This is a lawsuit brought by two individuals against Tesla Motors, Inc. alleging that the company concealed a safety defect in their Model X vehicles which resulted in a sudden unintended acceleration event. The plaintiffs allege that Tesla failed to properly disclose, explain, fix, or program safeguards to correct the underlying problem of unintended acceleration and that this failure led to the plaintiffs suffering physical injuries and emotional distress. They are seeking damages for medical expenses, pain and suffering, emotional distress, lost wages, and other damages. This is a lawsuit against Tesla alleging breach of express and implied warranties in the sale of a Model X vehicle. The plaintiff claims that the vehicle was defective and that Tesla was aware of the defect but failed to inform the plaintiff. The plaintiff also states that Tesla refused to honor the warranty and repair the vehicle, resulting in the plaintiff overpaying for the vehicle and suffering a diminution in value. The plaintiff is seeking damages, attorney's fees, and a civil penalty. This is a lawsuit brought by Plaintiffs Helen Lin Huang, Pi Lien Lee, and Emily Kao against Defendant Tesla, Inc. for damages sustained as a result of the alleged negligence, violations of the Consumer Legal Remedies Act, violations of the California Unfair Competition Law, breach of express warranties, violation of the Song-Beverly Consumer Warranty Act for breach of express warranties, violation of the Song-Beverly Act for breach of implied warranties, and strict product liability. Plaintiffs are seeking compensatory damages, pre-judgement interest, costs of suit, exemplary and/or punitive damages, and reasonable attorney's fees. Tesla has received 13 claims of SUA events, or approximately 71 per 100,000 vehicles per year (1 per 1,400 vehicles). Plaintiffs allege that Tesla has failed to disclose the defect to consumers, failed to issue a recall or otherwise remedy the defect, failed to respond to numerous complaints about the defect, failed to take any action to remedy the defect or to otherwise protect the public despite having actual knowledge of the defect, failed to disclose the defect to the National Highway Traffic Safety Administration or any other governmental agency despite having actual knowledge of the defect, and failed to disclose the defect to the public or to its customers despite having actual knowledge of the defect. As a result, Plaintiffs have suffered and will continue to suffer damages in an amount to be proven at trial due to negligence, violations of the Consumer Legal Remedies Act, violations of the California Unfair Competition Law, breach of express warranties, violation of the Song-Beverly Consumer Warranty Act for breach of express warranties, violation of the Song-Beverly Act for breach of implied warranties, and strict product liability. Tesla also expressly warranted to Plaintiffs that the subject vehicle and/or its component parts were of merchantable quality and fit for their ordinary purpose, free from defects in materials and workmanship, would conform to Tesla’s specifications and descriptions, and would be of a certain quality and would be fit for their ordinary purpose. As a direct result of the acts and/or omissions of Defendants, Plaintiffs have suffered and will continue to suffer damages, including, but not limited to, economic and non-economic damages, including, but not limited to, medical expenses, pain and suffering, emotional distress, lost wages, and other damages. Plaintiffs are entitled to recover from Defendants the damages they have sustained, including, but not limited to, economic and non-economic damages, including, but not limited to, medical expenses, pain and suffering, emotional distress, lost wages, and other damages, as well as attorney's fees based upon actual time expended and reasonably incurred in connection with the commencement and prosecution of this action.