28.  Honda has become one of the most popular automobile brands in the United States  as a result of its extensive and consistent marketing focused upon the quality, safety, and reliability  of its vehicles.   29.  Honda’s claims of excellence in quality, design, safety, and reliability are consistent  themes in its promotional materials.   30.  In fact, Honda has an entire section on its website entitled “safety,” where Honda  touts the safety of its vehicles.   31.  On its website, Honda states “Honda is a mobility company – we move people.   But, for us, safety is an enormous priority.  We don’t just want to move you; we want to move you  safely.”   33.  The website goes on to say “This kind of flexibility and affordability allows Honda  to make the road safer for everybody on it by engineering for worst case scenarios in an  unprecedented way.”3   34.  Honda touted its focus on safety on its Facebook page as well, stating that “[t]he  future of mobility is all about human connectivity and increased safety.”4   35.  On September 20, 2019, Honda issued a press release discussing “the automaker’s  deep-rooted and ongoing commitment to safety” and describing Honda’s new “Safety for  Everyone” campaign.  Honda explains that “‘Safety for Everyone’ represents Honda’s unique  approach to safety – that everyone sharing the road should be able to safely and confidently enjoy  the freedom of mobility.”   36.  Honda echoed its message regarding the quality, reliability, and safety of its  vehicles in the marketing materials specific to the Class Vehicles.   37.  The brochure for the 2016 Honda Accord touts the vehicle’s safety and reliability,  claiming that it is “Helping protect precious cargo” and that its “Convenient features make driving  a simpler task” and that its “suite of safety and driver-assistive technologies help free you to enjoy  your driving experience.”  One of the main slogans on the brochure tells drivers to “Boldly go.”5  3  Safety, Virtual & Real-World Tests, HONDA, https://www.honda.com/safety/virtual-and-real- world-tests (last visited May 24, 2021).  4  Honda,  88.  NHTSA complaints regarding the Defect in the 2018 CR-V:  March 6, 2018 NHTSA ID NUMBER: 11076480  Components: ELECTRICAL SYSTEM  NHTSA ID Number: 11076480  Incident Date January 31, 2018  Consumer Location CHASKA, MN  Vehicle Identification Number 5J6RW2H80JL****  Summary of Complaint  A.  Honda’s Advertisement of Class Vehicles Centered on Quality, Safety  & Reliability   AVAILABLE. THE DEALER (AUTOPARK HONDA, (919) 467-4747) WAS TO SCHEDULE  AN APPOINTMENT TO DIAGNOSE THE VEHICLE AND ADDRESS THE RECALL  REPAIR. THE MANUFACTURER WAS NOTIFIED OF THE FAILURE. THE FAILURE  AWARE OF THE FAILURE AND PROVIDED A CASE NUMBER. THE FAILURE  RECURRED. THE VEHICLE WAS NOT REPAIRED. THE FAILURE MILEAGE WAS  8,900.  December 30, 2020 NHTSA ID NUMBER: 11385578  Components: ELECTRICAL SYSTEM, UNKNOWN OR OTHER  NHTSA ID Number: 11385578  Incident Date December 27, 2020  Consumer Location ROCKY MOUNT, VA  Vehicle Identification Number 5J6RW2H88KL****  Summary of Complaint  CAME WITH COMPLETELY DIED AND COULDN’T EVEN GET A JUMP. CHANGED IT  AND NOW I HAVE TO KEEP GETTING JUMP EVERYDAY. MY WINDSHIELD HAS  ALSO CRACKED TWICE FROM PASSENGER SIDE TO DRIVER SIDE. NO PUNCTURE  CHARGE IT AGAIN TO SEE IF THAT HELPS THE PROBLEM. IT IS NOW DECEMBER  14, 2020 AND I AM GOING TO CALL THE HONDA DEALERSHIP TO HAVE MY CAR  TOWED IN TODAY FOR THE EXACT SAME PROBLEM OF THE BATTERY BEING  CORRECTED.  March 11, 2019 NHTSA ID NUMBER: 11185761  Components: ELECTRICAL SYSTEM  NHTSA ID Number: 11185761  Incident Date February 1, 2019  Consumer Location CUDDEBACKVILLE, NY  Vehicle Identification Number N/A  Summary of Complaint  DISPLAYED: “ANTI THEFT SYSTEM. THIS SYSTEM HAS LOST POWER. PUSH AND  HOLD THE POWER BUTTON FOR MORE THAN TWO SECONDS TO ENABLE THE  SYSTEM.” I ASSUMED THAT THE VEHICLE WAS DIRECTING ME TO HOLD THE  DRAINED WHILE PARKED OVERNIGHT AND HAD TO CHARGE BATTERY TO  START. TOOK TO DEALER, WHO DID A BATTERY TEST AND FOUND NO ISSUE.  THERE IS A HONDA TSB CAMPAIGN, BUT HONDA TELLS ME MY VIN IS OUT OF  EVERYDAY AND WE TRAVEL WHICH MEANS THE CAR MAY NOT BE DRIVEN FOR  10 DAYS OR MORE THE SERVICE ADVISOR INDICATED THAT WE NEED TO  ACQUIRE A BATTERY CHARGER BECAUSE MOST LIKELY THE BATTERY WOULD  FOURTH INCIDENT, THE DEALER CHARGED THE BATTERY. AFTER THE FIFTH  INCIDENT, ONE WEEK LATER, THE DEALER CHARGED THE BATTERY AND  CLAIMED ONLY A .002 MILIAMP DRAW.   HAPPENED. I LEFT IT OVER NIGHT AND IT WAS NORMAL AGAIN THE NEXT DAY.  RIGHT NOW, AS I’M WRITING THIS COMPLAINT, THERE’S ANOTHER PROBLEM. AN  HOUR AGO, I PARKED AT A RESTAURANT’S PARKING LOT. I CAME OUT 40  HAPPENNED TWICE SINCE THEN AND DEALERSHIP DOES NOT PROVIDE A FIX.  August 24, 2017 NHTSA ID NUMBER: 11019266  Components: ELECTRICAL SYSTEM  NHTSA ID Number: 11019266  Incident Date August 17, 2017  Consumer Location SAMMAMISH, WA  Vehicle Identification Number 5J6RW2H98HL****  Summary of Complaint  INCLUDED IN NHTSA CAMPAIGN NUMBER: 17V418000 (ELECTRICAL SYSTEM).  THE VEHICLE WAS NOT REPAIRED. THE FAILURE MILEAGE WAS 36,639. THE VIN  WAS UNAVAILABLE.  March 28, 2019 NHTSA ID NUMBER: 11192228  Components: ELECTRICAL SYSTEM, ENGINE  NHTSA ID Number: 11192228  Incident Date March 15, 2019  Consumer Location COVINA, CA  Vehicle Identification Number 1HGCR2F60GA****  Summary of Complaint  IT IN FOR SERVICE AT EH HONDA AUTONATION IN COSTA MESA CA AND THEY  TOLD ME THAT EVERYTHING CHECKED OUT FINE. I WAS WORKING IN LOS  ANGELES FOUR DAYS LATER AND ONCE AGAIN THE CAR WOULDN’T START.  LAST 3 MONTHS. THE FIRST TIME WAS ~7-8K MILES.  August 6, 2018 NHTSA ID NUMBER: 11118082  Components: ELECTRICAL SYSTEM  NHTSA ID Number: 11118082  Incident Date July 1, 2018  Consumer Location KLAMATH FALLS, OR  Vehicle Identification Number 2HKRW2H53JH****  Summary of Complaint  MILES)....THE FIRST INCIDENT CAME OUT OF THE BLUE - ON MAY 11TH, 2017 I  USED MY CAR AT 1 PM AND WHEN I TRIED TO LEAVE WORK AT 4:30 THE CAR  DISPLAY FLASHED A BUNCH OF ODD MESSAGES AND THE CAR WOULDN’T TURN  MY WIFE DRIVE THE CAR DUE TO NOT HAVING THE CONFIDENCE THAT THE CAR  WILL START, ESPECIALLY IF SHE HAS THE KIDS WITH HER. I WILL BE TAKING IT  IN AGAIN ON MONDAY AND SEE WHAT THEY HAVE TO SAY. I HAVE READ THAT  NO DIFFERENCE. I THEN PULLED OVER WHEN SAFE, TURNED THE VEHICLE OFF,  WAITED FOR 1 MINUTE AND THEN TURNED THE VEHICLE BACK ON. THE  NAVIGATION SCREEN WAS BACK ON TO NORMAL. THE INCIDENT OCCURRED ON  NOT DETERMINED. THE MANUFACTURER AND LOCAL DEALER WERE NOT  NOTIFIED OF THE FAILURE. THE FAILURE MILEAGE WAS 56,000.  April 11, 2019 NHTSA ID NUMBER: 11195584  Components: ELECTRICAL SYSTEM  NHTSA ID Number: 11195584  Incident Date April 11, 2019  Consumer Location TURLOCK, CA  Vehicle Identification Number N/A  Summary of Complaint  NOTIFIED OF THE FAILURE. THE APPROXIMATE FAILURE MILEAGE WAS 80. *TT  *TR  February 6, 2019 NHTSA ID NUMBER: 11174885  Components: ELECTRICAL SYSTEM, UNKNOWN OR OTHER  NHTSA ID Number: 11174885  Incident Date February 2, 2019  Consumer Location PRAIRIEVILLE, LA  Vehicle Identification Number 1HGCR2F12HA****  Summary of Complaint  REPAIRED. THE MANUFACTURER WAS NOT NOTIFIED OF THE FAILURE. THE  FAILURE MILEAGE WAS APPROXIMATELY 1,200.  August 18, 2017 NHTSA ID NUMBER: 11016279  Components: ELECTRICAL SYSTEM  NHTSA ID Number: 11016279  Incident Date August 18, 2017  Consumer Location HAWTHORNE, NJ  Vehicle Identification Number 2HKRW2H56HH****  Summary of Complaint  REPAIRED. THE FAILURE MILEAGE WAS 6,000.*DT*JB  September 23, 2020 NHTSA ID NUMBER: 11360689  Components: ELECTRICAL SYSTEM  NHTSA ID Number: 11360689  Incident Date August 17, 2020  Consumer Location WELLINGTON, FL  Vehicle Identification Number 7FARW1H81KE****  Summary of Complaint  THE DEALER. THE MECHANIC WAS UNABLE TO RESTART THE VEHICLE. THE  CONTACT WAS INFORMED THAT SEVERAL WIRING HARNESSES HAD MELTED  AND NEEDED TO BE REPLACED. THE VEHICLE WAS REPAIRED, BUT THE  THE FAILURE. THE FAILURE MILEAGE WAS APPROXIMATELY 700.  October 8, 2018 NHTSA ID NUMBER: 11139129  Components: POWER TRAIN, ELECTRICAL SYSTEM, ELECTRONIC STABILITY  THE BATTERY (WHICH WE ALL KNEW IT WAS NOT) BUT THEY PUT IN A NEW ONE  THEY SAID. ANYHOW AS YOU ALREADY KNOW THIS IS AN ELECTRICAL ISSUE  THAT NEEDS TO BE FIXED A.S.A.P.. DEALER NOW TELLS ME HONDA IS WORKING  UNDETERMINED. THE FAILURE RECURRED. THE VEHICLE WAS TAKEN BACK TO  THE DEALER WHERE IT WAS DIAGNOSED THAT THE BATTERY NEEDED TO BE  REPLACED. THE VEHICLE WAS REPAIRED; HOWEVER, THE FAILURE PERSISTED  VEHICLE. ABOUT 6 MONTHS AGO I STARTED HAVING THE SAME ISSUE WHERE  MY BATTERY WAS DYING. IN ADDITION TO THAT MY.CAR STARTED MAKING A  FUNNY NOISE. TURNS OUT I NEEDED MY TENSIONER/ALTERNATOR PULLEY  VIOLATION OF FLORIDA’S UNFAIR   & DECEPTIVE TRADE PRACTICES ACT  (FLA. STAT. §501.201, ET SEQ.)  232.  Plaintiffs reallege and incorporate by reference paragraphs 1-168 as though fully  set forth herein.  233.  Plaintiffs Andre Cruz, Mitchell Bryon Pazanki, Dayane Tessinari, and Fernanda  Nunes Ferreira (for the purposes of this section, “Plaintiffs”) bring this claim on behalf of  themselves and the Florida Class.  234.  Plaintiffs and the Florida Class members are “consumers” within the meaning of  WAS MADE AWARE OF THE FAILURE. THE CONTACT WAS INFORMED THAT THE  VEHICLE NEEDED TO BE DIAGNOSED TO BE COVERED UNDER THE WARRANTY.  IF NOT, THE CONTACT NEEDED TO PAY OUT OF POCKET FOR THE REPAIR. THE  WAS 2 MONTHS AGO WHEN A NEIGHBOR CALLED TO TELL ME THE WINDOWS  WERE DOWN. THE CAR WAS LOCKED THEN AS WELL, IT WAS ALSO AFTER A  RAINY DAY. IN BOTH OCCURRENCES, THERE WAS NO WATER IN THE VEHICLE OR  WAS IN DECEMBER 2017 IN BAY AREA CA, AND NOW IN PLEASANTON CA WITH  TEMP ABOUT 60 DEGREES OUTSIDER.  April 26, 2019 NHTSA ID NUMBER: 11203916  Components: ELECTRICAL SYSTEM  NHTSA ID Number: 11203916  Incident Date April 25, 2019  Consumer Location Unknown  Vehicle Identification Number 1HGCR2F58GA****  Summary of Complaint  WHAT - NO ALARM - NOTHING. I LOOKED ONLINE AND MANY HAVE THIS ISSUE.  FOR ALL I KNOW MY HONDA BATTERY DIED DAY 2 OR 3 AS MANY ONLINE SAY  THEIRS DIES AFTER SITTING JUST A FEW DAYS.  December 14, 2020 NHTSA ID NUMBER: 11383284  Components: ELECTRICAL SYSTEM  NHTSA ID Number: 11383284  Incident Date December 10, 2020  Consumer Location DECATUR, IL  Vehicle Identification Number 7FARW2H97JE****  Summary of Complaint 