for those Class Members who exclude themselves from the Class.

The class representatives and Mazda do not agree about the claims made in this Litigation. The Litigation has not gone to trial, and the Court has not decided in favor of the class representatives or Mazda. Instead, the class representatives and Mazda have agreed to settle the Litigation. The class representatives and the attorneys for the Settlement Class (i.e., Class Counsel) believe the Settlement is best for all Settlement Class Members because of the risks and uncertainty associated with continued litigation and the nature of the defenses raised by Mazda.

The Court has decided that everyone who fits the following description is a Settlement Class Member:

All persons residing in the United States and United States territories who currently own or lease, or previously owned or leased a Settlement Class Vehicle originally purchased or leased in the continental United States, Hawaii, Alaska, or any United States Territory. Class Vehicles include: Mazda2 2016–2022; Mazda3 2014–2018; Mazda6 2016–2021; Mazda CX-3 2016–2021; Mazda CX-5 2016–2020; Mazda CX-9 2016–2020; and Mazda MX-5 2016–2023.

If you did not receive a notification of the Settlement in the mail but believe you are a Class Member, or if you have any questions about your eligibility to participate in the Settlement, you may contact the Settlement Administrator.

If you are still unsure whether you are a Settlement Class Member, you can call or email the Settlement Administrator at info@MazdaInfotainmentSettlement.com or 1-844-552-0064.

The Settlement provides two benefits to Settlement Class Members: (1) a Limited Warranty Extension (LWE), and (2) Reimbursement for certain incurred Out-of-Pocket Expenses, subject to Proof of Expenses, as described below.

1. Limited Warranty Extension (LWE)

Settlement Class Members who are current owners or lessees of a Class Vehicle will automatically receive the LWE. Under the LWE, you may be entitled to receive potential software updates for Mazda Connect and (if recommended by the Authorized Mazda Dealerwho performs the Update), repair or replacement for the CMU for the Settlement Class Vehicles. The LWE provides a 24-month warranty extension with no mileage limitation for the extension period.

The warranty extension applies to Class Vehicles that are both within and outside of coverage under Mazda’s 3-year / 36,000-mile manufacturer New Vehicle Limited Warranty (NVLW) as of, February 17, 2025, the date of preliminary approval of the Settlement. For Vehicles still within the NVLW as of that date, the LWE would be added to and run from the expiration of the NVLW. For Vehicles whose NVLW is expired as of the date of preliminary approval, the LWE runs from the date of preliminary approval.

The LWE is fully transferable to subsequent owners during the term of the 24-month LWE.

2. Reimbursements for Out-of-Pocket Expenses

Settlement Class Members may submit a Claim Form for reimbursement of the following Out-of-Pocket Expenses:

• Software Updates for Mazda Connect. Settlement Class Members who previously incurred Out-of-Pocket Expenses for any Software Updates to Mazda Connect.
• CMU. Settlement Class Members who previously incurred Out-of-Pocket Expenses for repair or replacement of the CMU.
• SD Card. Settlement Class Members who incurred Out-of-Pocket Expenses for an SD Card repair or replacement.
• Display. Settlement Class Members who incurred Out-of-Pocket Expenses for a repair or replacement of the display.
• Rear-view Camera. Settlement Class Members who incurred Out-of-Pocket Expenses for a repair or replacement of the Rear-view Camera.

Settlement Class Members who incurred one or more of these Out-of-Pocket Expenses at an Authorized Mazda Dealer will be eligible for full reimbursement. For Settlement Class Members who incurred one or more the Out-of-Pocket Expenses listed above, which were made at or through any other facility that is not an Authorized Mazda Dealer, Settlement Class Members may be eligible for reimbursement under the following conditions:

• Verified Mazda OEM Parts were used
• Labor costs did not exceed the then-current Mazda national warranty labor rate for the Mazda-approved time allowed for said repair; and
• Allowable reimbursements will be capped on a per-vehicle basis at the amount of $1,750.

Claims for reimbursement must be supported by Proof of Expenses. Proof of Expenses means an original invoice, legible photocopy thereof, or other record, or some combination thereof, identifying the Out-of-Pocket Expenses paid by a Settlement Class Member. Sufficient proof should consist of one or more contemporaneous writings, including but not limited to third-party receipts, invoices, and repair orders, or bills, which, either individually or collectively, prove the existence of the Out-of-Pocket Expenses and the attendant amount.

To receive the reimbursement for Out-of-Pocket Expenses, you must submit a completed Claim Form electing to receive the reimbursement option. If you file a Claim Form for a reimbursement that is rejected by the Settlement Administrator and you do not correct it, your Claim Form will be considered ineligible.

Unless you exclude yourself, you are choosing to remain in the Class. If the Settlement is approved and becomes final, all the Court’s orders will apply to you and legally bind you. You will not be able to sue, continue to sue, or be part of any other lawsuit against Mazda and the Released Parties about the legal issues in this Litigation, resolved by this Settlement, and released by the Class Action Settlement Agreement and Release. The specific rights you are giving up are called Released Claims which are listed in FAQ 8.

In exchange for the Settlement, Settlement Class Members agree to release Mazda and its parent (Mazda Motor Corporation), subsidiaries, affiliates and related entities and all of its past and present directors, officers, employees, partners, principals, agents, and each of their predecessors, successors, parents, subsidiaries, divisions, joint ventures, attorneys, insurers, reinsurers, assigns, related or affiliated entities, Authorized Mazda Dealers, distributors, suppliers, and any members of their immediate families, and any trust for which any of them are trustees, settlers, or beneficiaries, from any and all claims, actions, causes of action, counterclaims, demands (including, without limitation, demands for arbitration), actions, suits, causes of action, allegations of wrongdoing, liabilities, rights, demands, suits, debts, liens, contracts, agreements, offsets or liabilities, including but not limited to tort claims, claims for breach of contract, breach of the duty of good faith and fair dealing, breach of statutory duties, actual or constructive fraud, misrepresentations, fraudulent inducement, statutory and consumer fraud, breach of fiduciary duty, unfair business or trade practices, restitution, rescission, compensatory and punitive damages, injunctive or declaratory relief, attorneys’ fees, interests, costs, penalties and any other claims, whether known or unknown, alleged or not alleged in the Litigation, suspected or unsuspected, contingent or matured, under federal law, state law, common law, or local law, which the Named Plaintiffs and/or any Settlement Class Member had, have, or may in the future have, with respect to any conduct, act, omissions, facts, matters, transactions or oral or written statements or occurrences relating to or arising out of the alleged claims as asserted, or as could have been asserted, in the Litigation or any other proceedings, and that relate to a Mazda Connect infotainment system and that are based on the same factual predicate asserted in the complaint filed in the Litigation, including via the use of a class action procedural device by the Named Plaintiffs and/or Settlement Class Members whether at law or equity, against MNAO and all the Releasees for injunctive relief, declaratory relief, and economic injury or damages. The Released Claims do not include claims for personal injury or wrongful death.

More information is provided in the Class Action Settlement Agreement and Release, which is available on the Important Documents tab.

You must complete and submit a Claim Form by August 1, 2025. Claim Forms may be submitted online or printed from the Settlement Website and mailed to the Settlement Administrator at the address on the form. Claim Forms are also available by calling 1-844-552-0064 or by writing to info@MazdaInfotainmentSettlement.com. The quickest way to file a Claim is online.

You may submit a claim for reimbursement for Out-of-Pocket Expenses by submitting a Claim Form and supporting Proof of Expenses on the Settlement Website, or by downloading, printing, and completing a Claim Form and mailing it along with supporting Proof of Expenses to the Settlement Administrator.

You do not need to take any action now to qualify for coverage under the LWE. Current owners or lessees of a Settlement Class Vehicle will automatically receive the LWE benefit. If you experience issues or problems with your Mazda Connect Software during the 24- month Limited Warranty Extension please bring the vehicle to an Authorized Mazda Dealer for service.

Mazda will reimburse Settlement Class Members for parts and labor paid by the Settlement Class Member for qualifying repairs involving repairs due to issues with the Mazda Connect infotainment system that were not covered by the Subject Vehicle's warranty or LWE. If the replacement was performed by an Authorized Mazda Dealer, the full amount the Class Member paid will be reimbursed. If the replacement was performed by a non-Mazda automotive repair facility, Mazda will reimburse actual costs for parts and labor paid under the following conditions: (1) Verified Mazda original equipment manufacturer (OEM) parts were used; (2) Labor costs do not exceed the then-current Mazda national warranty labor rate for the Mazda-approved time allowed for said repair; and (3) Allowable reimbursements will be capped on a per-vehicle basis at $1,750.

To file a claim for reimbursement for Out-of-Pocket Expenses, you must submit a valid Claim Form electing to receive reimbursement. To submit a Claim for reimbursement for Out-of-Pocket Expenses, you may either complete a Claim Form on this Settlement Website, by visiting the File a Claim page, or print and mail a completed Claim Form to the Settlement Administrator, postmarked on or before August 1, 2025.

Instructions for filling out a Claim for reimbursement is included on the Claim Form. You may access the Claim Form on the Important Documents tab.

If you change your mailing address or email address after you submit a Claim Form, it is your responsibility to inform the Settlement Administrator of your updated information. You may notify the Settlement Administrator of any changes by calling 1-844-552-0064, by emailing info@MazdaInfotainementSettlement.com, or by writing to the following address:

Mazda Connect Infotainment Settlement
c/o JND Legal Administration
PO Box 91494
Seattle, WA 98111

Class Counsel will apply to the Court for an award of attorneys’ fees and reimbursement of litigation costs and expenses in an amount not to exceed $1,900,000.00. Any award of attorneys’ fees and costs will be paid by Mazda separately from and in addition to any relief provided to the Settlement Class. Additionally, Class Counsel will apply to the Court for payments to each to the class representatives for their service to the Class, in the amount of $4,000 to Catherine Duffy and $2,500 each to Matthew Edlin, Lawrence Mulcahy, and Paula Hall. Any award of payments to the class representatives will be paid by Mazda separately from and in addition to any relief provided to the Settlement Class. Class Counsel’s motion for an award of Attorneys’ Fees and Expenses and for class representative payments will be posted on the Important Documents tab after it is filed with the Court. The approval process may take time.

Please be patient and check the Home Page for updates.

You do not need to hire an attorney, but you can if you want to. You, and the entire Class, are already represented by a group of attorneys listed below, who are known as Class Counsel. You do not have to pay for Class Counsel’s services. You may contact Class Counsel if you have any questions about this Notice or Settlement, but please do not contact the Court.

Class Counsel will file a motion asking the Court to award them attorneys’ fees and reimbursement of litigation costs and expenses in an amount not to exceed $1,900,000.00. They will also ask the Court to approve Service Awards to each of the Named Plaintiffs for participating in this Litigation and for their efforts in achieving the Settlement, as noted above.

Class Counsel’s application for attorneys’ fees, litigation costs and expenses, and Service Awards will be made available on the Important Documents tab before the deadline for you to comment or object to the Settlement. You can request a copy of the application by contacting the Settlement Administrator at info@MazdaInfotainmentSettlement.com.

You can choose not to be part of the Settlement and the Settlement Class. This is called “excluding yourself” or “opting out.” If you exclude yourself from the Settlement, you will not be entitled to receive the Settlement Benefits. However, you will not be bound by any judgment or settlement of the Litigation and will keep your right to sue Mazda independently and at your own expense over any claims you may have.

The Request for Exclusion must be postmarked or received by the Settlement Administrator at the address below no later than July 2, 2025:

Mazda Connect Infotainment Settlement
c/o JND Legal Administration
PO Box 91494
Seattle, WA 98111

You cannot exclude yourself by telephone or by email.

To exclude yourself from the Settlement, you must mail the Settlement Administrator a Request for Exclusion that contains the following information:

1. The name of the lawsuit: Duffy, et al. v. Mazda Motor of America, Inc., Case No. 3:24-cv-388-BJB (W.D. Ky.)
2. Your full name, current address, and telephone number
3. The approximate date of acquisition and VIN for the Settlement Class Vehicle
4. A clear statement of your intent to exclude yourself from the Settlement (for example, “Please exclude me from the ‘Mazda Connect Infotainment System Class Action Settlement”); and
5. Your signature and the date you signed it. You must send your request for exclusion postmarked no later than July 2, 2025 to the address below:

Mazda Connect Infotainment Settlement
c/o JND Legal Administration
PO Box 91494
Seattle, WA 98111

If you do not follow these procedures and deadlines to exclude yourself from the Settlement, you will remain a Settlement Class Member and forfeit any opportunity to exclude yourself from the Settlement.

This means that your rights will be determined in this lawsuit by the Settlement Agreement if it receives final approval from the Court.

Requests for exclusion will be permitted by individual Class Members only; proposed group or mass opt-outs will be deemed to be submitted on behalf of the individual signing the form.

No. Unless you timely exclude yourself, you give up any right to sue Mazda and Released Parties for the claims that this Settlement resolves. You must exclude yourself from this Litigation to start or continue with your own lawsuit or be part of any other lawsuit against Mazda or any of the Released Parties. If you have a pending lawsuit that may relate to this Settlement, speak to your lawyer in that case immediately.

You can ask the Court to deny approval of the Settlement by filing an objection. You cannot ask the Court to order a different settlement; the Court can only approve or reject the Settlement. If the Court denies approval, no Settlement payments will be sent out and the lawsuit will continue. If that is what you want to happen, you must object.

Any objection to the proposed Settlement must be in writing. If you file a timely written objection, you may, but are not required to, appear at the Final Approval Hearing, either in person or through your own attorney. If you appear through your own attorney, you are responsible for hiring and paying that attorney.

All written objections and supporting papers must:

1. identify the case name and number: Duffy, et al. v. Mazda Motor of America, Inc., Case No. 3:24-cv-388-BJB (W.D. Ky.);
2. state the Class Member’s full name, current mailing address, and telephone number;
3. include written proof establishing that he or she is a Class Member (e.g., a true copy of a vehicle title, registration, lease document, or other document reflecting current or former ownership or lease)
4. include a written statement of the objection(s), which must include a statement as to whether it applies only to the objector, a specific subset of the Settlement Class, or to the entire Settlement Class, and also state with specificity the grounds for the objection, including any evidence and legal authority the Class Member wishes to bring to the Court’s attention;
5. provide copies of any documents the objector wants the Court to consider;
6. include a statement as to whether the Class Member intends to appear at the Final Approval Hearing; and
7. submit a list of all other objections submitted by the objector or the objector’s counsel to any class action settlements submitted in any state or federal court in the United States in the previous 5 years. Each case identified should include the caption, docket number, and name of the court in which it was pending. If the Class Member or his or her counsel has not objected to any other class action settlement in the United States in the previous five years, the objector shall affirmatively so state in the objection.

If the objector is represented by counsel, the objection must be filed with the Court via the Court’s electronic filing system.

If the objector is not represented by counsel, he or she must send the objection to the Settlement Administrator via first-class mail, postage prepaid, at Mazda Connect Infotainment Settlement, c/o JND Legal Administration, PO Box 91494, Seattle, WA 98111. He or she must also serve the objection by first-class mail, postage prepaid, upon the following:

All objections must be filed electronically or postmarked no later than July 2, 2025.

Objecting is telling the Court you do not like something about the Settlement. You can object only if you stay in the Class (that is, do not exclude yourself). Requesting exclusion (sometimes called “opting out”) is telling the Court you do not want to be part of the Class or the Settlement. If you exclude yourself, you cannot object to the Settlement because it no longer affects you.

The Court will hold a Final Approval Hearing on July 28, 2025 at 9:30 a.m. ET, before the Honorable Benjamin Beaton, at the United States District Court for the Western District of Kentucky, Gene Snyder United States Courthouse, 601 West Broadway, Room 266, Louisville, KY 40202- 2227.

The date and time of the Final Approval Hearing is subject to change without further notice to the Settlement Class. Settlement Class Members should monitor the Settlement Website to confirm whether the date for the Final Approval Hearing has changed. Please note that the hearing may be held via telephone or video conference. All details about the Final Approval Hearing will be posted on the Settlement Website.

At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate, and will decide whether to approve the Settlement; Class Counsel’s application for attorneys’ fees, expenses, and costs; and the Service Awards to the Named Plaintiffs. If there are objections, the Court will consider them.

No. Class Counsel will answer any questions the Court may have. However, you are welcome to attend at your own expense. If you send an objection, you do not have to come to Court to talk about it. As long as you mail your written objection on time, the Court will consider it.

If you are a Settlement Class Member and you do nothing, you will not receive any reimbursements for any Out-of-Pocket Expenses covered by the Settlement Benefits. You will also give up certain rights, including your right to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Mazda or any of the Released Parties about the legal issues in this Litigation and released by the Settlement Agreement.

The Notice summarizes the proposed Settlement. For the precise terms and conditions of the Settlement, please see the Settlement Agreement available on the Important Documents tab, by contacting Class Counsel (see below), by accessing the Court docket in this case, through the Public Records System at www.pacer.gov or by visiting the United States District Court, Western District of Kentucky, Gene Snyder United States Courthouse, 601 West Broadway, Room 266, Louisville, KY 40202-2227, between 8:30 a.m. and 4:30 p.m. (EST), Monday through Friday, excluding Court holidays.

If you have questions about the proposed Settlement or anything in this Notice, you may contact Class Counsel at the following: