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IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
If You Received a Text Message from FRL Automotive LLC d/b/a
Toyota of North Miami, You May Be Entitled to a
Payment from a Class Action Settlement.
A court authorized this Notice. You are not being sued. This is not a solicitation from a lawyer.
• A Settlement has been reached in a class action lawsuit about whether FRL Automotive LLC d/b/a Toyota of North
Miami (“Defendant”) sent marketing text messages to telephone numbers after being asked to stop in violation of the
Telephone Consumer Protection Act (“TCPA”) and Florida Telephone Solicitation Act (“FTSA”). Defendant denies the
allegations and any wrongdoing. The Court has not decided who is right.
• The Settlement offers payments to Settlement Class Members who file valid Claims.
• Your legal rights are affected whether you act or do not act. Read this Notice carefully.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
If you are a member of the Settlement Class, you must submit a completed
SUBMIT A Claim Form to receive a payment. If the Court approves the Settlement and it
CLAIM FORM becomes final and effective, and you remain in the Settlement Class, you will
receive your payment by check.
You may request to be excluded from the Settlement and, if you do, you will
EXCLUDE YOURSELF
receive no benefits from the Settlement.
OBJECT Write to the Court if you do not like the Settlement.
GO TO A HEARING Ask to speak in court about the fairness of the Settlement.
You will not receive a payment if you fail to timely submit a completed Claim
DO NOTHING Form, and you will give up your right to bring your own lawsuit against
Defendant about the Claims in this case.
• These rights and options—and the deadlines to exercise them—are explained in this Notice.
• The Court in charge of this case still has to decide whether to approve the Settlement. If it does, and after any appeals
are resolved, benefits will be distributed to those who submit qualifying Claim Forms. Please be patient.
QUESTIONS? CALL 1-833-806-3492 OR VISIT WWW.FRLAUTOMOTIVETCPACASE.COM
WHAT THIS NOTICE CONTAINS
BASIC INFORMATION...................................................................................................................................................... 3
1. Why is there a Notice?
2. What is this litigation about?
3. What is the TCPA/FTSA?
4. Why is this a class action?
5. Why is there a settlement?
WHO IS PART OF THE SETTLEMENT?..................................................................................................................... 3-4
6. Who is included in the Settlement?
7. What if I am not sure whether I am included in the Settlement?
THE SETTLEMENT BENEFITS....................................................................................................................................... 4
8. What does the Settlement provide?
9. How do I file a Claim?
10. When will I receive my check?
EXCLUDING YOURSELF FROM THE SETTLEMENT........................................................................................... 4-5
11. How do I get out of the Settlement?
12. If I do not exclude myself, can I sue Defendant for the same thing later?
13. What am I giving up to stay in the Settlement Class?
14. If I exclude myself, can I still get a payment?
THE LAWYERS REPRESENTING YOU...................................................................................................................... 5-6
15. Do I have a lawyer in the case?
16. How will the lawyers be paid?
OBJECTING TO THE SETTLEMENT............................................................................................................................ 6
17. How do I tell the Court if I do not like the Settlement?
18. What is the difference between objecting and asking to be excluded?
THE FINAL APPROVAL HEARING................................................................................................................................. 7
19. When and where will the Court decide whether to approve the Settlement?
20. Do I have to attend the hearing?
21. May I speak at the hearing?
IF YOU DO NOTHING........................................................................................................................................................ 7
22. What happens if I do nothing at all?
GETTING MORE INFORMATION.................................................................................................................................. 7
23. How do I get more information?
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BASIC INFORMATION
1. Why is there a Notice?
A court authorized this Notice because you have a right to know about a proposed Settlement of a class action lawsuit known
as Karpiel v. FRL Automotive LLC in the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, and
about all of your options before the Court decides whether to give Final Approval to the Settlement. This Notice explains
the lawsuit, the Settlement, and your legal rights.
Hon. Reemberto Diaz a Judge of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida is overseeing this
case. The persons who sued, Plaintiff Jason Karpiel are called the “Plaintiff.” FRL Automotive LLC d/b/a Toyota of North
Miami is called the “Defendant”.
2. What is this litigation about?
The lawsuit alleges that Defendant sent text messages to Plaintiff’s telephone number after Plaintiff asked Defendant to stop
doing so in violation of the TCPA and FTSA, and seeks actual and statutory damages under the TCPA and FTSA on behalf
of the named Plaintiff and a class of all individuals in the United States.
Defendant denies each and every allegation of wrongdoing, liability, and damages that were or could have been asserted in
the litigation and that the claims in the litigation would be appropriate for class treatment if the litigation were to proceed
through trial.
The Plaintiff’s Complaint, Settlement Agreement, and other case-related documents are posted on the Settlement Website,
www.FRLAutomotiveTCPACase.com. The Settlement resolves the lawsuit. The Court has not decided who is right.
3. What is the TCPA/FTSA?
The Telephone Consumer Protection Act (commonly referred to as the “TCPA”) is a federal law that restricts the use of
marketing related text message calls without prior express consent. The Florida Telephone Solicitation Act (“FTSA”) is
similar to the TCPA and is a Florida state law that restricts the use of marketing text message calls to consumers 15 days
after the consumer has told the companies to “stop.”
4. Why is this a Class Action?
In a class action, one person called the “Class Representative” (in this case, Plaintiff) sue on behalf of themselves and other
people with similar claims.
All of the people who have claims similar to the Plaintiff are Settlement Class Members, except for those who exclude
themselves from the class, among others.
5. Why is there a Settlement?
The Court has not found in favor of either Plaintiff or Defendant. Instead, both sides have agreed to a settlement. By
agreeing to the Settlement, the parties avoid the costs and uncertainty of a trial, and if the Settlement is approved by the
Court, Settlement Class Claimants will receive the benefits described in this Notice. Defendant denies all legal claims in this
case. Plaintiffs and their lawyers think the proposed Settlement is best for everyone who is affected.
WHO IS PART OF THE SETTLEMENT?
6. Who is included in the Settlement?
The Settlement includes all persons who received text messages on their telephone from Defendant after having first asked
Defendant to stop sending them text messages. Specifically, the Settlement Class is defined as:
All persons within the United States who, from March 10, 2021 through September 20, 2025, (1) were sent a
text message as reflected in the text message logs produced in this case, (2) and who opted out of Defendant’s
messages but continued to receive text messages 15 days after opting out.
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The Settlement Class excludes the following: (1) the trial judge presiding over this case; (2) Defendant, as well as any
parent, subsidiary, affiliate, or control person of Defendant, and the officers, directors, agents, servants, or employees of
Defendant; (3) any of the Released Parties; (4) the immediate family of any such person(s); and (5) any Settlement Class
Member who has timely opted out of this proceeding.
7. What if I am not sure whether I am included in the Settlement?
If you are not sure whether you are in the Settlement Class or have any other questions about the Settlement, visit the
Settlement Website at www.FRLAutomotiveTCPACase.com or call the toll-free number, 1-833-806-3492. You also may
send questions to the Settlement Administrator at FRL Automotive TCPA Case, PO Box 2005, Chanhassen, MN 55317-2005.
THE SETTLEMENT BENEFITS
8. What does the Settlement provide?
To fully settle and release claims of the Settlement Class Members, Defendant has agreed to pay up to $889,525.00 (the
“Gross Settlement Fund”). The Gross Settlement Fund will also be used to pay for notice and administration costs of the
Settlement, attorneys’ fees and expenses incurred by counsel for the Settlement Class, and a service award for Plaintiff. Each
Settlement Class Member who submits a timely, valid, correct and verified Claim Form by the Claim Deadline in the manner
required by this Agreement, making all the required affirmations and representations, shall be sent a Claim Settlement Check
by the Administrator from the Settlement Fund for up to $85 per text message (for every text message they received after
they had first requested the text messages to stop) after all attorneys’ fees and expenses, all Notice and Administration Costs,
and any Service Award have been paid. Class Members only need to submit one Claim Form to receive payment for all text
messages they received after opting out. Class Claimants will be sent their Claim Settlement Payments to the address they
submitted on their Claim Form within 60 days following the Effective Date.
9. How do I file a Claim?
If you qualify for a payment, you must complete and submit a valid Claim Form. You may download a Claim Form at the
Settlement Website, www.FRLAutomotiveTCPACase.com, or request a Claim Form by calling the Settlement Administrator
at the toll-free number below. To be valid, a Claim Form must be completed fully and accurately and submitted timely. One
claim is allowed per Settlement Class Member.
You must submit a Claim Form by U.S. mail or through the Settlement Website, and it must be postmarked by April 9, 2026.
Please read the Claim Form carefully and provide all the information required. Only one Claim Form may be submitted per
Settlement Class Member.
10. When will I receive my check?
Payments in the form of a check to Settlement Class Members will be made only after the Court grants Final Approval to
the Settlement and after any appeals are resolved (see “Final Approval Hearing” below). If there are appeals, resolving them
can take time. Please be patient.
EXCLUDING YOURSELF FROM THE SETTLEMENT
If you do not want benefits from the Settlement, and you want to keep the right to sue or continue to sue Defendant on
your own about the legal issues in this case, then you must take steps to get out of the Settlement. This is called excluding
yourself—or it is sometimes referred to as “opting out” of the Settlement Class.
11. How do I get out of the Settlement?
To exclude yourself from the Settlement, you must send a timely letter by mail to:
FRL Automotive TCPA Case
P.O. Box 2005
Chanhassen, MN 55317-2006
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Your request to be excluded from the Settlement must be personally signed by you under penalty of perjury and contain a
statement that indicates your desire to be “excluded from the Settlement Class” and that, absent of excluding yourself or
“opting out,” you are “otherwise a member of the Settlement Class.”
Your exclusion request must be postmarked no later than January 23, 2026. You cannot ask to be excluded on the phone,
by email, or at the Settlement Website.
You may opt out of the Settlement Class only for yourself.
12. If I do not exclude myself, can I sue Defendant for the same thing later?
No. Unless you exclude yourself, you give up the right to sue Defendant for the claims that the Settlement resolves. You
must exclude yourself from this Settlement Class in order to pursue your own lawsuit.
13. What am I giving up to stay in the Settlement Class?
Unless you opt out of the Settlement, you cannot sue or be part of any other lawsuit against Defendant or the Released Parties
about the issues in this case, including any existing litigation, arbitration, or proceeding. Unless you exclude yourself, all of
the decisions and judgments by the Court will bind you.
The Settlement Agreement is available at www.FRLAutomotiveTCPACase.com. The Settlement Agreement provides more
detail regarding the Releases and describes the Released Claims with specific descriptions in necessary, accurate legal
terminology, so read it carefully. You can talk to the law firms representing the Settlement Class listed in Question 15 at
no charge to you, or you can, at your own expense, talk to your own lawyer if you have any questions about the Released
Claims or what they mean.
14. If I exclude myself, can I still get a payment?
No. You will not get a payment from the Gross Settlement Fund if you exclude yourself from the Settlement.
THE LAWYERS REPRESENTING YOU
15. Do I have a lawyer in the case?
The Court has appointed the following lawyers as “Class Counsel” to represent all members of the Settlement Class.
Scott Edelsberg
Edelsberg Law, P.A.,
20900 NE 30th Ave., Suite 417
Aventura, Florida 33180
Michael Eisenband, Esq.
Eisenband Law, P.A.
515 E Las Olas Blvd. Suite 120
Fort Lauderdale, Florida 33301
Manuel S. Hiraldo, Esq.
Hiraldo P.A.
101 NE 3rd Avenue, Suite 1500
Ft. Lauderdale, Florida 33301
You will not be charged for these lawyers. If you want to be represented by another lawyer, you may hire one to appear in
Court for you at your own expense.
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QUESTIONS? CALL 1-833-806-3492 OR VISIT WWW.FRLAUTOMOTIVETCPACASE.COM
16. How will the lawyers be paid?
Class Counsel intend to request up to 25% of the Settlement Fund for attorneys’ fees and out-of-pocket expenses incurred
in the litigation. The fees and expenses awarded by the Court will be paid out of the Gross Settlement Fund. The Court will
decide the amount of fees and expenses to award.
Class Counsel will also request a Service Award of up to $5,000 for Plaintiff for his service as Class Representative on behalf
of the whole Settlement Class. Any Service Award will be paid out of the Settlement Fund.
OBJECTING TO THE SETTLEMENT
17. How do I tell the Court if I do not like the Settlement?
If you are a Settlement Class Member (and do not exclude yourself from the Settlement Class), you can object to any part
of the Settlement. To object, you must timely submit a letter that includes the following:
1. A heading that includes the case name and case number—Karpiel v. FRL Automotive LLC d/b/a Toyota of North Miami
– Case Number 2025-020201-CA-01;
2. Your name, address, telephone number, the cell phone number at which you received text messages from Defendant and
if represented by counsel, the name, bar number, address, and telephone number of your counsel;
3. A signed statement stating, under penalty of perjury, that you received one or more text message from Defendant and
are a member of the Settlement Class;
4. A statement of all your objections to the Settlement including your legal and factual basis for each objection;
5. A statement of whether you intend to appear at the Final Approval Hearing, either with or without counsel, and if with
counsel, the name of your counsel who will attend;
6. The number of times in which your counsel and/or counsel’s law firm have objected to a class action settlement within
the five years preceding the date that you file the objection, the caption of each case in which counsel or the firm has
made such objection, and a copy of any orders related to or ruling upon counsel’s or the firm’s prior objections that were
issued by the trial and appellate courts in each listed case;
7. A list of all persons who will be called to testify at the Final Approval Hearing in support of the objection; and
8. Any and all agreements that relate to the objection or the process of objecting—whether written or verbal—between you
or your counsel and any other person or entity.
If you wish to object, you must file your objection with the Court (using the Court’s electronic filing system or in any manner
in which the Court accepts filings) and mail your objection to each of the following three (3) addresses, and your objection
must be postmarked by January 23, 2026.
Clerk of the Court Class Counsel Defendants’ Counsel
Eleventh Judicial Circuit Manuel Hiraldo, Esq. Ejola Cook, Esq.
Miami-Dade County Hiraldo, PA Kelley Kronenberg
73 West Flagler Street 101 NE 3rd Avenue, Suite 1500 10360 West State Road 84
Miami, FL 33130 Fort Lauderdale, FL 33301 Fort Lauderdale, FL 33324
18. What is the difference between objecting and asking to be excluded?
Objecting is telling the Court that you do not like something about the Settlement. You can object to the Settlement only if
you do not exclude yourself. Excluding yourself is telling the Court that you do not want to be part of the Settlement. If you
exclude yourself, you have no basis to object to the Settlement because it no longer affects you.
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QUESTIONS? CALL 1-833-806-3492 OR VISIT WWW.FRLAUTOMOTIVETCPACASE.COM
THE FINAL APPROVAL HEARING
The Court will hold a hearing to decide whether to approve the Settlement and any requests for fees and expenses (“Final
Approval Hearing”).
19. When and where will the Court decide whether to approve the Settlement?
The Court has scheduled a Final Approval Hearing on March 25, 2026 at 11:45 a.m. in the Virtual Courtroom. The hearing may
be moved to a different date or time without additional notice, so it is a good idea to check www.FRLAutomotiveTCPACase.
com for updates. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. The Court
will also consider the requests by Class Counsel for attorneys’ fees and expenses and for a Service Award to the Class
Representative. If there are objections, the Court will consider them at that time. After the hearing, the Court will decide
whether to approve the Settlement. It is unknown how long these decisions will take.
20. Do I have to attend the hearing?
No. Class Counsel will answer any questions the Court may have. But you are welcome to attend the hearing at your own
expense. If you send an objection, you do not have to come to Court to talk about it. As long as you submitted your written
objection on time to the proper addresses and it complies with all the other requirements set forth above, the Court will
consider it. You may also pay your own lawyer to attend the hearing, but it is not necessary.
21. May I speak at the hearing?
You may ask the Court for permission to speak at the Final Approval Hearing. To do so, your timely filed objection must
include a statement of whether you intend to appear at the Final Approval Hearing (see Question 17 above).
You cannot speak at the hearing if you exclude yourself from the Settlement.
IF YOU DO NOTHING
22. What happens if I do nothing at all?
If you are a Settlement Class Member and do nothing, meaning you do not file a timely Claim, you will not get benefits from
the Settlement. Further, unless you exclude yourself, you will be bound by the judgment entered by the Court.
GETTING MORE INFORMATION
23. How do I get more information?
This Notice summarizes the proposed Settlement. You are urged to review more details in the Settlement Agreement. For a
complete, definitive statement of the Settlement terms, refer to the Settlement Agreement at www.FRLAutomotiveTCPACase.
com. You also may write with questions to the Settlement Administrator at FRL Automotive TCPA Case, PO Box 2005,
Chanhassen, MN 55317-2005 or call the toll-free number, 1-833-806-3492.
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