Case 2:12-md-02311-SFC-RSW ECF No. 2137-5, PageID.39224 Filed 05/07/21 Page 1 of 18
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`EXHIBIT 2
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`EXHIBIT 2
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`Case 2:12-md-02311-SFC-RSW ECF No. 2137-5, PageID.39225 Filed 05/07/21 Page 2 of 18
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`IN RE: AUTOMOTIVE PARTS
` Master File No. 12-md-02311
`ANTITRUST LITIGATION
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`THIS DOCUMENT RELATES TO:
`ALL END-PAYOR ACTIONS
`
`Hon. Sean F. Cox
`Mag. Judge R. Steven Whalen
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`DECLARATION OF DANIEL W. SHOAG, PH.D.,
`CONCERNING TOTAL LOSS VEHICLE DATA
`SUBMITTED BY FINANCIAL RECOVERY SERVICES, LLC
`I, DANIEL W. SHOAG, declare:
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`1.
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`I am an economics professor. I have been teaching economics and
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`econometrics at Harvard University and Case Western Reserve University for the
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`past 10 years. I have been engaged by Kellogg, Hansen, Todd, Figel & Frederick,
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`P.L.L.C. (“Kellogg Hansen”), which represents Financial Recovery Services, LLC
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`d/b/a Financial Recovery Strategies (“FRS”) in connection with FRS’s retention by
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`automobile insurers (the “Insurers”), each a putative member of the End-Payor
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`Settlement classes, to prepare, submit, and manage their proofs of claim (each, a
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`“Claim Form”) to recover from the End-Payor Settlements as a result of the
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`indemnity payments they made in connection with Total Loss Vehicles.1 This
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`declaration is based on my personal knowledge and the knowledge of my colleagues
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`at Coherent Economics, LLC, the economic consulting firm also retained by Kellogg
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`Hansen in connection with this engagement, working under my supervision.
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`I.
`SCOPE OF ENGAGEMENT
`I have been tasked with identifying, processing, and compiling the
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`2.
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`data for each Total Loss Vehicle (the “Total Loss Vehicle Data”), as requested by
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`the Claim Form, for vehicles eligible to recover from the End-Payor Settlements
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`(each, an “Eligible Vehicle”),2 to complete the Claim Form that each Insurer
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`submitted on or before June 18, 2020.3 In summary, I obtained from or on behalf of
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`the Insurers data concerning vehicles that were deemed a “total loss” and were
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`indemnified by the Insurers (the “Indemnified Vehicles”), which data is of the type
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`1 All terms with initial capitalization that are not defined in this declaration
`have the same meanings as those set forth in the Memorandum of Law in Support of
`Financial Recovery Services, LLC’s Motion To Intervene, No. 2:12-md-02311, ECF
`No. 2060, PageID.37697-37721.
`2 Prior to June 18, 2020, the Claim Form approved by the Court was available
`on the official settlement website, http://www.autopartsclass.com/. The list of
`Eligible Vehicles may be found at http://www.autopartsclass.com/included.
`3 I understand that the expert retained by the End-Payor Plaintiffs determined,
`for each covered automobile part, the amount of overpayment caused by the alleged
`antitrust violations. I have made no independent investigation of those issues; I
`describe in this declaration only the work that I have performed and will perform to
`prepare the Total Loss Vehicle Data necessary to complete the Claim Form for each
`Total Loss Vehicle.
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`commonly relied upon by economic experts and that, for the reasons set forth below,
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`I determined to be reliable and sufficient to complete the Claim Form.4 I then
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`processed such data to identify which of the Indemnified Vehicles are Total Loss
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`Vehicles. As set forth below, it is my opinion that the Total Loss Vehicle Data that
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`will be submitted when my work is completed will be accurate and complete for
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`each Total Loss Vehicle set forth therein.
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`3.
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`This declaration is organized as follows: In Section II, I present my
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`qualifications as an expert. In Section III, I describe the sources that, for each Total
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`Loss Vehicle, I am using to provide the Total Loss Vehicle Data. And in Section IV,
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`I offer a summary of the methodology that I am using to prepare the Total Loss
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`Vehicle Data for the Claim Form.
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`II.
`QUALIFICATIONS
`I received my BA, MA, and Ph.D. in economics from Harvard
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`4.
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`University. My statistical research has been published in major academic journals,
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`including the Quarterly Journal of Economics and the Review of Economics and
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`Statistics, and has been featured in, among other outlets, The New York Times,
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`Bloomberg, The Washington Post, and The Wall Street Journal. In 2012, I was
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`selected as one of Forbes’ “30 Under 30 in Law & Policy.”
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`4 As discussed below, the data I obtained is from third-party data providers
`that maintain such data records in the ordinary course of business.
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`5.
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`I have worked as a visiting scholar at the Federal Reserve Bank of
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`Boston and as a visiting professor at Tel Aviv University, and I was selected by the
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`Stanford University Center on Poverty and Inequality as a “rising new scholar.”
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`6.
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`I have received research grants from the U.S. Department of
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`Transportation, the Russell Sage Foundation, and the Laura and John Arnold
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`Foundation. In 2017, I was awarded a prize for Best Paper on State, Local, and
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`Regional Economic and Fiscal Issues at the Brookings Conference on Municipal
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`Finance.
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`7.
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`I co-founded and co-chaired the more than 200-person HumTech
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`conference in Boston, and I have co-edited the annual peer-reviewed conference
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`proceedings volume. I have worked as an economic consultant for over a decade.
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`8. My qualifications, publications, and expert engagements are
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`summarized in detail in my curriculum vitae, which is attached to this report as
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`Exhibit C. For this matter, I am being compensated at a rate of $550 per hour.
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`III.
`SOURCES OF TOTAL LOSS VEHICLE DATA
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`9.
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`Using my education and my experience as an economist, together with
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`my extensive and wide-ranging experience in statistical research, I have obtained for
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`Indemnified Vehicles and will prepare for Total Loss Vehicles Total Loss Vehicle
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`Data sufficient to complete each Insurer’s Claim Form. As described below, because
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`not all of the data requested by the Claim Form for all Total Loss Vehicles was
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`readily accessible from the Insurers’ own records, I identified alternative sources of
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`reliable data, namely (i) the independent third-party salvage vendors (each, a
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`“Salvage Vendor”) that each Insurer contracted to process vehicles deemed to be a
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`total loss, and (ii) the AutoCheck® platform provided by Experian Information
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`Solutions, Inc. (“Experian”), a well-known commercial data vendor.
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`The Insurers
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`10. To prepare the Total Loss Vehicle Data, I first coordinated with each
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`Insurer. I determined that, due to the nature of recordkeeping necessary for providing
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`automobile insurance as compared to that for automobile ownership, none of the
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`Insurers had or could reasonably collect from its own records certain information
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`about the Total Loss Vehicles—specifically, whether each Total Loss Vehicle was
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`new when purchased or leased, whether it was among the vehicles listed as Eligible
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`Vehicles, and whether it was purchased or leased during the relevant class periods
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`(collectively, the “Class Periods”) by purchasers or lessees who resided in one of the
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`eligible jurisdictions. I learned that, for example, to the extent that the Insurers
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`continued to maintain relevant records for such data points decades after an
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`Indemnified Vehicle was initially insured, those records are maintained in different
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`departments and are not maintained for the entirety of the Class Periods. This is due
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`to, among other customarily occurring events, ordinary document retention and
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`destruction policies, acquisitions and divestitures of business units, and
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`modifications and upgrades to information technology and data storage systems.
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`Accordingly, it was necessary to identify alternative sources of data to reliably
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`provide all vehicle information requested by the Claim Form.
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`Salvage Vendors
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`11.
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`I identified the Salvage Vendors as one alternate source of data. In
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`connection with an insurer’s contractual indemnification obligations concerning
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`vehicles that the insurer has deemed to be a total loss, the insurer contracts with and
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`pays a Salvage Vendor to take possession of and process the vehicle. I learned
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`through my investigation that each of the Insurers’ Salvage Vendor maintains for
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`each of its clients, including the Insurers, digital records of all Indemnified Vehicles.
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`12. The two Salvage Vendors used by the Insurers were Copart Inc.
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`(“Copart”) and Insurance Auto Auctions, Inc. (“IAA”). I obtained from Copart and
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`IAA the Vehicle Identification Number, or “VIN,” for each of the Indemnified
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`Vehicles that Copart and IAA processed for one of the Insurers over the period for
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`which they were able to provide such records.5 Each Salvage Vendor maintains
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`records by client name; therefore, each Salvage Vendor provided the datasets
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`separately for each Insurer. Across all Insurers, the Salvage Vendors provided data
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`for in excess of 3.5 million Indemnified Vehicles.
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`5 This Declaration does not address Total Loss Vehicles for which records
`were not provided by the Salvage Vendors.
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`13.
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`I consider the Salvage Vendors’ records to be reliable given their
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`clientele and their credentials, which I describe in more detail below:6
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`a. Copart. Copart was founded in 1982. It operates more than 200
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`locations in 11 countries with more than 175,000 vehicles up for auction each
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`day. Copart specializes in the resale and remarketing of used, wholesale, and
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`salvage title vehicles for a variety of sellers, including insurance companies,
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`rental car companies, local municipalities, financial institutions, and
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`charities.7
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`b. IAA. Like Copart, IAA (NYSE: IAA) facilitates the marketing
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`and sale of total loss, damaged, and low-value vehicles. IAA has nearly 4,000
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`employees and has more than 200 facilities throughout the United States,
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`Canada, and the United Kingdom.8
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`14. Copart confirmed that neither it nor IAA will process any vehicle
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`deemed by an insurer to be a total loss unless directed by the insurer to do so, which
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`results in a fee being charged to the insurer and, therefore, occurs only when the
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`affected insurer has a contractual obligation under a policy of insurance to indemnify
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`6 I have made no independent assessment of the VINs provided to me by the
`Salvage Vendors.
`7 Information available at https://www.copart.com/ (last visited Mar. 31,
`2021).
`8 Information available at https://www.iaai.com/ (last visited Mar. 31, 2021).
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`the vehicle. In those rare cases in which an insurer, having previously directed a
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`Salvage Vendor to process a vehicle deemed to be a total loss and later determines
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`that the insurer does not have a contractual obligation to provide indemnity for that
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`vehicle (e.g., the damage resulted from a flood, but the coverage is limited to liability
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`and collision, not comprehensive), the Salvage Vendor will discontinue processing
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`the vehicle for the insurer and will instead work with the owner/lessee to resolve the
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`matter. The only VINs provided by the Salvage Vendors were for Indemnified
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`Vehicles that, because one of the Insurers had a contractual obligation to indemnify
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`it, the Salvage Vendors fully processed. Therefore, I find it reasonable to conclude
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`that, for the vehicles identified by the Salvage Vendors for each of the Insurers, it
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`was insured by the Insurer identified by the Salvage Vendor, it was deemed a total
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`loss by that Insurer, and the Insurer indemnified the vehicle.
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`15. The data provided by the Salvage Vendors did not include the following
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`data points requested by the Claim Form: (a) whether an Indemnified Vehicle was
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`new when purchased or leased, (b) where the purchaser or lessee resided at that time,
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`and (c) whether the Indemnified Vehicle was leased or purchased. Therefore, it was
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`necessary to identify an additional source of data reliably to provide all of the vehicle
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`information requested by the Claim Form.
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`Page 8 of 17
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`Experian’s AutoCheck® Platform
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`16.
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`I selected Experian’s AutoCheck® platform as the best source for the
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`remaining Total Loss Vehicles Data. As described on its website, the AutoCheck®
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`platform is relied upon by “automobile industry experts” and includes “industrial-
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`strength data backed by Experian, the global market leader in information services.”9
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`For these reasons, as well as the reasons I discuss below, it is my opinion that the
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`Experian AutoCheck® platform is a robust and reliable source of vehicle
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`information.
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`17. Experian’s AutoCheck® platform relies on data from 11 unique data
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`sources, including, among others, state departments of motor vehicles (“DMVs”),
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`auto and salvage auctions,
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`insurance companies, car dealerships, and
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`manufacturers.10 From these sources, Experian obtains the vehicle-level data
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`necessary to complete the Claim Form but that were not provided by the Insurers or
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`the Salvage Vendors. For example, Experian obtains directly from state DMVs such
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`information as branded titles, including salvage/junk, flood, hailstorm, and fire
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`damage; the city and state of previous registration; the number of owners; and lien
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`the AutoChcck® website,
`is available on
`9 More
`information
`https://www.autocheck.com/ (last visited Mar. 31, 2021).
`10 The full list of data sources for the Experian AutoCheck® database may be
`found at https://www.autocheck.com/vehiclehistory/backed-by-experian
`(last
`visited May 5, 2021).
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`and ownership transfer information. From insurance companies, Experian obtains
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`the identification of the vehicles they deemed a total loss and the reasons that they
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`were deemed as such. From salvage auctions, Experian obtains whether a vehicle
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`was salvaged or junked. Finally, from service and maintenance facilities and/or car
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`dealerships and vehicle inspection stations, Experian obtains a vehicle’s odometer
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`reading.
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`18. Before deciding to rely upon the data obtainable from Experian, I
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`considered publicly available independent reviews of vehicle history reports in
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`general, as well as of those available from Experian’s AutoCheck® platform in
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`particular. For example:
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`a. A September 26, 2019 article by Edmunds.com, Inc., “Carfax or
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`AutoCheck: Which Vehicle History Report Is Best for You?,” states:
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`Vehicle history reports have become an integral part of any
`used-car purchase. They are one of the best ways to learn about
`a given vehicle’s past and help make your search for a used car
`much easier. Most importantly, the report tells shoppers if a
`car has a “branded” title. Branding means an insurance
`company has declared the vehicle a total loss and given it a
`salvage title because of an accident, flood damage or other
`catastrophic event. …
`The car’s vehicle identification number (VIN) is the key to
`the vehicle history report. The 17-digit VIN is like the car’s
`Social Security number: It’s used to note nearly every
`major event
`in a vehicle’s
`lifetime. Typically,
`the
`information on a vehicle history report includes a summary
`and an overall evaluation of the vehicle, supported with
`details, dates and locations. The report makes it easy to see
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`if the car has been registered in numerous states. Other
`information can include a description of the vehicle, the
`number of previous owners, accident
`information,
`verification of recent mileage (which could include an alert for
`an odometer rollback), and lemon-law and recall checks. …
`Most major used-car dealers and some car-selling sites will
`provide a free Carfax report or AutoCheck report. …
`All dealers have vehicle history report subscriptions, usually
`for either AutoCheck or Carfax, and will run a free report for
`interested buyers. …11
`b. Another article, “AutoCheck vs Carfax – Which One Should I
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`Use?,” published on January 14, 2021 by Autolist, states that “[t]here are two
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`main companies that provide information about vehicles: AutoCheck and
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`Carfax.” In describing the merits of vehicle history research, Autolist points
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`out that they “offer a thorough look at the history of a vehicle’s service
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`records, accident history, and emissions records. A vehicle history report will
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`show salvage titles and other red flags for used vehicles, such as branded
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`titles (sometimes also called salvage titles).” The review goes on to state:
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`Both services draw information from the National Motor
`Vehicle Title Information System (NMVTIS), which is run by
`the federal Department of Justice. This agency collects its title
`information from state motor vehicle registries. It’s the only
`publicly-available system in the U.S. that all auto recyclers,
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`11 Montoya, Ronald, “Carfax or AutoCheck: Which Vehicle History Report Is
`for
`You?,”
`Edmunds,
`Sept.
`26,
`2019,
`available
`at
`Best
`https://www.edmunds.com/car-buying/which-vehicle-history-report-is-right-for-
`you.html (last visited May 5, 2021) (emphasis added).
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`junk yards and salvage yards – as well as insurance carriers –
`must report to regularly.
`In other words, both Carfax and AutoCheck let you analyze
`the vehicle’s past so you can make an informed purchase.
`In its review of AutoCheck®, Autolist advises that “AutoCheck is owned by
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`Experian, and it has relationships with industry leaders, including CarMax
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`(different than Carfax), eBay Motors, Edmunds.com, NADAguides.com, and
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`Kelley Blue Book.” Autolist also notes that AutoCheck® “provides
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`registration and title data from all 50 states, as well as the District of
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`Columbia. The platform also delivers collision records from police reports
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`and other sources, as well as event data from insurance companies and
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`salvage yards.” Autolist identifies as “[o]ne of AutoCheck’s key advantages
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`over Carfax,” its “exclusive access to auction data from the two largest
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`United States auctions, potentially giving prospective buyers a more
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`comprehensive look at a vehicle’s history (this is why their reports have a
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`better reputation with used car dealers).” And Autolist points out that, among
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`other things, AutoCheck® “checks for records of the vehicle being
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`abandoned, damaged, junked or scrapped. … The platform also reports any
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`documented fire, hail or water damage, as well as any frame or structural
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`damage or odometer damage.” 12
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`19. The Experian data includes each of the data points requested by the
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`Claim Form for each Total Loss Vehicle. Set forth in Table 1 below is the list of the
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`relevant data fields provided by Experian, which I discuss further below in
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`Section IV:
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`
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`IV.
`DETERMINING THE TOTAL LOSS VEHICLE DATA
`NECESSARY TO COMPLETE INSURERS’ CLAIM FORMS
`20. To identify and provide the Total Loss Vehicle Data necessary to
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`complete the fields on the Claim Form, I input into the Experian AutoCheck®
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`platform the VINs provided by the Salvage Vendors, and I received the data fields
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`listed above in Table 1, among others.
`
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`12 Per “AutoCheck vs Carfax - Which One Should I Use?,” Autolist Editorial,
`Jan. 14, 2021, available at https://www.autolist.com/guides/autocheck-vs-carfax
`(last visited May 5, 2021).
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`21.
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`I discuss below the processing methodology that I am applying to the
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`Experian AutoCheck® data to determine (i) whether each Indemnified Vehicle was
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`purchased or leased as a new vehicle (each, a “New Indemnified Vehicle”),
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`(ii) whether each New Indemnified Vehicle was purchased or leased in an eligible
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`jurisdiction, and (iii) whether each New Indemnified Vehicle that was purchased or
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`leased in an eligible jurisdiction is an Eligible Vehicle, which would result in it being
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`a Total Loss Vehicle for which I can provide the information necessary to complete
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`the Claim Form. This analysis is ongoing and has not yet been completed. Therefore,
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`the methodology described below is subject to revision.
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`22. As a starting point, I used the Experian AutoCheck® data to identify
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`the Indemnified Vehicles that were new when purchased or leased (the “New
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`Indemnified Vehicles”). To identify New Indemnified Vehicles, I first identified
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`Indemnified Vehicles for which Experian reported only one historical owner, which
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`indicates that the insured was the original owner. I consider these vehicles to be New
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`Indemnified Vehicles.
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`23. Next, because I obtained the Experian AutoCheck® data in 2021 and
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`because Experian tracks a vehicle’s ownership over time, including after a salvage
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`event, I processed Experian’s ownership history data for Indemnified Vehicles for
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`which Experian reported multiple historical owners as of 2021 to determine the
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`number of owners for each of those Indemnified Vehicles at the time they were
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`deemed a total loss. If Experian’s ownership history data shows that an Indemnified
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`Vehicle only had one historical owner at the time that it was deemed a total loss, I
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`consider such an Indemnified Vehicle to be a New Indemnified Vehicle.
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`24. To determine whether, at the time of purchase or lease, a purchaser or
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`lessee of a New Indemnified Vehicle resided or had a principal place of business in
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`one of the eligible jurisdictions, I identified in the Experian AutoCheck® data the
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`state associated with the first title or registration event for each New Indemnified
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`Vehicle. If the first title or registration event for a New Total Loss Vehicle is in an
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`eligible jurisdiction, I consider the New Indemnified Vehicle to be eligible based
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`upon the jurisdictional criteria.13
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`25. Finally, to determine whether the New Indemnified Vehicles that were
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`purchased or leased in an eligible jurisdiction also are Eligible Vehicles, I compared
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`for those vehicles the year, make, and model from the Experian AutoCheck® data
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`with the corresponding information on the list of Eligible Vehicles provided on the
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`official settlement website.14 I considered each New Indemnified Vehicle that was
`
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`13 I understand that the eligible jurisdictions are the District of Columbia,
`Arizona, Arkansas, California, Florida, Hawaii,
`Iowa, Kansas, Maine,
`Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska,
`Nevada, New Hampshire, New Mexico, New York, North Carolina, North Dakota,
`Oregon, Rhode Island, South Carolina, South Dakota, Tennessee, Utah, Vermont,
`West Virginia, and Wisconsin.
`Eligible Vehicles may
`14
`The
`list
`of
`http://www.autopartsclass.com/included.
`
`at
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`be
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`found
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`purchased or leased in an eligible jurisdiction for which the year, make, and model
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`matches the eligible list to be a Total Loss Vehicle.
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`26.
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`In sum, I have used the Experian AutoCheck® data to identify for each
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`of the Insurers Indemnified Vehicles that, because they (i) were new when they were
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`purchased or leased, (ii) were purchased or leased by a purchaser or lessee who or
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`which resided or had a principal place of business in one of the eligible jurisdictions,
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`and (iii) were included on the list of Eligible Vehicles provided on the official
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`settlement website, are Total Loss Vehicles.
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`27.
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`In the next stage of my analysis, I will use the data provided by the
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`Salvage Vendors and Experian to provide the Total Loss Vehicle Data necessary to
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`complete for each Insurer the fields on the Claim Form. Specifically, for each Total
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`Loss Vehicle, I will provide the following information: (i) that it was new when
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`purchased or leased; (ii) vehicle year, (iii) vehicle make, (iv) vehicle model,
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`(v) VIN, (vi) state of residence or principal place of business of the purchaser or
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`lessee at the time of purchase or lease, (vii) estimated date of purchase or lease, and
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`(viii) whether the vehicle was purchased or leased. It is my opinion, based on my
`
`education and my experience as an economist, together with my extensive and wide-
`
`ranging experience in statistical research, that the Total Loss Vehicle Data that will
`
`be submitted when my work is completed will be accurate and complete for each
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`Total Loss Vehicle set forth therein.
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`Page 16 of 17
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`Case 2:12-md-02311-SFC-RSW ECF No. 2137-5, PageID.39241 Filed 05/07/21 Page 18 of 18
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