Milligan et al v. Toyota Motor Sales, U.S.A., Inc. et al

Filing 57

ORDER GRANTING PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF NOTICE, AND PRELIMINARY CERTIFICATION OF SETTLEMENT CLASS AS MODIFIED BY THE COURT AT SECTION (9). Fairness Hearing set for 12/1/2011 01:30 PM.Signed by Judge Richard Seeborg on 5/17/11. (cl, COURT STAFF) (Filed on 5/18/2011)

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Michael F. Ram, CSB #104805
Email: [e-mail]
Jeffrey B. Cereghino, CSB #099480
Email: [e-mail]
RAM, OLSON, CEREGHINO &
KOPCZYNSKI LLP
555 Montgomery Street, Suite 820
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]

*E-Filed 5/18/11*

[Additional counsel appear on signature page]

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Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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CARIN and EDWARD MILLIGAN,
California residents, on behalf of themselves
and all others similarly situated,
Plaintiffs,

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v.

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TOYOTA MOTOR SALES, U.S.A., INC., a
California corporation; and TOYOTA
MOTOR CORPORATION, a foreign
corporation,

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Defendants.

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NO. C09-05418 RS
PROPOSED ORDER GRANTING
PRELIMINARY APPROVAL OF
CLASS ACTION SETTLEMENT,
APPROVAL OF FORM OF NOTICE,
AND PRELIMINARY
CERTIFICATION OF SETTLEMENT
CLASS AS MODIFIED BY THE
COURT AT SECTION (9)
Date:
Time:
Place:
Before:

May 5, 2011
1:30 p.m.
Courtroom 3, 17th Floor
Hon. Richard Seeborg

CLASS ACTION

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WHEREAS, Plaintiffs Carin Milligan, Ed Milligan, Damashata Washington

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(“Plaintiffs”), and Defendant Toyota Motor Sales, U.S.A., Inc. (“Toyota”) have entered into a
[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 1
CASE NO. C09-05418 RS
78016 V1
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Settlement Agreement dated March 18, 2011 (the “Agreement”) in the above-captioned matter
(the “Action”);

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WHEREAS, the Agreement sets forth the terms and conditions of a proposed class
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action settlement and dismissal with prejudice of this action (the “Settlement”), and the parties
have requested preliminary approval of the Settlement set forth therein;
WHEREAS, having reviewed the Agreement and its exhibits and the pleadings and

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other papers on file in this action, the Court finds that preliminary approval of the Agreement

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and proposed Settlement should be granted, and all defined terms in this Order shall have the

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same meaning assigned to them in the Agreement;

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NOW, after review of the Agreement, and the matter having come before the Court by

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hearing on May 5, 2011; and the Plaintiffs having appeared by Karl Olson and Jeffrey B.

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Cereghino of the law firm of Ram, Olson, Cereghino & Kopczynski LLP; Steven M. Tindall of

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the law firm of Rukin Hyland Doria & Tindall; and Jessica Moy of the law firm of Andrus

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Anderson LLP; and Toyota having appeared by Frank C. Rothrock and Eva M. Weiler of the

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law firm of Shook, Hardy & Bacon LLP, on application of the Parties and based on the record;

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IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows:
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(1)

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The Court grants preliminary approval of the Agreement and proposed

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Settlement set forth therein and all terms used herein shall have the same meaning as set forth

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in the Agreement.

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(2)

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Staying the Action. All discovery and other pretrial proceedings in this Action

are hereby stayed and suspended until further order of the Court.

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 2
CASE NO. C09-05418 RS
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(3)

Jurisdiction. Pending resolution of the settlement proceedings in this matter,

the Court hereby asserts jurisdiction over the members of the Settlement Class for purposes of

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effectuating this Settlement and releasing their claims.
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(4)

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Class Certification for Settlement Purposes Only. The Court preliminarily finds

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that the proposed Settlement Class meets all of the applicable requirements under Rules 23(a)

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and 23(b)(3) of the Federal Rules of Civil Procedure, and for the purposes of the Settlement

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only, the Court conditionally certifies the following Settlement Class:

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All persons in the United States, including the Commonwealth of
Puerto Rico, who currently own or lease or who previously owned
or leased a model-year 2001-2003 Toyota RAV4 vehicle with
automatic transmissions (“Class Vehicle”). Excluded from the
Settlement Class are the following: a) officers and directors of
Toyota (as defined below) b) the Judge to whom this case is
assigned and any member of the Judge’s immediate family; and c)
persons who have submitted a timely and valid request for
exclusion from the Settlement Class.

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The Court directs that, for the sole purpose of settlement, and without an adjudication

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on the merits, the Action shall proceed as a class action on behalf of the Settlement Class.

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(a)

Pursuant to Rule 23 of the Federal Rules of Civil Procedure, and for the

purposes of settlement only, the Court finds that the Settlement Class identified by this Order is

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ascertainable, that the size of the Settlement Class is numerous, and that it would be
impracticable to join all Settlement Class Members as individual parties.
(b)

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Pursuant to Rule 23 of the Federal Rules of Civil Procedure, and for the

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purposes of settlement only, the Court finds that the claims of the Plaintiffs are typical of the

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claims of the members of the Settlement Class. Plaintiffs allege harm for the same alleged

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 3
CASE NO. C09-05418 RS
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wrongs, and the same alleged harm appears to apply to members of the Settlement Class. The
Court also finds for the purposes of settlement only, that certification of the Settlement Class is

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the superior method for resolving the disputes between the Parties. The Court further finds, for
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the purposes of settlement only, that members of the Settlement Class will benefit from the
relief obtained in the proposed Settlement.
(c)

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Should the settlement not be finally approved or implemented for any

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reason or should the Agreement be terminated as provided therein, the Settlement Class shall

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be deemed decertified and entry of this Order shall not prejudice the rights of Defendants to

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oppose certification of this action pursuant to Fed. R. Civ. 23.

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(5)

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Class Representatives and Co-Lead Class Counsel. Carin Milligan, Edwin

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Milligan, and Damashata Washington are designated as Class Representatives for the purpose

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of seeking approval of the settlement of the Action. Michael F. Ram and Jeffrey B. Cereghino

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of the law firm of Ram, Olson, Cereghino & Kopczynski LLP; Beth Terrell of the law firm of

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Terrell Marshall Daudt & Willie PLLC; Steven M. Tindall of the law firm of Rukin Hyland

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Doria & Tindall; and Jennie Lee Anderson of the law firm of Andrus Anderson LLP are hereby

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designated as Co-Lead Class Counsel for the Class.
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(6)

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Granting Preliminary Approval. The Settlement Agreement is preliminarily

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approved as fair, reasonable and in the best interests of the Settlement Class, subject to the right

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of any Settlement Class Member to challenge the Settlement Agreement and to show cause, if

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any exists, why a Final Order and Judgment dismissing this Action (based on the Settlement

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 4
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Agreement) should not be entered after due and adequate notice to the Settlement Class and a
Fairness Hearing as ordered herein.

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(7)

Findings Regarding Proposed Settlement. The Court finds that: (i) the proposed

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settlement resulted from extensive arm’s-length negotiation; and, (ii) the proposed settlement

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evidenced by the Settlement Agreement is sufficient to warrant (a) notice thereof to the

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members of the Class and (b) a full hearing on the settlement.

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(8)

Fairness Hearing. A hearing (the “Fairness Hearing”) will be held on December

1, 2011, at 1:30 p.m. in Courtroom 3 of the United States District Court for the Northern
District of California, 450 Golden Gate Avenue, San Francisco, California, 94102, to

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determine: (i) whether the Action should be finally certified for class action settlement

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purposes; (ii) whether the Settlement of the Action should be approved as fair, reasonable and

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adequate; (iii) whether the Action should be dismissed with prejudice pursuant to the terms of

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the Agreement; (iv) whether Settlement Class Members should be bound by the Release set

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forth in the Agreement; (v) whether Settlement Class Members should be subject to a

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Permanent Injunction that, among other things, bars Settlement Class Members from filing,

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commencing, prosecuting, intervening in, or participating as class members in, any lawsuit in
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any jurisdiction based on or relating to the claims and causes of action, or the facts and

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circumstances related thereto, in this Action; (vi) whether the application for incentive awards

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for the named Plaintiffs should be approved; and (vii) whether the application of Class Counsel

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for an award of Attorneys’ Fees and expenses should be approved. The Parties’ initial

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submissions in support of the Settlement shall be filed with the Court no later than 86 days

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 5
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prior to the Fairness Hearing or September 6, 2011. The Parties’ Responses, if any, to any
objections or appearances filed pursuant to Paragraph 14 of this Order shall be filed with the

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Court no later than 14 days prior to the Fairness Hearing or November 17, 2011.
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(9)

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Pre-Hearing Notices.
(a)

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Notice by Direct Mail. Notice substantially in the form filed with this

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Court as Exhibit 1 hereto (the “Class Notice”), including the modifications listed in subsection

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9(e), shall be mailed, at the Defendants’ expense, by First-Class U.S. Mail, postage prepaid, to

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the last known address of each member of the Class, and, in addition to Exhibit 1, a Spanish-

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language version of the Class Notice, a copy of which is attached as Exhibit 2, will also be sent

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to those Class members residing in Puerto Rico. The mailing list for the Notice shall be

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compiled from information that includes information provided by R.L. Polk & Co., and shall

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include all identifiable current and prior owners and lessees of the Class Vehicles in the United

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States, including the Commonwealth of Puerto Rico. Notice shall be mailed within thirty (30)

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days after receipt of the final mailing list information regarding current and prior owners and

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lessees of the Class Vehicles from R.L. Polk & Co.

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(b)

Remailing and Additional Notice. If any Notice is returned along with

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an advisory identifying a forwarding address, the Settlement Administrator shall cause the
Notice to be placed in First-Class U.S. Mail, postage paid, directed to the forwarding address.
(c)

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Proof of Mailing. At or before the Fairness Hearing, the Defendants or

the Settlement Administrator shall file with the Court a proof of mailing of the Class Notice.

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 6
CASE NO. C09-05418 RS
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(d)

CAFA Notice. The Court finds that service of this Agreement together

with the materials specified in 28 U.S.C. § 1715(b) upon the entities and individuals listed in

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Exhibit 3 no later than ten (10) days after the Agreement was filed with the Court, shall
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constitute sufficient notice to the appropriate federal and state officials pursuant to the Class
Action Fairness Act (“CAFA”), 28 U.S.C. § 1715.
(e)

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Additions to the Class Notice. Class Counsel’s motion for attorneys’ fees

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shall be included on the website established by the Settlement Administrator. The following

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statement shall be added at the end of Section 14 of the Class Notice: “A copy of Class

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Counsel’s petition for an award of attorneys’ fees and expenses and request for incentive

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awards to Class Representatives will be available at www.________.com as of September 7,

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2011.” Additionally, the first sentence in Section 15 of the Class Notice shall be modified to

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read: “If you are a Class Member, you can object to the settlement or petition for attorneys’

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fees if you don’t like any part of them.”

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(10)

Findings Concerning Notice. Having considered, among other factors: (i) the

various methods by which notice to members of the Settlement Class might be given; (ii) the

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stake of each member of the Settlement Class; and (iii) whether significant numbers of
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Settlement Class Members might desire to exclude themselves from the Settlement Class or

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appear individually, the Court finds that notice given in the form and manner provided in

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paragraph 9 of this Order is the best practicable notice and is reasonably calculated, under the

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circumstances, to apprise members of the Class of: (a) of the pendency of this Action; (b) the

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terms of the Settlement; (c) the binding effect of any judgment approving the Settlement on

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 7
CASE NO. C09-05418 RS
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those who do not exclude themselves from the Settlement Class; (d) the manner in which Class
Counsel will be compensated; (e) the manner in which any additional compensation will be

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provided to named Plaintiffs; (f) of their right to exclude themselves from the proposed
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settlement; (g) that any judgment, whether favorable or not, will include all Settlement Class

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Members who have not been excluded; and (h) that any Settlement Class Member who has not

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been excluded may object to the settlement and, if he or she desires, enter an appearance either

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personally or through counsel. The Court further notes that the Class Notice provided in the

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Agreement is written in simple English and is readily understandable by members of the

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Settlement Class. In sum, the Court finds that such notice is reasonable, that it constitutes due,

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adequate and sufficient notice to all persons entitled to be provided with notice, and that it

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meets the requirements of due process, the Federal Rules of Civil Procedure and the Rules of

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the Court.

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(11)

Communications with Class Members. Toyota is authorized to communicate

with members of the Settlement Class about the Action and the terms of the proposed
Settlement provided for in the Agreement, and to engage in any other communication within

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the normal course of its business.
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(12)

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Retention of Administrators. The Court authorizes Toyota, in consultation with

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Co-Lead Class Counsel, to retain Kurtzman Carson Consultants (formerly Rosenthal &

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Company LLC), Class Action Settlement Administrators, 75 Rowland Way, Suite 250, Novato,

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California, 94945, to help implement the terms of the proposed settlement as Administrators,

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and authorizes the Administrators to assist the Defendants in (i) mailing the Class Notice, and

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 8
CASE NO. C09-05418 RS
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(ii) carrying out such other responsibilities as are provided for in the Agreement or may be
agreed to by the Parties in the Action.

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(13)

Exclusion from Class.

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(a)

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Requests for Exclusion. Any member of the conditional Settlement Class

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who wishes to be excluded from the Class must send a written request for exclusion to the

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Administrator by first-class mail, postage prepaid, to the following address: Toyota RAV4

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ECM Settlement Claims Administrator, P.O. Box 6177, Novato, California, 94948-6177.

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Any request for exclusion from the Class Settlement must be postmarked on or before
the deadline specified in the Notice, which shall be no less than forty-five (45) days after the

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mailing of the Notice. Any such exclusion request shall: (i) set forth the Class Member’s full

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name and current address; (ii) identify the model year and model of his/her Class Vehicle(s)

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and the approximate date of purchase; (iii) state whether the Settlement Class member

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requesting exclusion still owns or leases the Class Vehicle; and (iv) specifically state his/her

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desire to be excluded from the Settlement Class. Any current owner or lessee of a Class

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Vehicle who submits a request for exclusion must also provide the vehicle identification

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number of the Class Vehicle with that request.
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If the proposed Settlement is approved, any member of the Settlement Class who has

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neither submitted an appropriate, timely, written request for exclusion from the Settlement

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Class, nor has been excluded pursuant to paragraph 13(b) below, shall be bound by all

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subsequent proceedings, orders and judgments in this Action, even if he, she or it has pending

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 9
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or subsequently initiates litigation encompassed by the Settlement Class Members’ Release
against the Defendants relating to the claims released in the Agreement.

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(b)

Class Members Involved in Bankruptcy Proceedings. If, on or before the

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Final Settlement Date, any Settlement Class Member is a debtor subject to a pending

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bankruptcy proceeding with respect to such Class Member under the federal bankruptcy laws (a

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“Bankruptcy Proceeding”), such Settlement Class Member shall be excluded from the

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Settlement Class and neither the Settlement Agreement nor the Final Order and Judgment

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(including, without limitation, the Release and the relief provided therein) shall have any effect

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with respect to the Settlement Class Member, unless on or before the Final Settlement Date: (i)

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a final order and judgment approving and incorporating the terms of the Settlement Agreement

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as to such Settlement Class Member (in its entirety and without qualification or conditions that

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affect Toyota’s rights thereunder), or such other final order and judgment that the Parties agree

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to, has been entered by the federal court having jurisdiction over such Bankruptcy Proceeding;

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and (ii) the Settlement Class Member files such an order with this Court and delivers to Class

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Counsel and Toyota’s Counsel copies of the same at the addresses set forth in paragraph 14(a)

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below.
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(14)

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Objections and Appearances.
(a)

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Written Objections. Any Settlement Class Member who wishes to object

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to the Class Settlement must send a written objection (“Objection”) to the Settlement

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Administrator at Toyota RAV4 ECM Settlement Claims Administrator, P.O. Box 6177,

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Novato, California, 94948-6177 by First-Class U.S. Mail, postage paid. All objections must

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 10
CASE NO. C09-05418 RS
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also be served on Class Counsel and on counsel for Toyota. Any objection must be postmarked
on or before the deadline specified in the Notice, which shall be forty-five (45) days after

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mailing of the Notice. Only Settlement Class members may object to the Class Settlement.
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The Settlement Administrator shall be responsible for forwarding all Objections to counsel for

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Toyota and Class Counsel. Class Counsel will file all timely and valid Objections with the

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Court.

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(b)

In his/her objection, an objecting Settlement Class member must: (i) set

forth his/her full name, current address, and telephone number; (ii) identify the model year of
his/her Class Vehicle(s), as well as the vehicle identification number of his/her Class

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Vehicle(s); (iii) state whether he/she is a current or prior owner or lessee; (iv) state when he/she

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purchased the Class Vehicle(s); (v) set forth a statement of the position the objector wishes to

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assert, including the factual and legal grounds for the position; and (vi) provide copies of any

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other documents that the objector wishes to submit in support of his/her position.

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(c)

Any Settlement Class member who does not submit an objection in

complete accordance with this paragraph and the provisions specified in the Notice shall not be

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permitted to object to the Class Settlement.
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(d)

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Subject to approval of the Court, any objecting Settlement Class member

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may appear at any hearing on the Final Approval Order and Judgment (“Fairness Hearing”)

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held by the Court, in person or through counsel, to show cause why the proposed Class

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Settlement should not be approved as fair, adequate, and reasonable, or to object to any

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petitions for attorneys’ fees, Representative Class Plaintiff incentive fees, and reimbursement

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 11
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of litigation costs and expenses. The objecting Settlement Class member must file with the
Clerk of the Court and serve upon counsel designated in paragraph 33 below, a notice of

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intention to appear at the Fairness Hearing (“Notice of Intention to Appear”) by the deadline
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specified in the Notice, which shall be forty-five (45) days after the mailing of the Notice

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pursuant to this Agreement. The Notice of Intention to Appear must include copies of any

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papers, exhibits, or other evidence that the objecting Settlement Class member (or his/her

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counsel) will present to the Court in connection with the Fairness Hearing. Any Settlement

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Class member who does not provide a Notice of Intention to Appear in complete accordance

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with the deadlines and other specifications set forth in the Notice, and who has not filed an

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Objection in complete accordance with the deadlines and other specifications set forth in this

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paragraph and the Notice, will, subject to the Court’s final determination in the exercise of its

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discretion, be barred from speaking or otherwise presenting any views at any fairness hearing.

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(15)

Deadline for Petition for Attorneys’ Fees and Expenses. Class Counsel shall file

with this Court their petition for an award of attorneys’ fees and reimbursement of expenses
and request for incentive awards to the Class Representatives no later than September 6, 2011

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(86 days before the Fairness Hearing). Any objections or responses to the petition shall be filed
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no later than October 21, 2011 (41 days before the Fairness Hearing). Class Counsel may file a

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reply to any opposition to memorandum filed by any objector no later than November 17, 2011

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(14 days before the Fairness hearing).

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 12
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(16)

Appointment of Settlement Administrator. Kurtzman Carson Consultants, 75

Rowland Way, Suite 250, Novato, California, 94945, is hereby appointed Settlement

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Administrator to carry out the duties set forth in this Order and the Settlement Agreement.
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(17)

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Service of Papers. Toyota’s Counsel and Class Counsel shall serve on each

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other and on all other parties who have filed notices of appearance, at or before the Fairness

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Hearing, any further documents in support of the proposed Settlement, including responses to

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any papers filed by Settlement Class Members. Toyota’s Counsel and Co-Lead Class Counsel

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shall promptly furnish to each other any and all objections or written requests for exclusion that

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may come into their possession and shall file such objections or requests for exclusion with the

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Court on or before the date of the Fairness Hearing. Class Counsel and Toyota’s Counsel shall

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be prepared at the Fairness Hearing to respond to any objections filed by Settlement Class

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Members and to provide other information, as appropriate, bearing on whether or not the

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settlement should be approved by the Court.

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(18)

Termination of Settlement. This Order shall become null and void, and shall be

without prejudice to the rights of the Parties, all of whom shall be restored to their respective

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positions existing immediately before this Court entered this Order, if: (i) the proposed
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Settlement is not finally approved by the Court, or does not become final, pursuant to the terms

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of the Agreement; or (ii) the proposed Settlement is terminated in accordance with the

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Agreement or does not become effective as required by the terms of the Agreement for any

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other reason. In such event, the proposed Settlement shall become null and void and be of no

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 13
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further force and effect, and neither the Agreement nor the Court’s orders, including this Order,
shall be used or referred to for any purpose whatsoever.

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(19)

Use of Order. This Order shall be of no force or effect if the Settlement does not

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become final, and shall not be construed or used as an admission, concession or declaration by

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or against Defendants or Plaintiffs or members of the Settlement Class of the validity of any

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claim or counterclaim or any actual or potential fault, wrongdoing or liability whatsoever, or by

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or against Plaintiffs, members of the Settlement Class or Defendants, that their claims or

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counterclaims lack merit or that the relief requested in the Third Amended Complaint or any

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counterclaims are inappropriate, improper, or unavailable, or as a waiver by any Party of any

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defense or claims it or they may have.
(20)

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Reservation of Rights. The Court reserves the right to approve the Agreement

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with such modifications as may be agreed by the Parties and without requiring further notice to

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the Class Members.

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(21)

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Continuation of Hearing. The Court reserves the right to continue the Fairness

Hearing without further written notice.

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IT IS SO ORDERED.
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Dated: _5/17/11
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_______________________________________
THE HONORABLE RICHARD SEEBORG
U.S. DISTRICT COURT JUDGE

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[PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT, APPROVAL OF FORM OF
NOTICE, AND PRELIMINARY CERTIFICATION OF
SETTLEMENT CLASS - 14
CASE NO. C09-05418 RS
78016 V1
82070 V2