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Responding to Manufacturer Defenses

Counter-arguments when manufacturers deny your California lemon law claim

Manufacturers Deny Claims Routinely - Don't Give Up

Car manufacturers and their attorneys use standard defenses to deny lemon law claims. Understanding these defenses and knowing how to counter them can help you get the buyback or replacement you deserve. California's Song-Beverly Act provides strong consumer protections.

1
"Not Enough Repair Attempts"

Manufacturer's Defense

The manufacturer claims you haven't given them enough chances to repair the vehicle.

Your Response

  • The presumption is just a shortcut - claims exist without it
  • Count all related repairs, not just identical complaints
  • "Same defect" includes symptoms of the same underlying problem
  • Dealer diagnosis doesn't have to match - your complaint counts
  • If they couldn't find the problem, that still counts as a failed attempt
What to Say

"I have presented the vehicle for repair [X] times for this defect. Each visit where the problem was reported counts as a repair attempt, regardless of whether the dealer 'found' the problem. The defect persists. Under a reasonable number of attempts standard, you have failed to repair my vehicle."

2
"We Couldn't Duplicate the Problem"

Manufacturer's Defense

The manufacturer claims the dealer couldn't reproduce the defect, so there's nothing to fix.

Your Response

  • "Could not duplicate" doesn't mean the problem doesn't exist
  • Many defects are intermittent - that's still a substantial defect
  • Document when it happens - video, photos, witnesses
  • Dealer's inability to find it may show incompetence, not absence
  • Ask for test drive with you present to demonstrate
What to Say

"The inability of your technicians to duplicate an intermittent problem does not negate its existence. I have documented [dates/circumstances] when this occurs. An intermittent safety defect is still a defect that substantially impairs safety. I am prepared to provide video evidence/witness testimony."

3
"Owner Abuse or Misuse"

Manufacturer's Defense

The manufacturer claims you caused the problem through abuse, neglect, or unauthorized modifications.

Your Response

  • They must PROVE abuse - speculation isn't enough
  • Normal driving, even vigorous, is not abuse
  • Following owner's manual = not abuse
  • Minor cosmetic modifications don't void drivetrain warranty
  • Magnuson-Moss Act: Must show modification CAUSED problem
What to Say

"I have used this vehicle in accordance with the owner's manual for normal, intended purposes. You have provided no evidence of abuse or misuse - only speculation. Under Civil Code § 1794.3, you bear the burden of proving any affirmative defense. Please provide specific evidence of how my use caused this defect."

4
"The Warranty Has Expired"

Manufacturer's Defense

The manufacturer claims the warranty period has ended, so they have no further obligation.

Your Response

  • Defect must have first appeared during warranty - it did
  • Your repair attempts were during the warranty period
  • They can't escape by dragging out repairs until warranty expires
  • Review repair orders for dates - they prove when defect appeared
  • Powertrain warranty may be longer than bumper-to-bumper
What to Say

"The defect first manifested and was reported on [date], well within the warranty period. My repair orders from [dates] document warranty repairs for this issue. The manufacturer's failure to repair during the warranty period does not extinguish my statutory rights."

5
"This Isn't a Substantial Defect"

Manufacturer's Defense

The manufacturer claims the problem is minor and doesn't substantially impair the vehicle's use, value, or safety.

Your Response

  • You paid for a fully-functioning vehicle - not a partially-working one
  • Any safety-related defect is inherently substantial
  • Reduced resale value = impaired value
  • Inability to rely on the vehicle = impaired use
  • Repeated inconvenience counts (days at dealer, rental cars)
What to Say

"This defect substantially impairs my vehicle's [use/value/safety]. I cannot rely on this vehicle for [commuting/family transportation/work] because [explain impact]. Any defect affecting [brakes/steering/engine/safety system] is inherently substantial. A reasonable consumer would consider this a serious problem."

6
"Used Vehicles Aren't Covered"

Manufacturer's Defense

The manufacturer claims the lemon law only applies to new vehicles.

Your Response

  • CPO vehicles are covered - manufacturer warranty applies
  • Any dealer warranty triggers Song-Beverly protection
  • "As-is" sales are the exception, not the rule
  • Check your purchase documents for warranty terms
  • Even implied warranty may create coverage
What to Say

"My vehicle was sold with [manufacturer CPO warranty/dealer warranty] as documented in my purchase agreement. Under Civil Code § 1795.5, used motor vehicles sold with an express warranty are covered by the Song-Beverly Act. The warranty terms are attached."

7
"You Must Go Through Our Arbitration Program"

Manufacturer's Defense

The manufacturer insists you must use their internal arbitration program (like NCDS, BBB Auto Line) before suing.

Your Response

  • Manufacturer arbitration is NOT required
  • You can file suit without exhausting arbitration
  • BBB/NCDS decisions are binding on manufacturer, not you
  • California BAR arbitration is different (state-run)
  • Be aware of any binding arbitration clause in purchase contract
What to Say

"Participation in your arbitration program is optional under Civil Code § 1793.22(d). I am not required to exhaust this remedy before pursuing my statutory rights. I decline arbitration and will pursue my claim directly."

Check Your Contract

Some purchase contracts have binding arbitration clauses separate from manufacturer programs. Review your paperwork or consult an attorney.

8
"We'll Deduct Too Much for Mileage"

Manufacturer's Defense

The manufacturer agrees to a buyback but calculates an excessive mileage offset, drastically reducing your refund.

Your Response

  • Only miles BEFORE first repair attempt count
  • Formula uses 120,000 as denominator - not less
  • Verify their calculation against the statutory formula
  • Don't accept arbitrarily high offsets
  • Get exact mileage from first repair order
What to Say

"The mileage offset must be calculated per Civil Code § 1793.2(d)(2)(C). My first repair attempt was at [X] miles. The correct offset is: [X] ÷ 120,000 × purchase price = $[amount]. Your calculation of $[their amount] is incorrect/excessive."

9
"We Finally Fixed It"

Manufacturer's Defense

After multiple failures, the manufacturer claims they've finally repaired the defect and no buyback is required.

Your Response

  • Your rights vested when they failed to repair within reasonable attempts
  • Late repair doesn't undo prior failure
  • You've lost confidence in the vehicle's reliability
  • Vehicle's value is diminished regardless (lemon stigma)
  • If it fails again, their "fix" didn't work anyway
What to Say

"My lemon law rights accrued when you failed to repair the defect after [X] attempts. A repair now, after I've demanded a buyback, does not cure your prior violation. The vehicle's value remains diminished due to its repair history, and I have reasonably lost confidence in its reliability."

10
"Take This (Low) Settlement Offer"

Manufacturer's Defense

The manufacturer offers a cash settlement, extended warranty, or partial buyback far below what you're entitled to.

Your Response

  • Calculate your actual entitlement before considering offers
  • Don't accept extended warranty in lieu of buyback
  • Cash settlements often undervalue your claim
  • Consult a lemon law attorney - they can get you more
  • Remember: manufacturer pays attorney fees if you win
What to Say

"Your offer of $[amount] is inadequate. Under Civil Code § 1793.2(d), I am entitled to a full refund of $[purchase price] plus [collateral charges, incidentals], minus only the statutory mileage offset of $[amount]. Your offer represents approximately [X%] of my legal entitlement. I decline and will pursue my full statutory rights."

Attorney Consultation

Most lemon law attorneys work on contingency. Since manufacturers pay attorney fees when you win, there's often no cost to you. Get professional advice before accepting any offer.

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