“Lindsay also admitted to the Virginia Motor Vehicle Dealer Board that one of its prices required two conditions that were virtually impossible to satisfy — namely that, to qualify, the consumer had to both already have a vehicle, but also to have never purchased a vehicle before.”

💡 This shows Lindsay deliberately advertised prices no real consumer could obtain, proving intent to deceive rather than accidental error.

“The biggest complaints that I receive come from the ‘Lindsay Love It Price’ that we advertise at some of our dealerships. In short, we never deliver the vehicle anywhere near the stated price. Even my friends have chided me for it.”

💡 Michael Lindsay, the part-owner and president, explicitly acknowledged in writing that they systematically fail to honor advertised prices.

“One manager at Lindsay Ford complained internally about Lindsay’s artificially low advertised prices, admitting, we list everything online with a ridiculous price that is so far out of reality it’s embarrassing.”

💡 Even Lindsay’s own managers recognized the advertised prices were intentionally misleading and embarrassing, yet the practice continued.

“According to Lindsay’s Marketing Manager, statistically the customer is ours to lose at that point.”

💡 This reveals a deliberate strategy to exploit sunk costs after consumers invested time and travel expenses, making them vulnerable to pressure.

“Lindsay managers describe compensation Lindsay receives through this type of financing as a kickback.”

💡 Management’s own terminology reveals they understood they were receiving payments for steering consumers into dealership financing rather than serving customer interests.

“Two weeks after the video was posted, Lindsay’s Chief Marketing Officer (CMO) alerted Defendants Smyth and Smallwood that the video had 7.4 million views and said, This problem is only escalating. The CMO noted that the name Blazer had been tainted in social media and recommended changing the name of the optional product to protection package.”

💡 When faced with widespread public exposure of deceptive practices, management chose to rename the package rather than end the deceptive tactic, showing intent to continue the misconduct.

“Another Lindsay executive forwarded the internal discussion of the video to Defendant Michael Lindsay with the comment, Same stuff as always.”

💡 This shows senior leadership recognized the Blazer Package complaint as part of an ongoing pattern of misconduct, not an isolated incident.

“Defendant Michael Lindsay received a complaint in May 2021 that Lindsay CDJR had added thousands of dollars in fees to the advertised price. He did not direct the dealerships to start advertising prices accurately, or to stop adding thousands to the price. Instead, he simply forwarded the complaint to Defendant Smallwood, writing I know we keep talking about this but I don’t like the way we’re doing business at some of our dealerships. These complaints are too frequent. We need to come up with a better way to present the price. Do you agree? Defendant Smallwood responded, Let me look.”

💡 Despite acknowledging the problem and the frequency of complaints, ownership took no meaningful action to stop the deceptive practices.

“At Lindsay CDJR, a manager informed another consumer that the price on the website was not realistic and that no one would qualify for it because it was nearly impossible to qualify for all the rebates to get to that price. Another manager told her the real price was over $4,000 more than advertised.”

💡 Managers explicitly admitted to consumers that advertised prices were fake and unattainable, demonstrating knowing deception.

“Lindsay’s salesperson even told the consumer he was naïve to expect to pay the advertised price.”

💡 This shows dealership staff openly mocked the idea that advertised prices should be honored, revealing a culture where deception was normalized.

“According to a survey of Lindsay’s customers who were charged for add-ons, 68% were charged for at least one add-on they did not agree to buy or were falsely told was required.”

💡 This quantifies the systematic nature of unauthorized charges, showing the practice affected the overwhelming majority of customers.

“For example, a random sample of Lindsay’s transactions from April 2020 through March 2023 shows that, of the vehicles Lindsay advertised and priced on third-party sites CarGurus.com and Cars.com, over 88% of consumers paid more than the advertised price. And of those consumers, most paid over $2,000 more.”

💡 This data proves deceptive pricing was not occasional but the standard practice affecting nearly nine out of ten customers.

“According to a survey of consumers who purchased a vehicle from Lindsay, over 38% were told financing through the dealership was required to purchase a vehicle or obtain the advertised price. Nearly all of these consumers ultimately financed through Lindsay, even if they initially brought their own financing.”

💡 More than one in three customers were subjected to false financing requirements, demonstrating how widespread this deceptive tactic was.

“One dealer sent a consumer to Lindsay CDJR to complete a purchase, only to have a Lindsay salesperson quote a retail price that was, according to the dealer, a complete fiction, and add a warranty and service contract the consumer did not want or need. The dealer complained to Defendant Paul Smyth that Lindsay’s conduct was why consumers are increasingly dissatisfied with the dealership experience.”

💡 Even other auto dealers recognized Lindsay’s pricing as fraudulent, showing the practices were so extreme they damaged the industry’s reputation.

“Under TRANSP. § 15-313(a), a dealer or an agent or employee of a dealer may not use any advertisement that is in any way false, deceptive, or misleading. The Transportation Article makes clear that it is false, deceptive, and misleading for a dealer to advertise the purchase price of a vehicle when that advertised price is not the full delivered purchase price of the vehicle, excluding only taxes, title fees, and any freight or dealer processing charge.”

💡 Maryland law explicitly requires advertised prices to include all fees except taxes and title, making Lindsay’s practices clear legal violations.