Campfield Files Amended Complaint While Safelite Files Motion to Dismiss

Is the case of Campfield vs. Safelite close to a resolution? Not quite. On February 7, Richard Campfield filed a 60-page amended complaint, including a jury demand, to his original lawsuit filed in August 2015. The next day Safelite filed a motion to dismiss that amended complaint. Campfield, the founder of Ultra Bond in Grand Junction, Colo., alleges Safelite uses misleading advertising that favors replacement of windshields rather than repairs of long cracks. This, Campfield claims, has “wiped out a large portion (if not most) of the market for Ultra Bond’s products and services.”

The Amendment

Campfield requests, among other items, in the new complaint the following:

  • “Permanently enjoin Defendants from disseminating or causing the dissemination of any oral or written statements, expressly or by implication, stating that only windshield cracks up to six inches long can be safely repaired and/or that windshield cracks longer than six inches require that the windshield be replaced rather than repaired.”
  • “Require Defendants to disseminate corrective advertising for the misrepresentations in (a) above in a manner to be determined.”

The Motion to Dismiss

Defendants Safelite Group, Inc., Safelite Solutions, LLC, and Safelite Fulfillment, Inc. (“Safelite” or “Defendants”) respectfully move the Court to dismiss Plaintiffs Richard Campfield and Ultra Bond, Inc.’s Amended Complaint with prejudice.

“The Court already narrowed this case once when it granted in part Safelite’s motion to dismiss Plaintiffs’ original complaint. It should now dismiss the case in its entirety,” Safelite says in the court documents. “Plaintiffs’ Amended Complaint disregards the Court’s order by attempting to re-introduce everything the Court dismissed—and more.”


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