NHTSA Recalls definition

NHTSA Recalls refer to NHTSA Recall Campaigns 16V815, 18V026, 20V061, 20V088, 20V518, 20V519, 20V520, 20V543, 21V160, 21V161, 21V303, 21V331, 21V137, 22V051, and 22V056. For the avoidance of doubt, any expansion of the above NHTSA Recall Campaigns issued after the Court’s entry of the Preliminary Approval and Class Certification Order shall not be included in this definition or otherwise provided for in this Settlement unless agreed to in writing by the Parties and approved by the Court.