2026 Toyota Corolla

#### The ABS Defect 12. Within seven (7) days of purchase, and with fewer than [NUMBER] miles driven, the subject vehicle experienced a catastrophic failure of the ABS pump containing the Electronic Control Unit (ECU) [citation:1 from previous analysis]. 13. This failure caused the ABS warning light to illuminate and completely disabled the ABS functionality, reducing the braking system to non-power-assisted, pre-ABS technology. 14. The failure occurred with no warning and despite the vehicle being operated under normal driving conditions. 15. Upon information and belief, the ABS pump/ECU unit contained manufacturing and/or design defects that existed at the time the vehicle left Defendants' control. #### The Airbag System Defect 16. On or about [DATE OF CRASH], Plaintiffs were involved in a motor vehicle collision while operating the subject 2026 Toyota Corolla. 17. Upon information and belief, the crash forces were of sufficient magnitude that the vehicle's Airbag Control Unit (ACU) should have deployed the front airbags. 18. The airbags failed to deploy, causing Plaintiffs to sustain enhanced injuries that would have been prevented or mitigated had the airbags functioned properly. 19. Upon information and belief, the Airbag Control Unit in the subject vehicle is of the same type or design as those implicated in prior class action litigation against Toyota involving defective ACUs manufactured by ZF-TRW Automotive . 20. Defendants have previously settled claims regarding ACUs that were vulnerable to "electrical overstress," which could disable the airbag system entirely during a crash, for $78.5 million . 21. Defendants failed to warn Plaintiffs that the 2026 Toyota Corolla might contain an ACU with these same vulnerabilities.

The contact owns a 2026 Toyota Corolla. The contact stated while driving at an undisclosed speed and attempting to avoid striking a deer the vehicle crashed into a tree. The air bags did not deploy. The contact stated that the SOS system detected the impact to the vehicle and alerted First Responders. The vehicle was towed to the local tow yard and later towed to a Collision Center. The contact stated that the vehicle had not been accessed by the adjuster. The contact stated that there were damages to the front of the vehicle, the windshield was shattered, and damages to the hood of the vehicle and the front passenger's door failed to open. No Police report was filed because the crash occurred on private property. The contact later sustained chest pains, however no medical attention was received. In addition, the contact stated that the chest pain was continuous. The contact was advised by the insurance company to contact the NHTSA Hotline to report the failure. The manufacturer was made aware of the failure. The contact was informed that the vehicle event data recorder (EDR) was retrieved; however, the contact was not provided any additional information regarding the data. The failure mileage was approximately 883.