The only way the odometer will be able to read with zero error is for the tire circumference to be perfectly constant over the life of the warranty.

Since tire wear can easily affect the circumference, then there's no way for an odometer to have zero error.

In the Honda case, they have odometers that meet the DOT spec for odometer accuracy, and someone still sued them.

If this case is similar (and I don't claim to know the particulars), then it's frivolous.

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