throbber
Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 1 of 56
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`
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`Alex R. Straus (SBN 321366)
`MILBERG COLEMAN BRYSON
`PHILLIPS GROSSMAN, PLLC
`280 S. Beverley Drive
`Beverly Hills, CA 90212
`Telephone: (917) 471-1894
`Facsimile: (310) 496-3176
`E-Mail: astraus@milberg.com
`
`
`
`
`
`
`Attorneys for Plaintiff
`
`
`
`
`
`Mark Wheeler, on Behalf of Himself and all
`Others Similarly Situated,
`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF CALIFORNIA
`
` Case No.
`
`
`CLASS ACTION COMPLAINT
`
`
`JURY TRIAL DEMANDED
`
`
`Plaintiff,
`
`v.
`
`LG ELECTRONICS USA, INC.,
`
`
`
`Defendant.
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`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 2 of 56
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`Plaintiff Mark Wheeler (“Plaintiff”), by his attorneys, makes the following allegations
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`pursuant to the investigation of his counsel and based upon information and belief, except as to
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`allegations specifically pertaining to himself and his counsel, which are based on personal
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`knowledge.
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`NATURE OF THE ACTION
`This class action arises from LG’s knowing sale of QuadWash-enabled dishwashers
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`1.
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`(“Class Dishwashers”)1 equipped with defective LED control panels (“Control Panels”) and
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`identified by the following model numbers: LDF5545, LDP6797, LDT7797, LDT5665, LDT5678,
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`and LDT7808
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`2.
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`LG designed Class Dishwashers with Control Panels that are “easy to see and use[,]”2
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`and uniformly marketed each and every Class Dishwasher as “among the most energy-efficient in
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`[their] class” and utilizing “energy- and water-saving features … [that] help reduce your energy and
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`water consumptions.”3
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`3.
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`Unfortunately for consumers, each and every Control Panel—all of which are
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`identical from an assembly and mechanical engineering standpoint regardless of the model in which
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`they are equipped—suffer from an identical, latent, and pervasive defect in materials, workmanship,
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`and/or design that eventually renders Class Dishwashers inoperable well in advance of the end of
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`1 Plaintiffs reserve their right to expand this definition if discovery reveals the existence of additional
`models equipped with an LG Control Panel.
`2 Top Control Smart wi-fi Enabled Dishwasher with QuadWash, LG,
`https://www.lg.com/us/dishwashers/lg-LDT5678BD-top-control-dishwasher (last visited February
`20, 2022).
`3 LDT7808BD, LG,
`https://web.archive.org/web/20180331093453/https:/www.lg.com/us/dishwashers/lg-
`LDT7808BD-top-control-dishwasher (last visited February 20, 2022).
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 3 of 56
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`
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`their expected useful life and, thus, unsuited for their ordinary and intended purpose (the “Control
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`Panel Defect” or “Defect”).
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`4.
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`Specifically, the Defect allows moisture to penetrate the Control Panels, damaging
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`the sensitive electronic components housed therein. When the Defect first manifests, the Control
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`Panel’s buttons and/or LED display will appear to simply malfunction, either blinking the Panel’s
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`various lights or shutting off completely, which can cause Class Dishwashers to stop mid-cycle or
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`fail to re-start once a cycle is complete. Ultimately, the Defect renders the Control Panels
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`unresponsive, and without a functioning Control Panel Class members cannot commence a wash
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`cycle or use their Class Dishwashers as expected and intended.
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`5.
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`LG has been aware of the Control Panel Defect since at least 2015, when it began
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`receiving complaints from consumers concerning the Defect. And on November 8, 2018, it
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`acknowledged the Defect’s existence in a Service Bulletin (attached hereto as Exhibit A) made
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`available only to its authorized repair technicians in which it detailed the Control Panel Defect and
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`its root cause and asserted that the Defect is not present in Panels manufactured after a particular
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`date.
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`6.
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`But although LG has long known, or had reason to know, that Class Dishwashers’
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`Control Panels are Defective and are unfit for their ordinary and intended purpose and incapable of
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`performing as warranted, LG failed to disclose and actively concealed this material fact from
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`Plaintiffs and the Class.
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`7.
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`Consumers report that any and all efforts to remedy the Control Panel Defect without
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`actually replacing the Control Panel—for example, by resetting the breaker to which a Dishwasher
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`is connected—offer only temporary relief, at best. In order to permanently return their Class
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`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 4 of 56
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`
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`Dishwashers to proper working order, Class members must replace Control Panels with a non-
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`defective replacement component.
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`8.
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`Despite its longstanding knowledge of the Defect in Class Dishwashers, however, LG
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`has yet to successfully remedy the Control Panel Defect: the updated Control Panels referenced in
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`the 2018 TSB suffer from the very same Defect. Indeed, consumers report that their replacement
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`Control Panels, which LG describes in the Service Bulletin as “improvements” designed to “prevent
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`further moisture penetration,” likewise fail shortly after installation.
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`9.
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`Because LG repairs Class Dishwashers using defective Control Panels that are
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`doomed to fail, its warranty offers little in the way of actual relief and fails of its essential purpose.
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`Adding insult to injury, once LG’s one-year “labor and parts” warranty expires, LG claims the Defect
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`does not exist, declines to provide further warranty coverage, and requires consumers who have not
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`purchased an extended warranty to pay out of pocket to (temporarily) return their Class Dishwashers
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`to proper working order, even if LG previously replaced the Control Panel under warranty.
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`10.
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`LG does so even though its express limited warranty requires it to provide free
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`replacement electronics, including Control Panels, within five years of the purchase date. It instead
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`informs complaining customers that they must agree to pay diagnostic and service fees before LG
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`will provide a replacement Panel under warranty. Consumers who do not realize the extent of the
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`Defect until after their warranty has expired likewise are out of luck.
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`11.
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`LG’s unlawful conduct thus placed Plaintiff and the Class between a rock and a hard
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`place: once the Defect manifests, their only two options are to either purchase a new non- defective
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`dishwasher to replace a Class Dishwasher for which they paid a premium or keep their Class
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`Dishwasher and pay for multiple repairs.
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`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 5 of 56
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`12.
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`Accordingly, Plaintiff, on behalf of himself and all others similarly situated, bring this
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`action to redress LG’s violations of the California Consumer Legal Remedies Act (“CLRA”), Civil
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`Code §§ 1750, et seq., California’s Unfair Competition Law (“UCL”), Bus. & Prof. Code §§ 17200,
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`et seq., California’s False Advertising Law (“FAL”), Bus. & Prof. Code §§ 17500, et seq.; the
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`Magnuson-Moss Warranty Act (15 U.S.C. § 2301, et seq.), and also seeks recovery for breach of
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`express warranty, breach of implied warranty, common law fraud, and unjust enrichment.
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`THE PARTIES
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`13.
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`Plaintiff Mark Wheeler is and was at all times relevant to this complaint domiciled in
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`California and a resident of Bakersfield, California.
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`14. Mr. Wheeler purchased a Class Dishwasher, model LDT5678SS for personal and
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`family use on November 29, 2019, from a Lowes Store located in Bakersfield, California for
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`approximately $616.48.
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`15.
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`Prior to purchasing his Class Dishwasher, Mr. Wheeler researched online the wide
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`variety of LG Dishwashers and reviewed LG’s website, which claimed their Class Dishwasher was
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`“[a]mong the most energy-efficient dishwashers in its class” and through “energy- and water-saving
`features … [would] help reduce your energy and water consumption.”4 Neither LG, nor its agents,
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`sellers, or other representatives disclosed the Control Panel Defect in the Class Dishwasher to the
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`Mr. Wheeler at the point of sale or otherwise.
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`16.
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`In July of 2020, Mr. Wheeler contacted LG regarding the Control Panel Defect. LG
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`concluded upon inspection that the Control Panel would need to be replaced and did so since the
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`Dishwasher was still under warranty.
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`4 LG Top Control Smart wi-fi Enabled Dishwasher with QuadWash, LG,
`https://www.lg.com/us/dishwashers/lg-ldt5678ss-top-control-dishwasher (last visited April 1,
`2022).
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 6 of 56
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`17.
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`In February of 2021 however, only six months after replacement, Mr. Wheeler’s
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`replacement Control Panel began failing, inappropriately powering on and off again during cycles.
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`Upon inspection, the technician concluded that the Control Panel would need to be replaced again.,
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`Because the Dishwasher’s original warranty expired in November of 2021, Mr. Wheeler was left
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`with a defective Dishwasher.
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`18.
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`LG is incorporated in the state of Delaware and headquartered in Englewood cliffs,
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`New Jersey. LG manufactures and sells mobile devices, home entertainment devices, and home
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`appliances, including dishwashers, air conditioners, and kitchen appliances.
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`JURISDICTION AND VENUE
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`19.
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`This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §
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`1332(d) because there are more than 100 Class Members, the aggregate amount in controversy
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`exceeds $5,000,000.00, exclusive of interest, fees, and costs, and at least one Class Member is a
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`citizen of a state different from at least one Defendant.
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`20.
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`This Court also has subject matter jurisdiction over Plaintiffs’ Magnuson-Moss
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`Warranty Act claim, 15 U.S.C. § 2301 et seq.
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`21.
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`This Court has supplemental jurisdiction over the state law claims pursuant to 28
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`U.S.C. § 1367.
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`22.
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`This Court has personal jurisdiction over Defendant because they conduct substantial
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`business within California, including the sale, marketing, and advertising of the Class Dishwashers.
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`A substantial portion of the events giving rise to Plaintiff’s claims occurred in this State, including
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`Plaintiff’s purchase.
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`23.
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`Venue is proper in this District pursuant to 28 U.S.C. § 1391 because Defendant does
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`business throughout this District, Plaintiff purchased their Class Dishwasher in this District, and the
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`Products that are the subject of the present Complaint are sold extensively in this District.
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`5
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 7 of 56
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`
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`FACTUAL ALLEGATIONS COMMON TO ALL CLAIMS
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`A. LG’s Marketing and Advertising
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`24.
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`LG markets all its appliances as top-of-the-line, efficient, and trustworthy products
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`that “offer innovative solutions to make life good.” LG’s website boasts superior consumer goods
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`“[w]ith intuitive, responsive controls, sleep, stylish designs, and eco-friendly features” and promises
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`that their team will “be there for you every step of the way.”5
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`25.
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`According to LG, its appliances are “[c]reated to help you enjoy more of what life has
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`to offer” and that LG Dishwashers will “clean your dishes faster.” Not only does LG tout its
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`appliances and consumer goods, but the company also highlights its consumer support team through
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`its corporate website. LG’s website ensures that their support services will “[g]et your questions
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`answered about product setup, use and care, repair and maintenance issues. We can help.”6
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`26.
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`LG’s portfolio of consumer appliances includes various models of dishwashers that
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`LG designs, manufactures, warrants, markets, advertises, and sells, including dishwashers equipped
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`with LED Control Panels. LG sells its dishwashers through major retail stores such as Lowes,
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`Amazon, Home Depot, and Best Buy, throughout the United States with retail prices ranging from
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`$600 to $1,200.
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`27.
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`LG claims it designed Class Dishwashers to leave dishes “virtually spotless[,]” and
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`LG’s website advertises the appliances as having not only “stellar drying and stain removal abilities”7
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`but also as among the most energy efficient dishwashers available in the marketplace. Indeed, LG
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`uniformly marketed each and every Class Dishwasher as “among the most energy-efficient in [their]
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`5 LG Life’s Good, LG, https://www.lg.com/us/dishwashers (last visited February 15, 2022).
`6 Id.
`7 Dishwashers, LG, https://www.lg.com/us/dishwashers (last visited February 15, 2022).
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 8 of 56
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`class” and utilizing “energy- and water-saving features … [that] help reduce your energy and water
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`consumption.”8
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`28.
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`Accordingly, LG’s ubiquitous marketing campaigns lead consumers to believe that
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`Class Dishwashers are high quality, efficient, and dependable. Consequently, consumers are willing
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`to pay more for LG’s dishwashers than those offered by its competitors, even when competing
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`dishwashers have comparable features.
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`29.
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`However, as described throughout this Complaint, the Class Dishwashers do not work
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`as advertised or promoted. Instead, the Control Panels equipped in Class Dishwashers suffer from a
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`pervasive defect in materials, workmanship, and/or design that cause the Control Panels to
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`malfunction, stop mid-cycle (wasting both water and energy), and inevitably render the entire
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`machine inoperable.
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`B. The Defect
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`30.
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`Due to the Defect in Class Dishwashers’ Control Panels—which are identical from
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`an internal design, assembly, and mechanical engineering standpoint—water seeps into the Control
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`Panel, resulting in shortages that cause these costly appliances to continually stop mid-cycle—not
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`only prolonging the cycles, but also consuming excessive water and energy—and/or fail to re-start
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`once a prior cycle has been completed, eventually rendering the Control Panel totally unresponsive
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`and depriving consumers of a functioning dishwasher.
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`31.
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`One YouTube poster recorded their Dishwasher Control Panel malfunctioning as the
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`lights flashed and blinked and the buttons failed to operate.9
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`8 Soon: Top Control Dishwasher with QuadWash™ and EasyRack™ Plus, LG,
`https://web.archive.org/web/20170525074839/https:/www.lg.com/us/dishwashers/lg-LDP6797BB-top-
`control- dishwasher (last visited February 15, 2022).
`9 LG Dishwasher Display Issue, YOUTUBE,
`https://www.youtube.com/watch?app=desktop&v=htLoH1wJIMM (last visited May 25, 2021).
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 9 of 56
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`32.
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`The Defect in the Control Panel manifests during the expected useful life of the
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`Dishwasher, both within and outside the applicable warranty periods. Plaintiff and consumers expect
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`dishwashers to last for years, yet the Control Panel Defect can cause Class Dishwashers to fail in as
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`little as few months after purchase.
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`33.
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`The Control Panel Defect is substantially likely to prevent the Class Dishwashers
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`from performing their ordinary and intended purpose—washing dishes—because once the Defect
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`manifests, Class Dishwashers will eventually, if not immediately, cease to function.
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`34.
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`Because the Defect often causes consumers to believe their Dishwasher has lost
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`power, they often attempt to troubleshoot their appliance by resetting its assigned breaker and
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`returning power to the Control Panel.
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`35.
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`However, the manual reset is at best a temporary fix because the Control Panels fail
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`due to moisture penetration, which cannot be resolved by simply resetting a breaker: even if the
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`Control Panel defect does not result in an immediate and complete loss of functionality because the
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`Control Panel can be temporarily reset, the defective Control Panel (and the Dishwasher in which it
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`is equipped) will eventually become inoperable as the following representative complaints from the
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`LG website demonstrate:10
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`10 Front Control Dishwasher with QuadWash and EasyRack Plus, LG,
`https://www.lg.com/us/dishwashers/lg-LDF5545BD-front-control-dishwasher (last visited May 25,
`2021); Front Control Smart wi-fi Enabled Dishwasher with QuadWash, LG,
`https://www.lg.com/us/dishwashers/lg-ldf5678ss-front-control-dishwasher (last visited May 25,
`2021); Top Control Smart wi-fi Enabled Dishwasher with QuadWash, LG,
`https://www.lg.com/us/dishwashers/lg-LDP6797BD-top-control-dishwasher (last visited May 25,
`2021); Front Control Dishwasher with QuadWash™ and EasyRack™ Plus, LG,
`https://www.lg.com/us/dishwashers/lg-LDF5545ST-front-control-dishwasher (last visited June 15,
`2021); Front Control Dishwasher with QuadWash™ and EasyRack™ Plus, LG,
`https://www.lg.com/us/dishwashers/lg-LDF5545WW-front-control-dishwasher (last visited June
`15, 2021).
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`Comment
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`ass
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`* N
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`ot reliable
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`Recommends this product
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`X
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`t
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`Features
`—
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`Quality—
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`Yes-0
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`No-0
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`Report
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`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`9
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 10 of 56
`Case 1:22-cv-00459-DAD-BAM Document1 Filed 04/19/22 Page 10 of 56
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`expensive dishwasher
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`Features
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`© Pros:
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`Recommends this product
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`X
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`!
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`Yes - 0
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`No- 0
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`Report
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`Commer
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`5s dishwasher at all costs!
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`© Pros:
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`Recommends this product
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`X
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`|
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`Features
`Ce
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`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 11 of 56
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`Inherent problem withcircuitry
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`Quality
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`Features
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`Kevint313
`Washes great but control panel keeps fail
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`aled 4
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`‘Quality
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`Features
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`* GBGO1-2 years ag
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`t this dishwasher in 5
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`ber 2017
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`andfo
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`shy
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`have
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`an
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`extended wa
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`rough
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`Costeo.
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`The
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`a
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`Features
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`Report
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`go
`Over it
`even MORE terrible customer service
`
`Quality
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`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
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`36.
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`There is only one way to permanently cure the Defect: replace the failed Control panel
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`with a non-defective replacement Panel. LG, however, has yet to make available a non-defective
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`Control Panel.
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`C. LG’s Knowledge of the Control Panel Defect
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`37.
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`Before LG sold the Class Dishwashers, LG knew or had reason to know that the Class
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`Dishwashers suffer from the Control Panel Defect, yet it made no effort to resolve the Defect prior
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`to placing Class Dishwashers into the stream of commerce.
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`38.
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`Instead, LG continued to manufacture and sell Dishwashers equipped with the
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`defective Control Panels, and its efforts to produce a Control Panel that resolves the Defect’s
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`underlying root cause have come up short. As Plaintiff’s and the Class’s experiences show, LG’s
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`purported solutions, including releasing updated service Control Panels as described in its Service
`
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`
`
`
`
`11
`
`

`

`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 13 of 56
`
`
`
`Bulletin, have not addressed the underlying cause of the Control Panel Defect and repeatedly have
`
`proven ineffective.
`
`39.
`
`Consumers have complained repeatedly to LG about the Control Panel Defect on
`
`message boards, social media, and other websites since as early as 2015, but LG refuses to properly
`
`address and rectify the problem and has failed and refused to reimburse customers for repairs and/or
`
`replacement costs. The following are a representative sampling of complaints from the LG website
`
`that LG has personally responded to, thereby demonstrating its awareness of both the Defect’s
`
`existence and its effect on consumers:11
`
`
`
`
`
`
`11 Front Control Dishwasher with QuadWash and EasyRack Plus, LG,
`https://www.lg.com/us/dishwashers/lg-LDF5545BD-front-control-dishwasher (last visited May 25,
`2021); Front Control Dishwasher with QuadWash™ and EasyRack™ Plus, LG,
`https://www.lg.com/us/dishwashers/lg-LDF5545ST-front-control-dishwasher (last visited June 15,
`2021); Front Control Dishwasher with QuadWash™ and EasyRack™ Plus, LG,
`https://www.lg.com/us/dishwashers/lg-LDF5545WW-front-control-dishwasher (last visited June
`15, 2021).
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`
`
`
`
`12
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`

`

`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 14 of 56
`Case 1:22-cv-00459-DAD-BAM Document1 Filed 04/19/22 Page 14 of 56
`
`
`
`* brd1542-a year ago Bsapadesea!)al
`
`BhWwWbv
`~ANAN
`
`I purchased this three years ago after warranty expired main control panel failed that was about 18 months ago doing the same thing this time.
`
`Recommends this product % No
`
`Originally posted on LDF5545ST
`
`Helpful? Yes-5
`
`No-4
`
`Report
`
`Qualitya
`
`Features
`Le
`Value
`as
`
`Comment
`
`Please accept my apologies for the delayed response.| certainly hope this issue has been resolved. The extended warranty on this unit offers coverage 5 years from the date of
`purchase for the main control board, part only.If the issue is not resolved, and you would like to exercise the extended warranty, please contact LG Customer Support by direct
`message via Twitter (@LGUSSupport) or Facebook Messenger (https:/Awww.facebook.com/LGUSA,). Please be sure to provide your name, phone number, address, email, model/serial
`numbers, and date of purchase and we will be happy to assist you. Again, we apologize for any inconvenience this has caused. “Daphane
`
`
`
`1
`
`
`
`2
`Main control failure again...
`3
`4
`5
`6
`7
`Response from LG Electronics:
`LGE Social Media-8 months ago
`8
`9
`10
`11
`12
`
`
`Not a good purchase for me
`13
`14
`15
`16
`Helpful? Yes-1 No-0~~Report
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`* Heather T.14 days ago SWEEPSTAKES ENTRY RECEIVED
`
`Quality
`After less than a year, the electric control panel stopped working. Gotit serviced and it came backtolife for about 6
`months. Only to die again. Overall,
`| got less than 1 year out of this dishwasheruntil | decided to cut mylosses and —
`switch brands.
`Features
`
`Recommends this product X No
`
`Originally posted on LDF5545ST
`
`Value
`
`
`
`Comment
`
`Response from LG Electronics
`LGE Social Media - 12 days ago
`
`Wehate to hear that you experienced a problem with your unit. Your feedback is especially important to us and your concemswill be shared with our
`marketing and product teams. We work continuously to improve the quality of our products and anticipate market demands that drive customer
`satisfaction.
`If you have questions or further concerns, please reach out to our support team via private message on Facebook @LGUSSupport or
`call at 800-243-0000. Please be sure to provide your contact information, model/serial numbers and date of purchase. We apologize for the
`inconvenience and frustration caused. “Daphane
`
`
`
`
`
`
`
`
`
`
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`
`
`
`
`13
`13
`
`

`

`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 15 of 56
`Case 1:22-cv-00459-DAD-BAM Document1 Filed 04/19/22 Page 15 of 56
`
`
`
`BhWwWbv
`
`~ANAN
`
`‘Quality=<
`Features
`—eeeee!
`Value
`——
`
`
`
`Heipfu
`
`Yes-3
`
`WNo-0
`
`Report
`
`ie Incentivzed Review
`
`‘Comment
`
`Response from LG Electronics:
`Customer Service - 3 years ago
`We hate to
`vine
`have available. Ou
`
`Twitter @
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`
`
`Don't BUY!
`15
`16
`17
`18
`19
`Response from LG Electronics:
`20
`Customer Service-2 years ago
`21
`22
`23
`24
`25
`26
`27
`28
`
`* Bailey426-2 years ago SWEEPSTAKES ENTRY RECEIVED
`
`Quality
`| have had this for under 2 years and have problems with the control panel. it flashes and doesn't finish a cycle and trying to get support is like
`visiting Fort Knox! LG gave me 2 repair companies - one isn't taking warranty work and the other has to call me back. BUYER BEWARE ad
`
`@ Pros: Style/Design
`Recommends this product X No
`
`Helpful?
`
`Yes-0O
`
`No-O
`
`Report
`
`Feakaes:hh
`
`Value
`el
`
`Comment
`
`Thats not good! We're sorry to see that you've run into these issues with your dishwasher. We'll need to gather some additional details from you in order to see howwe can best assist.
`Please reach out to a specialist via Twitter @LGUSSupport or via Facebook https:/hwww.facebook.com/LGUSA/ “CP
`
`
`
`
`
`
`
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`
`
`
`
`14
`14
`
`

`

`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 16 of 56
`Case 1:22-cv-00459-DAD-BAM Document1 Filed 04/19/22 Page 16 of 56
`
`
`
`Bought this dishwasher about two years ago have had problems with it ever since. The control panel blinks and won't do anything. Unplug it
`restarted it and nothing happens. Then out of blue it wil work.
`| have been doing a lot of dishes by hand. Thanks LG for making a piece of junk
`that! paid alot of money for. | knew | should have bought a cheaper brand! Do not buy this dishwasherl
`
`‘Quality
`
`Recommends this product X No
`
`Originally posted on LDF55456D
`
`Helpful?
`
`Yes -4
`
`No-O
`
`Report
`
`BhWwWbv
`~ANAN
`
`ft sounds like we'll need to walk through some troubleshooting for your dishwasher. Please head over to our support team via @LGUSSuppert on Twitter or you can give us a call at
`600-243-0000 so that we can dig into this a little more for you. “CP
`
`
`
`Quality
`This dishwasher came newin my house andI’ve hadit repaired twice under warrantyfor the same issue. Control
`Panaykeepsfrying andout on us rendering the dishwasheruseless.
`It's nowgoing out again and I'm fighting with LG —
`to get an out of warranty repair done because they neverfixed the original issue under warranty!
`Fentuies
`This is a garbage dishwasher and LG isn't responding to me aboutgettingit fixed. A lot of people in my neighborhood el
`aré having the same issues and switching dishwasher brands.
`If LG would have just complied with coming outto fix
`my dishwasher again | wouldn't have posted this horrible review but what else am | supposed to do?
`
`Value
`—_
`
`Recommendsthis product X No
`
`Originally posted on LDF5545ST
`
`Helpful? Yes-0
`
`WNo:0
`
`Report
`
`We hate to hear that you experienced a problem with your unit. Your feedback is especially important to us and your concemswill be shared with our
`marketing and product teams. We work continuously to improve the quality of our products and anticipate market demandsthat drive customer
`satisfaction.
`If you have questions or further concerns, please reach out to our support team byprivate message on Twitter or Facebook
`@LGUSSupport orcall at 600-243-0000. Please be sure to provide your contactinformation, model/serial numbers and date of purchase. We
`apologize for the inconvenience andfrustration caused. “Daphane
`
`Comment
`
`Comment
`
`1
`* Annn-2 years ago
`
`2
`Worst dishwasher ever bought
`3
`4
`5
`6
`7
`Response from LG Electronics:
`Customer Service-2 years ago
`8
`9
`10
`11
`* JCHT - a month agoRYselLia siaeat3)
`
`Broke... multiple times
`12
`13
`14
`15
`16
`17
`18
`19
`Responsefrom LG Electronics
`LGE Social Media-a month ago
`20
`20
`21
`21
`22
`22
`23
`23
`24
`24
`25
`25
`26
`26
`27
`27
`28
`28
`
`
`
`
`
`
`
`
`
`
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`
`
`
`
`15
`15
`
`

`

`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 17 of 56
`Page 17 of 56
`Case 1:22-cv-00459-DAD-BAM Documenti Filed 04/19/22
`
`
`
`BhWwWbv
`~ANAN
`
`Originally posted on LDF5545BB
`
`Helpful? Yes-5
`
`No-O
`
`Report
`
`1
`* Big Family Man-2 years ago
`
`2
`Worst Dishwasher, Ever
`QualityEas
`Apparently, this particular unit was not intended for regular use. Purchased this in November 2018. In September 2019, scheduled the 4th service
`call for the same issues - dishwasher stops during the cycle, control panel flashes/beeps during use and/or cannotturn the unit off or on.
`3
`Despite registering with LG, | have to upload a copy of the receipt for every service call. Generally have to wait a week for service, then the
`Features.
`technician replaces the same part (display/user controls). The “fix”
`lasts a month or two and then we repeat the cycle. The 3rd service call, the
`EEEEEeeeee
`technician replaced both the display and the main circuit board. Now on the 4th call, LG has no record of the prior service and wants both parts
`4
`Value
`replaced again (rather thanjust replace the entire unit). Which means wailing for the parts to be received and then scheduling another service
`call. Being a family of 2, you can imagine that having a reliable dishwasher is quite important. So not having one for weeks on end can be quite a
`hassle. Due to the 12-month warranty,| fully expect to be purchasing another dishwasher later this year. | can guarantee it won't be another LG.
`5
`@Pros: Features/Settings
`Recommendsthis product X No
`6
`7
`8
`Response from LG Electronics:
`9
`‘Customer Service-2 years ago
`10
`11
`12
`* Henmom01-3 years ago
`
`Buyer beware
`13
`14
`15
`16
`17
`18
`19
`20
`Response from LG Electronics:
`21
`Customer Service-3 years ago
`22
`23
`24
`25
`26
`27
`28
`
`We hate to see that you've had multiple issues with your dishwasher and that you're having a hard time getting it repaired. We'll be happy to take a look and see how we can help get
`this completed for you. Please take a moment, at your convenience, to contact us directly via Twitter @LGUSSupport or Facebook https:/Awwew.facebook.com/LGUSA! “CP
`
`
`
`Where to start. | didn't have this dishwasher for 13 months when the control panel went out. Had to get a newboard. Now6 months laterit's
`going out again. | spent waytoo much money on this to now last. | will never buy an LG PRODUCT AGAIN. | have a fridge, and washer and dryer.
`Very disappointed.
`
`Recommends this product X No
`
`
`
`Helpful?
`
`Yes -5
`
`No-O
`
`Report
`
`Quality
`
`Features
`
`i rB
`
`‘Comment
`
`Comment
`
`This is certainty not what we expect out of the performance of our dishwasher. We would be happyto lock into the repair options available. Please take a moment, at your convenience,
`to contact us directly via Twitter @LGUSSupport or Facebook https:/Aaww.facebook.com/LGUSA/ or you can give us a call at 200-243-0000. “CP
`
`
`
`
`
`
`
`
`
`
`
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`
`
`
`
`16
`16
`
`

`

`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 18 of 56
`
`
`
`
`
`
`
`40.
`
`The following exemplar consumer complaints posted to LG’s own forums similarly
`
`demonstrate its years’-long knowledge of the Control Panel Defect.12
`
`
`
`
`
`
`
`
`
`
`12 Front Control Dishwasher with QuadWash and EasyRack Plus, LG,
`https://www.lg.com/us/dishwashers/lg-LDF5545SS-front-control-dishwasher (last visited February
`14, 2022); Top Control Smart wi-fi Enabled Dishwasher with QuadWash, LG,
`https://www.lg.com/us/dishwashers/lg-LDP6797BD-top-control-dishwasher (last visited February
`14, 2022).
`CLASS ACTION COMPLAINT; JURY TRIAL DEMANDED
`
`
`17
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`

`

`Case 1:22-cv-00459-DAD-BAM Document 1 Filed 04/19/22 Page 19 of 56
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`41. Consumers likewise have complained of the Control Panel Defect en masse on third-
`
`party websites such as Amazon, Home Depot, Lowes, Consumer Affairs, and BestBuy. Several
`
`exempla

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