Frequently Asked Questions

1. What’s the Notice about?

PLEASE BE ADVISED THAT, if you purchased or leased a new Harley-Davidson motorcycle from Quaid Harley-Davidson, Inc. from March 4, 2015 to September 16, 2021, and were charged a pre-delivery inspection and set up fee or “DLR PREP” fee, you could be entitled to benefits under a class action settlement.

The California Superior Court for the County of San Bernardino has authorized this Notice in a pending lawsuit entitled Hill v. Quaid Harley-Davidson, Inc. et al., Case No. CIV DS1826573 (hereafter, the “Action”). You should have already received a notice about the Action in 2021.

The Action is between Plaintiff Lisa Hill, individually on behalf of herself, the class, all others similarly situated, and on behalf of the general public ("Plaintiff”), and Defendant Quaid Harley-Davidson, Inc. (“QHD”). The purpose of this Notice is to provide a summary of the claims asserted in the Action and the terms of a proposed Class Settlement Agreement. In the Action Plaintiff alleges that QHD improperly charged consumers a pre-delivery inspection and set up fee, often called “DLR PREP,” which – Plaintiff claims – was unlawful, misleading, and/or fraudulent because QHD was compensated by the manufacturer (Harley-Davidson Motor Company, Inc.) to perform all necessary and appropriate pre-delivery inspection and/or preparation work for new Harley-Davidson motorcycles. Plaintiff also alleges that QHD did not comply with various applicable California statutes and regulations applicable to disclosures of dealer preparation charges and advertising new motorcycles for sale, amounting to unfair business practices and false advertising. QHD strongly denies any wrongdoing, contends the Action is without merit, and claims it complied with all applicable laws. The Court has made no determination about whether Plaintiff or QHD is correct on the merits.

On June 1, 2021, the Court certified the Action as a class action consisting of all consumers who purchased or leased a new Harley-Davidson motorcycle from QHD from March 4, 2015 to September 16, 2021, and were charged a pre-delivery inspection and set up fee or “DLR PREP” fee.

Plaintiff and QHD have concluded it is in their best interests to settle the Action between them to avoid the expense and uncertainty of ongoing litigation. The Court did not decide which side was right, but both sides agreed to the Settlement. On or about November 27, 2024, the Court granted preliminary approval of a proposed settlement (the “Class Settlement Agreement”) between Plaintiff on behalf of the Class Members and QHD, inclusive of QHD’s present or former owners, officers, directors, employees, heirs, agents, insurers and assigns) (“Related Entities”). If approved by the Court, the Class Settlement Agreement will resolve all of the claims by Plaintiff against QHD in the Action.

The Court determined that there is sufficient evidence to suggest that the proposed Class Settlement Agreement might be fair, adequate, and reasonable, and scheduled a Final Approval Hearing to make a final determination of those issues. If you wish to be included in the proposed Class Settlement, you do not have to do anything to indicate your consent. If you wish to be excluded from the Class Settlement, to appear at the Final Approval Hearing or to object to the proposed Class Settlement, follow the instructions in this Notice.

2. Who is in the Settlement Class?

The Settlement Class includes all consumers who: (1) purchased or leased a new motorcycle from QHD and were charged a pre-delivery inspection and set up fee or ‘DLR PREP’ fee between March 4, 2015 and September 16, 2021, and (2) who were previously sent notice of this class action litigation and did not timely opt out of the class.

3. Information about the lawyers representing you.

The Class is represented by Ross H. Hyslop, Esq., of Pestotnik LLP, 501 West Broadway, Suite 1025, San Diego, CA 92101, who is referred to as Class Counsel. As a Class Member, you are represented by Class Counsel. You will not be charged for the services provided by this lawyer. If you want to be represented by your own lawyer, you may hire one at your own expense.

4. What benefits does the proposed Class Settlement provide?

The Court has only preliminarily approved the Class Settlement terms. If the Court grants Final Approval of the Class Settlement Agreement and enters a Final Approval Order and Judgment which becomes final, the terms of the Class Settlement Agreement will be the binding terms of the Class Settlement. All the terms are in the Class Settlement Agreement that is on file with the Court, and can also be found here, where you may review it.

The important terms of the proposed Class Settlement are:

1. Payment Funding & Timing: As specified in the proposed Class Settlement Agreement, QHD will deposit settlement funds of $800,000 into a Qualified Settlement Fund (“QSF”) account controlled by Simpluris, Inc., the court-approved Settlement Administrator, no later than ten (10) days after the Court enters a Final Approval Order and Judgment which has become final. The $800,000 is allocated as $495,000.00 to Class Counsel’s Attorneys’ Fees And Costs, $275,000.00 to Class Member Cash Payments, $5,000.00 to Class Representative Service Fee and $25,000 to Settlement Administration fees. Only after the Final Approval Order and Judgment become final will any payment be required or made, including QHD Vouchers, Individual Settlement Cash Payments to Settlement Class Members who submit a timely and valid Claim, to Class Representative Lisa Hill, to Class Counsel, or the Settlement Administrator.


2. Class Member QHD Voucher: As specified in the proposed Class Settlement Agreement, QHD will provide a Voucher (“QHD Voucher”) in the amount of $267.69, which will be automatically mailed to each Class Member and which will be valid for 180 calendar days from the date of mailing. The Class Member may redeem the QHD Voucher at the QHD Dealership toward the Class Member’s purchase of a Harley-Davidson motorcycle, service, or parts, subject to its terms.


3. Class Member Cash Payment Claims: As specified in the proposed Class Settlement Agreement, each Class Member who timely submits a valid form with all required information, and which is approved by the Settlement Administrator (“Claim”), may receive an Individual Settlement Cash Payment via check from QSF funds. The Settlement Administrator will calculate the amount of the payment based on the amount of DLR PREP charged to each individual Class Member, which will be divided by the total DLR PREP charges for all the Class Members, and multiplied by the Class Member Cash Payments fund amount of $275,000.00. Individual Settlement Cash Payment for valid Claims are estimated to be between $77.50 to $445.25 per Class Member depending on the amount of DLR PREP charged.


4. Class Representative Service Fee for Lisa Hill: As specified in the proposed Class Settlement Agreement, a Class Representative Service Fee of $5,000 will be paid by QHD from the QSF to Plaintiff, for filing the Action, working with Class Counsel, and representing the Class in the Action.


5. Class Counsel Attorneys’ Fees: As specified in the proposed Class Settlement Agreement, Class Counsel will ask the Court to award them attorneys’ fees and costs of $495,000.00 from the QSF, which includes all litigation fees, costs, expenses, inclusive of appeal, and mediation/mediator fees incurred by counsel on behalf of the Certified Class, and any interest thereon.


6. Settlement Administration Fees: As specified in the proposed Class Settlement Agreement, QHD has agreed to pay Simpluris for the costs of its settlement administration services, and allocated $25,000 from the QSF for that purpose. If Simpluris’ costs exceed $25,000, QHD will add funds to the QSF sufficient to pay Simpluris.


7. Injunctive Relief: As specified in the proposed Class Settlement Agreement, QHD has agreed to an injunction, which is a Court order that requires QHD to do or not do specific acts, including:


• QHD will not advertise new, assembled motorcycles at its dealership and/or on its website without itemizing and disclosing to consumers all costs/fees associated with buying the advertised motor vehicle, as required by California law.


• QHD will not charge consumers extra fees and charges for assembly, delivery, preparation, inspection, or equivalent work specified by the manufacturer Harley-Davidson Motor Company (collectively “PDI”) on new motorcycles, where the manufacturer compensates QHD for all costs of performing such work, or where such work is included in the manufacturer’s suggested retail price (“MSRP”), and QHD has performed no additional work over and above that specified by the manufacturer as part of QHD’s PDI obligations.


• QHD will attach a California DMV-approved, VIN-specific price hang tag furnished by the manufacturer (“Hang Tags”) to each new motorcycle QHD currently has displayed on the sales floor.


• QHD will use supplemental price hang tags (in addition to the Hang Tag) when QHD’s asking price exceeds the manufacturer’s suggested retail price, and describe the difference only as “added mark-up.”


• QHD will clearly and conspicuously post in its showroom in a place that is easily accessible to prospective purchasers, a list of each new motor vehicle that QHD currently has advertised for sale, (satisfied by displaying each new motor vehicle on the sales floor with a Hang Tag and/or supplemental price hang tag).


• QHD will not state or infer to its consumers that PDI charges are not included in QHD’s retail prices where the manufacturer compensates QHD to perform all necessary and appropriate PDI and/or includes PDI as part of the MSRP price.


• QHD will not modify, delete, or increase the MSRP for the motorcycle on Hang Tags.


• QHD will not modify, delete, or increase the MSRP for manufacturer-installed options and/or accessories on Hang Tags.


• QHD will not advertise a motor vehicle as having special equipment or accessories unless such equipment or accessories are installed and operative at the time of the advertisement.


• QHD will not charge consumers freight charges more than those freight charges QHD pays to the manufacturer.


• QHD will comply with other applicable California statutes and regulations, including existing laws applicable to motorcycle dealers, as specified in the Settlement Agreement.


• QHD shall train its management and sales staff on California law related to false advertising, pricing rules/compliance, and advertised price rules, as specified in the proposed Settlement Agreement.


8. Release of Class Claims: As specified in the proposed Class Settlement Agreement, all Class Members who have not timely and properly requested to be excluded from the Class Settlement Agreement will be legally prohibited from asserting any of the claims released by the Class Settlement against QHD. You cannot sue, continue to sue, or be part of any other lawsuit or other legal action against QHD or its Related Entities for any damages based on facts as alleged in the Action and resolved by the Settlement.

5. Release of all Claims.

If the Court grants final approval to the proposed Class Settlement at the Final Approval Hearing, it will enter a judgment, which will apply to all Class Members who have not timely and properly requested to be excluded from the Class Settlement Agreement. Those Class Members who have not timely and properly requested to be excluded from the Class Settlement Agreement will be legally prohibited from asserting any of the claims released by the Class Settlement against QHD. You cannot sue, continue to sue, or be part of any other lawsuit or other legal action against QHD or its Related Entities for any damages based on facts as alleged in the Action and resolved by this Settlement.

1. The Class Members will be bound by the following release:
   By the Judgment and this Agreement, and except as to the obligations created herein, and effective as of the date of completion of mailing by the Settlement Administrator of Cash Payment checks to the Claims Made Class Members, Plaintiff and the Class do hereby release and forever discharge QHD and its Related Entities (collectively the “Released Parties”) of and from any and all Released Claims, including unknown claims, which the Class had or now has against the Released Parties or any of them, so that Plaintiff and the Class shall have no claim of any kind or nature whatsoever on or against the Released Parties, or any of them solely relating to or arising from those facts alleged in Plaintiff’s Second Amended Complaint (“SAC”).


2. “Released Claims” means any and all claims of any kind or nature whatsoever against the Released Parties, or any of them, solely relating to or arising from those facts alleged in Plaintiff’s Second Amended Complaint asserted in the Action by the Class, including but not limited to all other claims, demands, actions, and causes of action of any nature whatsoever arising from the facts alleged in the SAC, such as any claim for violations of federal, state, or other law (whether in contract, tort, or otherwise, including statutory and injunctive relief, common law, property, warranty and equitable claims), and also including any claims arising from the facts alleged in the SAC that could have been or could be asserted by the Class Members against the Released Parties in the Action, or in any other complaint, action, or litigation in any other court or forum, including but not limited to claims based upon alleged unfair competition, false advertising, unfair business practices, violations of the Consumer Legal Remedies Act, or violations of any federal, state, local, statutory, or common law, including both known and unknown claims, that could have been or could be asserted against QHD or a Released Party in any forum by any Class Member or any of them, or their heirs, successors, or assigns or any of them.

As to the foregoing release of Released Claims only, the release includes a knowing and voluntary waiver of the provisions of Cal. Civil Code § 1542, which provides:

NOTWITHSTANDING THE FOREGOING REFERENCE TO CIVIL CODE § 1542, THE CLASS IS NOT PROVIDING A “GENERAL RELEASE” TO THE RELEASED PARTIES.

Rather, the scope of the release for the Class Members shall be limited to facts alleged in Plaintiff’s SAC against QHD. Further, the release shall not operate to release any manufacturer from potential or alleged liability on any legal or factual theory, including any Harley-Davidson entity (HDI, HDMCI, HDMCOI, etc.).

6. What are my options?

1. Remain in the Class and Do Nothing: If you do nothing, you are automatically part of the Class Settlement. You will remain in the Class and be bound by the Class Settlement and the release of claims described in this Notice and the Class Settlement Agreement. You will receive a QHD Voucher, and may submit a Claim which if approved will entitle you to receive an Individual Settlement Cash Payment.


2. File a Claim: You may submit a claim, which if approved will entitle you to receive an Individual Settlement Cash payment in addition to a QHD Vocher.


3. Remain in the Class and Appear at The Final Approval Hearing: If you remain in the Class, you may appear at the Final Approval Hearing to speak to the Court about the Class Settlement. You are not required to do this.


4. Remain in the Class and Object to The Settlement: If you remain in the Class, you may object to the Settlement.


• To object, you must prepare a written objection and send it to the to the Class Administrator:



Quaid Harley-Davidson Class Settlement
c/o: Settlement Administrator
PO Box 25226
Santa Ana, CA 92799



• Any objection must be postmarked by March 2, 2025. The written objection must include the Case No., CIVDS1826573, your name, address, and phone number. You must also provide an explanation for the objection. You must personally sign and date the objection. If you are represented by legal counsel, the objection must also be signed by your counsel.


• If you fail to make a timely objection that complies with these requirements, you will be deemed to have waived any objections and will be prohibited from making any objections (whether by appeal or any other process) to the Class Settlement and/or Class Settlement Agreement.


• If the Court ultimately approves of the Class Settlement, you will be bound by the final judgment even if you submitted a timely objection. If the Court ultimately approves of the Class Settlement, you will (unless you submitted a valid and timely Request For Exclusion) also be prevented from pursuing any individual claims against QHD based on the facts alleged in the Action.


5. Exclude Yourself From The Settlement: If you want to be excluded from the Settlement Class and not be bound by the Class Settlement and the release, you may make a Request for Exclusion by sending a signed letter with the Case No. CIVDS1826573, your name, present mailing address, telephone number, and a simple statement requesting to be excluded from the Settlement to the Settlement Administrator:



Quaid Harley-Davidson Class Settlement
c/o: Settlement Administrator
PO Box 25226
Santa Ana, CA 92799



• The Request for Exclusion must be made online or postmarked by March 2, 2025.


• If a timely and complete Request for Exclusion is received, and the Court grants Final Approval to the Settlement at the Final Approval Hearing, you will not be bound by the Settlement Agreement and the Final Approval Order and Judgment entered in the Action. You will not receive a QHD Voucher or be eligible to make a Claim for an individual cash payment, but you will preserve the right to personally pursue claims against QHD and the Released Parties based upon the facts alleged in Plaintiff’s Second Amended Complaint in the Action.

7. Final Approval Hearing

The Court will hold a hearing to decide whether to finally approve the Class Settlement on April 28, 2025, at 8:30 a.m. before the Honorable Wilfred J. Schneider, Jr. in Department S32 of the Superior Court of California, County of San Bernardino, San Bernardino District – Civil Division, 247 West Third Street, San Bernardino, California 92415.

The Court will conduct an inquiry into the fairness of the proposed Class Settlement and determine whether to approve Class Counsel’s request for attorneys’ fees and costs and a Class Representative Service Fee for Lisa Hill. It is possible that the date and/or time of the hearing could be changed. If you plan to attend because you have filed an objection, please confirm the date and time by visiting the Important Dates page where any changes will be posted. If the Court grants Final Approval of the Class Settlement, the Final Approval Order and Judgment will be posted on the Important Documents page.

8. Appeal After Final Approval Hearing

The Court will issue an order after the Final Approval Hearing. The order may deny or approve the Settlement. Even if the Court order approves the Settlement, there may be appeals challenging the Court’s order. The appeal process can take time, perhaps more than a year. You will not receive your cash payment or Voucher until any appeals are resolved.

9. Denial of Final Approval

It is possible the Court will decline to grant final approval of the Settlement or decline entry of Judgment. If the Court denies final approval, the proposed Settlement Agreement will have no effect. It is also possible the Court will enter a judgment that is reversed on appeal. Plaintiff and QHD have agreed that, while they expect to work to obtain Final Approval, in such case, the Settlement will have no effect: Namely, QHD will not pay any money and Class Members will not release any claims against QHD, and the Action between QHD and Plaintiff on behalf of the Class will resume.

10. Additional Information

This website’s and the Notice’s description of the Action is general in nature. To see the complete file, you may visit the office of the Clerk of the Superior Court of California, County of San Bernardino, San Bernardino District – Civil Division, 247 West Third Street, San Bernardino, California 92415-0210. The Clerk will make the Court’s file for the Action available for inspection at no cost to you. If you want to make copies of any documents in the file, you may do so at your own expense. You may also review the Court file online and obtain a copy of the Settlement Agreement from the Court website at https://cap.sb-court.org/. There are court costs to view/download/print document images from the Court website.

The Class Settlement Agreement, as well as other legal papers related to the Class Settlement and the Court’s consideration of it, can also be viewed here.

You may contact Class Counsel if you wish to obtain further information. Class Counsel can be reached at:

Ross H. Hyslop
Pestotnik LLP
501 West Broadway, Suite 1025
San Diego, CA 92101
(619) 237-3000

PLEASE DO NOT CALL OR WRITE THE COURT or QHD WITH QUESTIONS ABOUT THE ACTION, THE CLASS SETTLEMENT, OR THE CLASS CLAIM PROCESS.