You have 2 issues at play. Michigan Lemon Law would apply to the value when you first complained about the 12V battery issue minus taxes paid minus 10 cents per mile till now + any repair expense you paid = is what you should get if its been in dealer repair for more than 30 days total. The HV battery setting itself on fire is a different issue would in my belief be relative to the value in mid 2023 at the first recall less sales taxes paid minus 10 per mile driven since that date till now+any special costs to clean up the mess for when it happens. Even though I didn't complain about the HV fire, the USDOT complained on everyone's behalf. If the HV fire happens, the car turns to ashes...nothing to drive, nothing fixable. Nobody wants the HV car fire to happen to have something to complain about... it could burn your house down and physically injure you and your family. Now is your 12V battery issue before or after mid 2023, or older closer to when you bought your car? In my case I have no 12V issue, just the HV battery issue. Its a bit harder to accurately identify the value or sellable price in mid 2023, far in time from 2019 when I bought the car. I can't get Kelly Blue Book to tell me now the resale price in 2023 when I had 30K Miles vs now 2 years later. The 15k miles since mid 2023 are easy to evaluate. But the mid 2023 value is hard even for the bean counters to figure out unless lawyers make a special request to KBB. Personally, $5K to $10K above what it might have been should not matter much, Jaguar turns around and bills Magna Steir Austria for it who then bills LG for it. I can understand the entire food chain not wanting too much sloppy cost over evaluations or closing cost proposals. Like everyone for their personal car, I want an over estimation and not an underestimation on the starting value in the Michigan calculation. What the calculation is in their state or country, can all be different. So what a Michigan person gets offered can be different than what someone is offered in California or Canada or Australia or where ever they are (the variations in all the laws can be mind boggling). I certainly would not accept a "todays value". Which is $0. One can not sell the I Pace with the death certificate of this particular recall. Any simple VIN search for free will reveal this serious safety recall... my car is not publically sellable by a licensed dealer. They would not touch it or accept for a trade in value because of this recall. Which is probably true around the world for the 2018 and early 2019 I Paces.