United States District Court for the District of New Jersey
Craft v. BMW of North America, LLC, et al., Case No. 2:24-cv-06826-WJM-CF
If you are a current or former owner or lessee of certain model-year 2019 to
2020 BMW X3, X4, X5, X6, or X7 vehicles, you could get benefits from a class
action settlement.
A federal court has authorized this notice. This is not a solicitation from a lawyer.
• A nationwide settlement has been reached in a class action lawsuit against BMW of North America, LLC
(BMW NA), entitled Craft v. BMW of North America, LLC, et al., Case No. 2:24-cv-06826-WJM-CF,
involving the Shark-Fin Antenna in certain Model Year 2019 to 2020 BMW vehicles.
• For included BMW vehicles, the Settlement provides an opportunity to be reimbursed for certain past
Sealing-Defect Repair expenses and an extension of the New Vehicle Limited Warranty, as it relates to
the Sealing Defect.
• Your legal rights are affected whether you act or don’t act, so please read this notice carefully.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:
SUBMIT A CLAIM FORM Submit a Claim to receive reimbursement Claims must be submitted by the later of
for eligible past expenses potentially (i) thirty (30) days after the later of the
available to you under the Settlement. date of Final Approval of the Settlement
or (ii) the Effective Date of the
Settlement, to be posted on the
Settlement Website but estimated to be
on or about August 27, 2026. See
Question 8, below.
EXCLUDE YOURSELF Write to Class Counsel and Defendant’s Requests for Exclusion must be
Counsel to exclude yourself from (“opt postmarked by June 30, 2026. See
out” of) the Settlement. This is the only Question 12, below.
option that allows you to be part of any
other lawsuit, or your own lawsuit, against
BMW NA about the legal claims released
in this Settlement.
OBJECT Write to the judge about why you do not Objections must be postmarked by June
like the Settlement, but you will still be 30, 2026. See Question 17, below.
included in the Settlement.
GO TO A HEARING Ask to speak in Court to the judge about The Final Approval Hearing is currently
the Settlement. scheduled for July 28, 2026, at 10:00
a.m. See Questions 19 to 21, below.
DO NOTHING Give up the benefits to which you may be See Question 22, below.
entitled under the Settlement and your
right to be part of any other lawsuit
against the BMW NA about the legal
claims released by the Settlement (but not
your right to future repairs under the
extended warranty explained below).
• These rights and options -- and the deadlines to exercise them -- are explained in this notice.
• The Court in charge of this case still must decide whether to approve the Settlement before any benefits
can be distributed. Please be patient and check the Settlement Website for updates.
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WHAT THIS NOTICE CONTAINS
BASIC INFORMATION ....................................................................................................................PAGE 3
1. Why have I received this notice?
2. What is the lawsuit about?
3. Why is this a class action?
4. Why is there a Settlement?
WHO IS IN THE SETTLEMENT .....................................................................................................PAGE 4
5. How do I know if I am part of the Settlement?
THE BENEFITS: WHAT YOU GET ................................................................................................PAGE 4
6. What are the benefits of the Settlement?
7. What am I giving up in exchange for the Settlement benefits?
HOW TO GET SETTLEMENT BENEFITS ....................................................................................PAGE 5
8. How do I get the benefits of the Settlement?
9. What if my claim for reimbursement benefits is denied?
10. When will I get the Settlement benefits?
EXCLUDING YOURSELF FROM THE SETTLEMENT .............................................................PAGE 6
11. Can I exclude myself from this Settlement?
12. If I exclude myself, can I get anything from this Settlement?
13. If I don’t exclude myself, can I sue later for the same claims?
14. How do I exclude myself from the Settlement?
THE LAWYERS REPRESENTING THE CLASS ..........................................................................PAGE 7
15. Are there lawyers representing the Class in this Settlement?
16. How will the lawyers be paid?
OBJECTING TO THE SETTLEMENT ............................................................................................PAGE 7
17. How do I tell the Court if I don’t like the Settlement?
18. What’s the difference between objecting and excluding yourself?
THE COURT’S FINAL APPROVAL HEARING ............................................................................PAGE 8
19. When and where will the Court decide whether to approve the Settlement?
20. Do I need to go to the hearing?
21. May I speak at the hearing?
WHAT IF I DO NOTHING? ...............................................................................................................PAGE 8
22. What happens if I do nothing?
GETTING MORE INFORMATION .................................................................................................PAGE 8
23. Can I get more details about the Settlement?
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BASIC INFORMATION
1. Why have I received this notice?
A Court has authorized this notice because you have a right to know about the proposed settlement of this class
action lawsuit, and your options, before the Court decides whether to give “final approval” to the Settlement. This
notice explains the lawsuit, the proposed Settlement, and your legal rights. You have received this notice because
BMW of North America’s records indicate that you are a current or former owner or lessee of one or more of the
following vehicles purchased or leased in the United States, including the District of Columbia and Puerto Rico
(Class Vehicles):
Model Model Years Production Range
X3 2019 - 2020 November 1, 2018, to March 31, 2020
X4 2019 - 2020 November 1, 2018, to March 31, 2020
X5 2019 - 2020 November 1, 2018, to March 31, 2020
X6 2019 - 2020 November 1, 2018, to March 31, 2020
X7 2019 - 2020 November 1, 2018, to March 31, 2020
District Judge William J. Martini of the United States District Court for the District of New Jersey is overseeing
this class action lawsuit, known as Craft v. BMW of North America, LLC, et al., Case No. 2:24-cv-06826-WJM-
CF (the Action). Tim Craft, the person who sued, is called the “Plaintiff,” and the company that was sued, BMW
of North America, LLC (BMW NA), is called the “Defendant.”
2. What is the lawsuit about?
This lawsuit alleges that the Shark-Fin Antenna on Class Vehicles may not be fully sealed to the vehicle’s roof,
leading to water infiltration and, possibly, damage to components located below the antenna (the Sealing Defect).
BMW NA, which distributes and warrants BMW vehicles in the U.S., denies these allegations and stands behind
and supports its products.
3. Why is this a class action?
In a class action, one or more people called “Class Representatives” assert claims on behalf of people who have
similar claims. All of these people are the “Class” or “Class Members.” One court resolves the issues for all Class
Members, except for those who timely exclude themselves from (opt out” of) the Class. The Class Representative
in the Action is the Plaintiff identified above in Question 1. You have received this notice because you have been
identified as a potential Class Member.
4. Why is there a Settlement?
All parties have agreed to a Settlement to avoid further cost and risk of a trial, and so that the people affected can
begin getting benefits in exchange for releasing the Defendant from liability for the claims that were raised or
could have been raised in the Action involving the Class Vehicles’ alleged issues with the Shark-Fin Antenna.
The Settlement does not mean that the BMW NA broke any laws, or otherwise did anything wrong, because Judge
Martini did not decide which side was right. The Class Representative and the lawyers representing him think the
Settlement is fair and reasonable for the Class.
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WHO IS IN THE SETTLEMENT?
5. How do I know if I am part of the Settlement?
The Class includes all persons or entities in the United States, including the District of Columbia and Puerto Rico,
who currently own or lease, or previously owned or leased, certain U.S.-specification Model Year 2019-2020
BMW vehicles purchased or leased, and registered and operated, in the United States, including the District of
Columbia and Puerto Rico, which include the following vehicles:
Model Model Years Production Range
X3 2019 - 2020 November 1, 2018, to March 31, 2020
X4 2019 - 2020 November 1, 2018, to March 31, 2020
X5 2019 - 2020 November 1, 2018, to March 31, 2020
X6 2019 - 2020 November 1, 2018, to March 31, 2020
X7 2019 - 2020 November 1, 2018, to March 31, 2020
You have received this notice because BMW NA’s records indicate that you have or had a Model Year 2019-
2020 BMW vehicle equipped with the Shark-Fin antenna that may be included in this Action.
THE BENEFITS: WHAT YOU GET
6. What are the benefits of the Settlement?
If Judge Martini grants final approval of the Settlement and the Settlement becomes effective (the Effective Date),
you may be eligible for reimbursement of costs you incurred for a “Sealing-Defect Repair” (repair of the Shark-
Fin Antenna, telematics unit, and battery for telematics unit) on your Class Vehicle if you have already paid for
such repairs, either at a BMW Center or an independent repair shop prior to the Effective Date, by filing a claim
with the required proof, which includes:
That the replacement was made at an authorized BMW dealer (e.g., a BMW Center), or at an independent
repair shop; and
Your Class Vehicle’s Model, Model Year, and VIN; and
The identity of the owner/lessee of the Class Vehicle; and
That your Class Vehicle had fewer than 10 years and 120,000 miles at the time of the repair, as evidenced
by proof such as a repair order with vehicle mileage at the time of replacement or service records from
before and after the replacement; and
The cost of repair, with parts and labor separated; and
Proof of payment for the amount(s) sought for reimbursement (credit card receipt, credit card statement,
or cancelled check); and
The nature of the repair; and
The part(s) description and part number(s) used in the repair; and
The date of repair.
If the Sealing-Defect Repair was performed at a BMW Center, you will be reimbursed 100% of the repair costs
you incurred without any payment cap. If the repair was performed at an independent repair shop, you will be
reimbursed 100% of the repair costs you incurred up to a cap of $2,000. Regardless of where repairs were made,
reimbursement is limited to Class Vehicles that were under 10 years old or 120,000 miles (whichever comes first)
at the time of repair from the vehicle’s in-service date. If you are unsure of your Class Vehicle’s in-service date,
please check with your local BMW Center, which can look up the in-service date based on your Vehicle
Identification Number (VIN). Reimbursement amounts will be reduced by goodwill or other adjustment, coupon,
refund, or payment made by an authorized BMW Center, BMW NA, any person or entity associated with BMW
NA, an insurer, or a provider of an extended service contract.
In addition, if the Court grants final approval of the Settlement, for 60 days after entry of the Final Approval
Order, BMW Centers will provide no-cost Sealing-Defect Repairs for any Class Vehicle, regardless of age
or mileage.
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Finally, regardless of whether the Court grants final approval of the Settlement, BMW NA has extended its New
Vehicle Limited Warranty, as it relates to the Sealing Defect in Class Vehicles, to 10 years or 120,000 miles
(whichever comes first) from the vehicle’s in-service date to cover all costs associated with diagnostics and
Sealing-Defect Repair(s). After the mailing date of this notice, any Class Vehicle that requires a Sealing-Defect
Repair will be repaired by a BMW Center free of charge during the Extended Warranty Period. No reimbursement
will be available for repairs performed after the mailing date of this notice because such repairs will be provided
at no cost under the extended warranty at BMW Centers. If you experience the Sealing Defect after you receive
this Class Notice, you must take your Class Vehicle to a BMW Center if you want the free repair offered under
the limited warranty extension.
Limitations: BMW NA does not warrant or guarantee any do-it-yourself repairs or repairs performed at
independent (non-BMW Center) repair shops and, should any such repairs fail after a Class Member has made a
reimbursement claim under the Settlement, the Class Member will not be entitled to submit an additional claim
or seek replacement under the extended warranty. BMW NA does not warrant replacement parts that were not
certified by the original equipment manufacturer. The limited warranty extension will not apply to vehicles
declared a total loss, sold for salvage purposes, or branded with a “salvage” or “flood” title. There are additional
limitations and exclusions from reimbursement and extended-warranty coverage set forth in BMW NA’s New
Passenger Vehicle Limited Warranty and in the Settlement Agreement, which can be viewed at
www.SharkFinSettlement.com.
To receive reimbursement for eligible past out-of-pocket expenses, you must submit a Claim Form and include
all of the documentation described in the Settlement Agreement and identified on the Claim Form.
7. What am I giving up in exchange for the Settlement benefits?
If the Settlement becomes final, Class Members will release BMW NA and related people and entities from the
claims described and identified in Paragraphs 33 and 34 of the Settlement Agreement. In essence, Class Members
are releasing all claims (except for personal injury or damage to property other than the Class Vehicle) that could
arise based on alleged shark-fin antenna defects contained in the Class Vehicles. The Settlement Agreement is
available at www.SharkFinSettlement.com. The Settlement Agreement describes the released claims with specific
descriptions, in necessarily precise legal terminology, so read it carefully.
Judge Martini has appointed specific lawyers to represent the Class in this lawsuit and Settlement. You can contact
one of the lawyers listed in Question 15 below, free of charge, if you have questions about the released claims or
what they mean. You can also speak with your own lawyer, should you have one, about this Settlement.
HOW TO GET SETTLEMENT BENEFITS
8. How do I get the benefits of the Settlement?
If you are a Class Member and would like to obtain the reimbursement benefits (described in Question 6 above),
you need to complete the Claim Form that accompanies this notice and mail it, with all the required proof, to the
address provided on the Claim Form or file the Claim Form online through the Settlement Website portal.
Additional Claim Forms are available at www.SharkFinSettlement.com. The current deadline for submitting your
Claim Form is August 27, 2026. Claim Forms submitted after the Claims Submission Period are not eligible
for reimbursement. This date may or may not be extended, so please check the Settlement Website.
These benefits are also subject to limitations, which are discussed in Question 6 and in the Settlement Agreement.
If you have any questions on how to complete the Claim Form or what information is needed, you can call the
toll-free number at the bottom of this notice.
9. What if my claim for reimbursement benefits is denied?
There is a process in the Settlement Agreement to allow you to cure deficient Claims, such as those Claims
missing required documentation, as well as a process to validate your Claim. If the independent Claims
Administrator determines that your Claim is deficient, the Claims Administrator will notify you and allow you
thirty (30) days to cure your Claim. If the Claims Administrator determines that your Claim is still invalid, it will
notify you of that decision, which is final. If you have questions regarding this process, visit
www.SharkFinSettlement.com to see a copy of the Settlement Agreement, or contact Class Counsel below.
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10. When will I get the Settlement benefits?
If you have submitted a Claim, your Claim Form will be processed and payments will be issued on a continuing,
rolling basis after the Effective Date of the Settlement, which will be after the Court’s Final Approval Hearing,
scheduled for July 28, 2026, and all appeals, if any, are resolved.
Please be patient, and visit the website for the current status of the Settlement.
EXCLUDING YOURSELF FROM THE SETTLEMENT
11. Can I exclude myself from this Settlement?
Yes. If you want to keep the right to sue or if you are already suing BMW NA in another action over the legal
issues in this case, then you must take steps to do so. This is called asking to be excluded from – sometimes called
“opting out” of – the Settlement.
12. If I exclude myself, can I get anything from this Settlement?
If you ask to be excluded, you will not receive any of the reimbursement benefits of the Settlement and you cannot
object to the Settlement. However, your Class Vehicle will still receive the limited warranty extension described
in Question 6, above. If you opt out of the Settlement you may sue, continue to sue, or be part of a different
lawsuit against BMW NA for the same or similar claims in the future, including for claims that this Settlement
resolves. You will not be bound by anything that happens in this lawsuit.
13. If I don’t exclude myself, can I sue later for the same claims?
No. Unless you exclude yourself, you give up the right to sue BMW NA for the claims that this Settlement
resolves.
14. How do I exclude myself from the Settlement?
To exclude yourself from the Settlement, you must send a letter by mail to the Claims Administrator saying that
you want to be excluded from Craft v. BMW of North America, LLC, et al., Case No. 2:24-cv-06826-WJM-CF.
Be sure to include: (1) your full name and current address; (2) the Model Year, Model, and Vehicle Identification
Number (“VIN”) of your Class Vehicle(s) and the date(s) of purchase/lease; (3) specifically and clearly state your
desire to be excluded from the Settlement and from the Class; and (4) your signature. You cannot ask to be
excluded over the phone or via the internet. You must mail your request to be excluded, postmarked no later than
June 30, 2026, to:
Craft Claims Administrator
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391
Failure to comply with any of these requirements for excluding yourself will result in you being bound by this
Settlement.
THE LAWYERS REPRESENTING THE CLASS
15. Are there lawyers representing the Class in this Settlement?
The Plaintiffs and the Class have been represented by the law firm of Sauder Schelkopf LLC, who Judge Martini
has approved as “Class Counsel” to represent Class Members:
Matthew D. Schelkopf
Joseph B. Kenney
Sauder Schelkopf LLC
1109 Lancaster Avenue
Berwyn, PA 19312
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The Class will not be charged for these lawyers. BMW NA will pay the Class Counsel Court-approved Attorneys’
Fees and Expenses separate and apart from the Settlement benefits provided to the Class, and such payment will
not reduce the value of the benefits distributed to Class Members. If you want to be represented by another lawyer,
you may hire one to appear in Court for you at your own expense.
16. How will the lawyers be paid?
Class Counsel will ask the Court to approve an award of Attorneys’ Fees and Expenses not to exceed $800,000,
plus a Service Payment for the Class Representative not to exceed $5,000. If the Court approves this request,
BMW NA will pay it separate from the Settlement benefits. BMW NA has also agreed to pay the costs of
Settlement Notice and Administration. None of these payments will reduce the value of the benefits distributed
to Class Members.
OBJECTING TO THE SETTLEMENT
17. How do I tell the Court if I don’t like the Settlement?
If you don’t like some part of the Settlement but still want to remain included in the Settlement, you can object
to it. You can give reasons why you think the Court should not approve it. To object, you must send a letter to the
Clerk of the Court saying that you object to the Settlement Craft v. BMW of North America, LLC, et al., Case No.
2:24-cv-06826-WJM-CF. You must include: (1) your full name, current address, current telephone number, and
the name of your lawyer and your lawyer’s address if you are represented by a lawyer other than Class Counsel;
(2) the Model Year, Model, and VIN of your Class Vehicle(s) and the date(s) of purchase or lease; (3) whether
the objection applies only to you, to a specific subset of the Class, or to the entire Class; (4) the reasons why you
object and the factual and legal reasons for your objection (including all relevant documents that pertain to your
objection); (5) copies of relevant repair history or other proof that you have owned or leased the Class Vehicle
(i.e., a true copy of a vehicle title, registration, or license receipt); (6) a statement that you have reviewed the
Settlement Class definition and understand that you are a Settlement Class Member, and you have not opted out
of the Settlement Class; (7) a detailed list of any other objections to any class action settlements you have
submitted in the previous five (5) years to any court, whether state, federal, or otherwise, in the United States; (8)
a Notice of Intention to Appear at the Final Approval Hearing, if you intend to appear in person at the hearing;
and (9) your signature. A total of four copies of the objection must be mailed, one to the Court, one to the
Claims Administrator, one to Class Counsel, and one to Defendant’s Counsel at the addresses below. The
mailed copies must be postmarked on or before June 30, 2026:
COURT Clerk of Court
United States District Court for the District of New Jersey
Rev. Dr. Martin Luther King, Jr. Federal Building & U.S. Courthouse
50 Walnut Street
Newark, New Jersey 07102
CLAIMS Craft Claims Administrator
ADMINISTRATOR c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391
CLASS COUNSEL Matthew D. Schelkopf
Joseph B. Kenney
Sauder Schelkopf LLC
1109 Lancaster Avenue
Berwyn, PA 19312
DEFENDANT’S Christopher J. Dalton
COUNSEL Argia J. DiMarco
Buchanan Ingersoll & Rooney PC
550 Broad Street, Suite 810
Newark, New Jersey 07102-4582
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Note: Class Counsel or Defendant’s Counsel may depose objectors or conduct discovery related to your objection.
If you fail to make yourself available or comply with expedited discovery, the Court may not consider your
objection. If your objection is found to be frivolous or made for an improper purpose, the Court may tax you for
the costs of any discovery.
18. What’s the difference between objecting and excluding yourself?
Objecting is simply telling the Court that you don’t like something about the Settlement. You can object only if
you stay in the Settlement. Excluding yourself is telling the Court that you request to be removed from, and not
included in, the Settlement. If you exclude yourself, you have no basis to object because the Settlement no longer
affects you.
THE COURT’S FINAL APPROVAL HEARING
19. When and where will the Court decide whether to approve the Settlement?
The Court will hold a “Final Approval Hearing” to decide whether to approve the Settlement on July 28, 2026,
at 10:00 a.m., at the United States District Court for the District of New Jersey, Rev. Dr. Martin Luther King, Jr.
Federal Building & U.S. Courthouse, 50 Walnut Street, Newark, New Jersey 07102. At this hearing, Judge
Martini will determine whether the Settlement is fair, adequate, and reasonable and whether Class Members’
objections, if any, have merit. If you have filed an objection on time, you may attend and ask to speak, but you
don’t have to. However, Judge Martini will only listen to people who have properly requested to speak at the
hearing (see Question 21 below). At this hearing, Judge Martini will also decide the Service Payment for the Class
Representative, as well as the Attorney’s Fees and Expenses for the lawyers representing the Class Members. We
do not know how long the Court’s decision will take, and the hearing date may change due to other court business.
You should monitor www.SharkFinSettlement.com to find out if any dates have changed and to learn if Judge
Martini has approved the Settlement.
20. Do I need to go to the hearing?
No. Class Counsel will answer any questions the Court may have, but you are welcome to come at your own
expense. If you send an objection, you don’t have to come to Court to talk about it. As long as you mail your valid
written objection on time, the Court will consider it. You may also pay another lawyer to attend, but that’s not
required.
21. May I speak at the hearing?
You may ask Judge Martini for permission to speak at the Final Approval Hearing. To do so, you must file a
“Notice of Intent to Appear” in Craft v. BMW of North America, LLC, et al., Case No. 2:24-cv-06826-WJM-CF.
Be sure to include your name, address, telephone number, signature, and other requirements outlined in Question
17. Your Notice of Intent to Appear must be postmarked no later than June 30, 2026, and mailed to the addresses
listed in Question 17. You cannot speak at the hearing if you have excluded yourself from the Settlement.
WHAT IF I DO NOTHING?
22. What if I do nothing?
If you do nothing, you will remain part of this Settlement and give up the right to be part of any other lawsuit
against the Defendant about the legal claims released by this Settlement. Your Class Vehicle will, however, still
get the benefit of the extended warranty, if applicable. To be eligible for reimbursement benefits described in
Question 6 offered by this Settlement, you must submit a Claim Form (and the required supporting
documentation) on or before the deadline.
GETTING MORE INFORMATION
23. Can I get more details about the Settlement?
This notice summarizes the proposed Settlement. More details are in the Settlement Agreement. You can review
the Settlement Agreement and related documents at www.SharkFinSettlement.com.
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