The within proposed auto defect liability multi-jurisdictional class proceeding which involves allegations that certain Ford vehicles, engineered, designed, manufactured, assembled, tested, marketed, distributed, supplied, leased and/or sold by the Defendants, Ford Motor Company and Ford Motor Company of Canada, in Canada, including the Province of British Columbia, equipped with either the 10R60 or 10R80 transmissions (collectively, the “Transmission”) that contain one or more design and/or manufacturing defects. In particular, the defects in the Transmissions are caused by: (1) axial movement of the triple-clutch assembly within the cylinder sleeve; (2) internal oil cross-leakages, sticking of the valves, and solenoid failures in the valve body; (3) issues with the adaptive transmission shift learning strategy employed by the transmission control module; and/or (4) miscalibration of the solenoid identification strategy (the “Transmission Defect”). The Transmission Defect results in harsh or delayed engagement and/or harsh or delayed shifting of the Transmission gears which causes the Affected Class Vehicles to shudder, jerk, lunge, clunk and hesitate between gears, which severely affect the driver’s ability to control the speed, acceleration and deceleration of the vehicle, and all of which poses a real, substantial and imminent risk of harm, injury and/or death to vehicle occupants.