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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 1 of 11
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`
`
`David R. Markham (SBN 071814)
`dmarkham@markham-law.com
`Maggie Realin (SBN 263639)
`mrealin@markham-law.com
`Lisa Brevard (SBN 323391)
`lbrevard@markham-law.com
`The Markham Law Firm
`888 Prospect Street, Suite 200
`La Jolla, CA 92037
`Tel.: 619.399.3995; Fax: 619.615.2067
`[Additional Counsel Listed on Next Page]
`
`
`Attorneys for Plaintiffs on behalf of themselves and the general public
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`Alejandro Corona and Cabanillas &
`Associates, P.C., on behalf of
`themselves and the general public,
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`
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`
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`Tesla, Inc., a Delaware Corporation
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`
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`v.
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`Plaintiffs,
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`
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`Defendant.
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`
`
` CASE NO.:
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`COMPLAINT FOR:
`
`
`1) PUBLIC INJUNCTIVE RELIEF FOR
`VIOLATION OF CALIFORNIA’S
`UNFAIR COMPETITION LAW, BUS. &
`PROF. CODE § 17200, § 17203, AND
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`2) PUBLIC INJUNCTIVE RELIEF FOR
`VIOLATION OF NEW YORK’S
`GENERAL BUSINESS LAW, § 349
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`
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`
`
`Corona, et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
`
`

`

`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 2 of 11
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`Catherine E. Anderson, Esq.
`GISKAN SOLOTAROFF & ANDERSON LLP
`90 Broad Street, 2nd Floor
`New York, NY 10004
`Tel: (212) 847-8315
`Fax: (646) 964-9620
`canderson@gslawny.com
`
`
`
`Roosevelt N. Nesmith, Esq.
`LAW OFFICE OF ROOSEVELT N. NESMITH LLC
`363 Bloomfield Avenue, Suite 2C
`Montclair, New Jersey 07042
`Tel: (973) 259-6990
`Fax: (866) 848-1368
`roosevelt@nesmithlaw.com
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`Pro Hac Vice Pending
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`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 3 of 11
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`Plaintiffs Alejandro Corona and Cabanillas & Associates, P.C (“Plaintiffs”), by
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`and through their attorneys of record, bring this Complaint seeking public injunctive
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`relief against Tesla, Inc. (“Defendant” or “Tesla”). Plaintiffs hereby allege, on
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`information and belief, except for information based on personal knowledge, which
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`allegations are likely to have evidentiary support after further investigation and
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`discovery, as follows:
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`NATURE OF THE ACTION
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`1.
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`This is an action seeking public injunctive relief arising from Tesla’s
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`unlawful, unfair and deceptive business practice of misrepresenting to consumers the
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`mileage driving range of its electric vehicles in violation of California’s Unfair
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`Competition Law (“UCL”) and New York’s General Business Law (“GBL”).
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`2.
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`On approximately July 27, 2023, public sources reported that Tesla has
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`engaged in a practice of inflating projections on its vehicle dashboards for the driving
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`range of its electric vehicles. Tesla dashboard range meters indicate to drivers that its
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`vehicles will travel 350 to 400 – or more – miles on a full electric charge. However, as
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`the battery is depleted, the dashboard range meters mileage projections drop at a rate
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`faster than miles are actually driven, resulting in an overall mileage range significantly
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`less than originally projected on the dashboard. Additionally, the public source reports
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`included allegations that Tesla had orchestrated a practice to quash nationwide consumer
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`complaints from this defect and service appointment requests related to this mileage
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`range issue by creating an internal “Diversion Team” whose purpose was to unilaterally
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`cancel the service appointments of customers complaining about the rate at which their
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`car’s driving range was being depeleted.
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`3.
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`The inflated mileage projections resulted in consumers, including Plaintiffs,
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`purchasing Tesla vehicles expecting a longer mileage driving range between charges than
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`their vehicles provided. Plaintiffs continued to receive false and misleading projections
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`from their Tesla vehicles dashboard range meters while using their Tesla vehicles.
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` Corona et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 4 of 11
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`Tesla’s practice violates the UCL and GBL.
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`4.
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`Pursuant to the UCL and GBL, Plaintiffs seek a public injunction
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`compelling Defendant to fix the mileage readings displayed by Tesla’s dashboard range
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`meters from Tesla’s software, hardware and/or firmware, as necessary and appropriate, so
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`that the readings reflect the actual available mileage in its electric vehicles, rather than
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`intentionally overestimated projections.
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`JURISDICTION AND VENUE
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`5.
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`Jurisdiction in this case is based on 28 U.S.C. §§ 1332. Plaintiffs and
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`Defendant are citizens of different states and the amount in controversy exceeds
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`$75,000, exclusive of interests and costs.
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`6.
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`The Court has jurisdiction to hear and determine this suit because Defendant
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`Tesla, Inc., conducts substantial business within the San Franciso Bay area, including in
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`Palo Alto, California where it has its Engineering Headquarters. Tesla, Inc., is a
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`Delaware corporation headquartered in Austin, Texas.
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`7.
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`Venue is proper in this District because Tesla conducts substantial business
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`within the San Franciso Bay area.
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`PARTIES
`
`8.
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`Plaintiff ALEJANDRO CORONA is currently a resident of San Diego,
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`California. Mr. Corona owns and has previously owned Tesla vehicles, including a 2023
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`Tesla Model Y.
`
`9.
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`Plaintiff CABANILLAS & ASSOCIATES, P.C.
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`is a professional
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`corporation (law firm)
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`located
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`in White Plains, New York. CHRISTOPHER
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`CABANILLAS, a member of CABANILLAS & ASSOCIATES, P.C, is currently a
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`resident of Connecticut. Cabanillas & Associates, P.C. purchased a 2018 Tesla Model X
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`100D on or about December 10, 2018.
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`10. Defendant TESLA, INC. is a Delaware Corporation with its principal place
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`of business in Austin, Texas. Plaintiffs are informed and believe, and on that basis, allege
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`3
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` Corona et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 5 of 11
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`that Tesla, Inc. and at all relevant times was, a Delaware corporation authorized to do
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`business in California.
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`11. At all relevant times, Tesla was doing business in numerous counties
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`throughout California. Tesla is a car manufacturer and dealer operating numerous offices
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`and facilities throughout California, including within the San Franciso Bay area.
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`FACTUAL ALLEGATIONS
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`12. The mileage range Tesla has represented to its consumers and designed its
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`software to reflect on the dashboard for its vehicles, intentionally does not match reality.
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`Tesla advertised mileage projections of 350 to 400 miles – or more – on a fully charged
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`battery, and programmed its software to display mileage readings on its vehicles’
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`dashboard range meters that reflected the advertised projections. However, as Plaintiffs
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`and similarly situated consumers drove the vehicles and thereby discharged the battery,
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`the projected mileage range would diverge from the projections, and drop, often
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`significantly, resulting in an actual mileage range which was much less than Tesla’s
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`dashboard projections.
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`13. Plaintiffs and similarly situated consumers did not receive the advertised
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`mileage projections or the dashboard full battery projected mileage range, and instead
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`purchased vehicles with a lesser mileage range than advertised and projected in their
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`vehicles. This negatively impacted Plaintiffs’ and similarly situated consumers’ ability to
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`reliably drive their vehicles between charges. There is some degree of variance in all
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`electric vehicles battery performance, due to numerous factors. Nonetheless, Tesla’s
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`mileage projections do not account for all relevant facts. Instead, Tesla has intentionally
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`programmed its software to provide overly optimistic mileage range projections.
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`14. As reported by Reuters on July 27, 2023, Tesla created an internal
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`“Diversion Team” to address Tesla’s large number of consumer complaints concerning
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`their vehicles failure to achieve advertised or dashboard meter projected driving range.
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`Tesla employees were instructed to blame the shortfalls in projected mileage on the
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`4
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` Corona et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 6 of 11
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`consumers themselves for their driving habits and to unilaterally cancel scheduled service
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`appointments related to this mileage driving range issue.
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`15. These unlawful, unfair and deceptive practices occurred systematically and
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`were done with the full knowledge and consent of Defendant.
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`16. Upon information and belief, the above–mentioned unlawful, unfair and/or
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`fraudulent practices by Defendant with respect its fraudulent mileage projections were
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`imposed on all consumers who purchased Tesla vehicles from Tesla dealerships in
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`California and/or New York and continues to the present day.
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`17. Defendant’s conduct, as alleged here, caused Plaintiffs, and other Tesla
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`consumers public harm because they were unable to use their vehicles safely and reliably
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`to the projected driving ranges. A vehicle’s driving range is a significant factor in the
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`consumer’s purchasing decision, and vehicle charging capacity must be reliable,
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`particularly when taking longer trips and planning distance between charging stations.
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`Plaintiffs and other consumers are unable to reliably predict the amount of time required
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`to complete a trip due to more charging being required to reach their destinations.
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`Plaintiffs and similarly situated consumers were – and continue to be – harmed by Tesla’s
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`failure to accurately advertise and display the mileage range projections.
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`18. Plaintiffs bring this suit on behalf of themselves and the general public who
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`have purchased a Tesla vehicle during the relevant time period. Plaintiffs bring this action
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`for public injunctive relief and do not assert a class action. See McGill v. Citibank, N.A.
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`(2017) 2 Cal.5th 945, 958-61.
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`FIRST CAUSE OF ACTION
`VIOLATION OF CALIFORNIA’S UNFAIR COMPETITION LAW
`(Violation of California’s Unfair Competition Law,
`Bus. & Prof. Code § 17200 and § 17203)
`(By California Plaintiff Corona Against Defendant)
`19. Plaintiff Corona re–alleges and incorporates all preceding paragraphs as if
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`fully set forth herein.
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`
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`20. Defendant is a “person” as that term is defined under Cal. Bus. and Prof.
`5
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` Corona et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 7 of 11
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`Code §17201.
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`21.
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`§ 17200 of the California Business and Professions Code (the “UCL”)
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`prohibits any unlawful, unfair and/or fraudulent business practices.
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`22. Through the actions alleged herein, Defendant has engaged in unlawful,
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`unfair and/or fraudulent conduct within the meaning of the UCL.
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`23. Defendant has engaged in unlawful practices by failing to provide accurate
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`advertised and dashboard projections for the mileage its consumers would receive on
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`their Tesla vehicles. Under California law, Telsla gives an implied warranty that its
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`vehicles are fit to be used as represented by its onboard performance instruments,
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`including its in-dash range meters, and this warranty has been breached by Tesla through
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`the above-described conduct and omissions. Such conduct is also both deceptive and
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`unfair.
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`24. Additionally, as reported, Defendant has worked to quash and divert
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`consumer complaints and service appointment requests for this mileage driving range
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`issue so as to cover up and conceal its conduct.
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`25. An unlawful business activity includes “anything that can properly be called
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`a business practice and that at the same time is forbidden by law.” Barquis v. Merchants
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`Collection Ass’n, 7 Cal. 3d 94, 113 (1972). To meet the “unlawful” prong, the person
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`suing under Section 172000 “borrows” violations of other laws and treats them as
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`unlawful practices independently actionable under the UCL. Saunders v. Superior Court,
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`27 Cal. App. 4th 832, 839 (1994). “Virtually any statute or regulation (federal or state)
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`can serve as a predicate for a UCL unlawful practice cause of action.” Guitierrez v.
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`Carmax Auto Superstores Cal., 19 Cal. App. 5th 1234, 1265 (2018).
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`26. Through its action alleged herein, Defendant has engaged in unfair
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`competition within the meaning of the UCL. Defendant’s conduct, as alleged herein,
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`constitutes unlawful, unfair, and/or fraudulent business practices under the UCL.
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`27. Tesla’s conduct
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`is
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`in addition
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`immoral, unethical, oppressive, and
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`6
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` Corona et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 8 of 11
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`unscrupulous, and thereby constitutes unfair and unlawful business practices in violation
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`of California Business and Professions Code § 17200 et seq.
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`28. Plaintiff and similarly situated members of the general public seek to
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`prohibit Tesla from engaging in any of the above described unfair, unlawful and/or
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`fraudulent business practices in the future.
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`29. Plaintiff has standing to assert this claim because he has suffered and/or will
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`suffer an injury in fact in use of his vehicles and has lost and/or will lose money and
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`value of his vehicles as a result of Defendant’s conduct.
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`30. Business and Professions Code Section 17203 states, in part: “Any person
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`who engages, has engaged, or proposes to engage in unfair competition may be enjoined
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`in any court of competent jurisdiction. The court may make such orders or judgments,
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`including the appointment of a receiver, as may be necessary to prevent the use or
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`employment by any person of any practice which constitutes unfair competition, as
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`defined in this chapter, or as may be necessary to restore to any person in interest any
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`money or property, real or personal, which may have been acquired by means of such
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`unfair competition.”
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`31. Pursuant to Section 17203, Plaintiff Corona seeks a public injunction
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`prohibiting Defendant from projecting on its in dash range meters intentionally inaccurate
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`mileage readings for their vehicles and enjoining future violations.
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`32. Plaintiff and other similarly situated members of the general public have no
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`plain, speedy, and/or adequate remedy at law to redress the injuries which they have
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`suffered as a consequence of the unfair, unlawful and/or fraudulent business practices of
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`Tesla. As a result of the unfair, unlawful and/or fraudulent business practices described
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`above, Plaintiff and other similarly situated members of the general public have suffered
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`and will continue to suffer irreparable harm unless Tesla is restrained from continuing to
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`engage in these unfair and unlawful business practices.
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`33. Plaintiff Corona has assumed the responsibility of enforcement of the laws and
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` Corona et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 9 of 11
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`public policies specified here by suing on behalf of himself and other similarly situated
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`members of the general public who purchased a Tesla vehicle from Defendant in
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`California. Plaintiff’s success in this action will enforce important rights affecting the
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`public interest. Plaintiff will incur a financial burden in pursuing this action in the public
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`interest, and an award of injunctive relief would confer a significant benefit on the public.
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`Pursuant to Code of Civil Procedure § 1021.5, Plaintiff Corona requests that the court
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`award him reasonable attorneys’ fees and costs incurred by him in this action.
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`SECOND CAUSE OF ACTION
`Violation of New York General Business Law § 349
`(GBL §349, et. seq.)
`(New York Plaintiff Cabanillas & Associates, P.C. Against Defendant)
`32. Plaintiff Cabanillas & Associates, P.C. (“Cabanillas”) repeats and realleges
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`each preceding paragraph of the Complaint as if fully set forth herein.
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`33. Plaintiff Cabanillas and others similarly situated are “persons” and members
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`of the consuming public within the meaning of GBL §349(h).
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`34. GBL §349(a) states: “Deceptive acts or practices in the conduct of any
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`business, trade or commerce or in the furnishing of any service in this state are hereby
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`declared unlawful.”
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`35. Defendant’s acts and practices alleged herein took place within New York
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`and constitute acts, uses, or employment of deception, fraud, unconscionable and unfair
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`commercial practices, false pretenses, false promises, misrepresentations, or the knowing
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`concealment, suppression, or omission of material facts with the intent that others rely
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`upon such concealment, suppression, or omission, in connection with the sale or
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`advertisement of merchandise, and with the subsequent performance, of Defendant in
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`violation of § 349 of New York's General Business Law, making deceptive and unfair
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`acts and practices illegal.
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`36. Defendant’s conduct is deceptive because it is likely to mislead consumers
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`and the public, including Plaintiff Cabanillas and other similarly situated members of the
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` Corona et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 10 of 11
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`general public, by making them believe, falsely, that their vehicles would reach longer
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`mileage ranges than were actually possible. Defendant’s representations and omissions
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`were materially false and misleading and likely to deceive the consuming public because
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`Defendant knew, or reasonably should have known, and failed to disclose that the
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`vehicles mileage projections were inaccurate.
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`37. The deceptive acts and practices of Defendant has directly, foreseeably, and
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`proximately caused injury to Plaintiff Cabanillas and other similarly situated purchasers
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`in New York.
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`38. Plaintiff Cabanillas and others similarly situated have no adequate remedy of
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`law.
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`39. Plaintiff Cabanillas and other similarly situated members of the general
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`public who purchased Tesla vehicles in New York state are entitled to pursue claims
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`against Defendant for injunctive relief, costs and attorney’s fees pursuant to GBL §349(h)
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`to redress Defendant’s violations of GBL §349(a).
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiffs, on behalf of themselves and the general public, pray for
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`judgment against Defendant as follows:
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`A. A judicial declaration that Tesla’s conduct is unlawful, unfair and/or fraudulent
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`and an order halting Tesla’s further misrepresentation of the projected mileage
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`range in its vehicles, and requiring Tesla to accurately display the mileage range
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`of its vehicles;
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`B. Costs of suit;
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`C. Pre- and post-judgment interest;
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`D. Attorneys’ fees pursuant to Code of Civil Procedure §1021.5;
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`E. Attorneys’ fees pursuant to GBL §349(h); and
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`///
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`///
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`9
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` Corona et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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`Case 5:23-cv-03902-VKD Document 1 Filed 08/03/23 Page 11 of 11
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`F. Such other equitable relief as the Court may deem just and proper.
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`THE MARKHAM LAW FIRM
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`DATED: August 3, 2023
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`By:
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` David R. Markham
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` Maggie Realin
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` Lisa Brevard
`Attorneys for Plaintiffs
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` Corona et al. v. Tesla, Inc.
`COMPLAINT FOR PUBLIC INJUNCTIVE RELIEF
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