#### 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 re