“For example, on December 10, 2008, VW issued a Technical Service Bulletin (‘TSB’) No. 17-08-03 applicable to 2000-2010 model year vehicles (with the exception of the Routan). VW acknowledged customer complaints of high oil consumption that may exceed VW’s oil consumption standard.”

💡 This proves VW had knowledge of excessive oil consumption problems in its engines for over 17 years before selling the defective 2022-2023 Tiguans.

“However, despite its knowledge of the Defect as evidence by this TSB, under the ‘Product Solution’ section VW offers no solution, stating instead ‘Not applicable.'”

💡 VW acknowledged the oil consumption problem in internal documents but deliberately provided no repair instructions to dealers, leaving owners without recourse.

“In response, Stone Mountain Volkswagen told Ms. Martinez it was ‘normal’ for her vehicle’s engine to consume oil, and added oil to the Martinez Vehicle engine.”

💡 VW and its dealers actively misled consumers by characterizing excessive oil consumption as normal, preventing owners from understanding the severity of the defect.

“Subsequently, Ms. Martinez returned her vehicle to Stone Mountain Volkswagen four more times, with an interval of about 2,000 miles, complained about the same low engine oil level warning. During each such visit, Stone Mountain Volkswagen topped up engine oil level and continued to reassure Ms. Martinez that such consumption of engine oil was ‘normal.'”

💡 This demonstrates the repetitive nature of the defect and how VW avoided providing actual repairs despite numerous warranty claims.

“Therefore, this Oil Consumption Defect is unreasonably dangerous because it can cause engine failure while the Class Vehicles are in operation at any time and under any driving conditions or speeds, thereby exposing the Class Vehicle drivers, their passengers, and others who share the road with them to serious risk of accidents and injury.”

💡 The defect creates immediate safety risks by causing sudden engine failure that could lead to accidents, distinguishing this from a mere inconvenience.

“Despite having pre-sale knowledge of the Defect, VW failed to disclose it to Plaintiff and other class members at the time of purchase or lease. Had it done so, Plaintiff and class members would not have purchased the Class Vehicles or would have paid substantially less for them.”

💡 VW knowingly hid material information that would have affected consumer purchasing decisions, allowing the company to sell vehicles at higher prices.

“Specifically, as a result of defective piston rings in the EA888 engine, oil passes into the cylinder combustion chamber where it burns off.”

💡 The complaint identifies the specific mechanical cause of the defect, showing this is a design flaw rather than a maintenance issue.

“Burning oil produces blue-gray smoke in the exhaust and releases harmful pollutants, such as partially burned or unburned fuel, and small particles resulting from the burning of oil.”

💡 The defect creates environmental harm beyond just consumer economic damage, affecting air quality and public health.

“Similarly, on September 18, 2024, VW updated its TSB No. 17-18-06, where it expanded bulletin application from 2000 to 2025 model year vehicles (with the exception of the Routan and ID.4).”

💡 VW repeatedly acknowledged the problem affects more and more vehicle models over 25 years but never implemented an actual solution.

“BOUGHT CAR ON 4/6/ 2020 BRAND NEW AT 2600 MILES OIL LITE CAME ON I CHECKED AND IT NEEDED 1 QUART.I WENT TO DEALER THEY CHECKED IT AND ADDED 1 QUART AND TOLD ME TO COME BACK WHEN IT HAPPENS AGAIN.”

💡 NHTSA complaints show VW’s systematic approach of downplaying the defect and avoiding comprehensive repairs across its dealer network.

“The SERVICE GUY CHECKING ME IN TOLD ME ‘VW CONSIDERS IT ACCEPTABLE FOR THEIR CARS TO BURN THROUGH A QUART OF OIL EVERY 1,000 MILES.’ YOU HAVE TO BE KIDDING ME. THIS CAR DOESN’T EVEN HAVE 16,000 MILES ON IT YET.”

💡 VW established an official corporate position that extreme oil consumption is acceptable, allowing them to deny warranty claims systematically.

“WE HAVE SAME ISSUE WITH OUR 2018 TIGUAN AS MANY OTHER PEOPLE OUT THERE. AFTER OUR FIRST OIL CHANGE WE HAD ENGINE OIL LIGHT CAME ON… I OWNED MANY VW INCLUDING 2019 JETTA WE BOUGHT FOR MY SON AND NEVER HAD ANY ISSUES WITH BURNING OIL.”

💡 The widespread and consistent pattern of complaints across different owners and model years proves this is a systematic defect, not isolated incidents.

“VW Dealership in West Lebanon NH is acknowledging that there is an issue with VW Tiguan engines burning oil at a higher rate than the standard… They stated they are seeing a lot more folks like myself coming in with lower mile Tiguan with this issue.”

💡 Even VW’s own dealerships privately acknowledge the widespread nature of the defect, contradicting the company’s public stance.

“My vehicle low oil light cane on and I had just had the oil changed less than 2,000 miles. Took it to local dealership, they stated 2 seals needed to be replaced, they replaced them and stated I should be good but check the oil every so often to make sure. 500 miles goes by I need at least 1 qt of oil, took it back to dealership now they say I need a whole new Head and it is a common problem.”

💡 The defect causes serious engine damage requiring expensive repairs like cylinder head replacement, not just inconvenient oil top-offs.

“To date, VW has failed to correct the safety defect under VW’s warranty, requiring that Class Vehicle owners continue to operate their vehicles with the safety defect. Indeed, VW has not issued any adequate repairs to its dealers, has not issued a safety recall, and at most VW dealers top up engine oil level whenever consumers present their vehicles seeking warranty repairs.”

💡 VW systematically violated its warranty obligations by refusing to provide actual repairs for a known defect, leaving owners with dangerous vehicles.