Misleading Odometer System:

Tesla’s odometer system uses predictive algorithms, energy consumption metrics, and driver behavior multipliers, rather than direct distance measurements, resulting in inflated mileage readings (Complaint ¶¶ 3-4, 62-65).

These readings deviate from traditional odometers, over-registering mileage by 15% to 117% compared to industry standards (¶ 71).

Tesla intentionally designed, manufactured, or tolerated this system to manipulate mileage, violating California Vehicle Code § 28050 (¶¶ 69-73, 133-136).