IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

Premier Dealer Services, Inc., Case No. 2:18-cv-00735-EAS-CMV 

Plaintiff, Judge Edmund A. Sargus 

vs. Magistrate Judge Chelsey M. Vascura 

Allegiance Administrators, LLC, et al., 

Defendants. 

Expert Report of Allegiance's Retained Expert, Mr. Lyle King 

1. My name is Lyle King and I have been retained by counsel for Allegiance Administrators, 

LLC, et al. as an expert witness in this matter designated above (the "Case"). 

2. I've been in the related Finance and Insurance industry within the auto dealer space for 

over 20 years and have significant history working with administrators on warranty and 

service contract products similar to the types of products at issue in this Case. 

3. I graduated from Texas A&M University in 1984 with a business administration degree 

and early in my career began working in the automotive industry. In 1998, I began my 

agency business and along with partners that shared in ownership over time, built a large 

agency business called AutoGroup Services, Inc and AGS Direct, Inc. which served as an 

intermediary between dealers and administrators in the automotive finance and insurance 

industry. 

4. In 2015, we sold the company to a multi-billion dollar insurance broker (NFP — formerly 

known as National Finance Partners). I stayed with NFP until earlier this year when I began 

my consulting practice in the same industry space which I now operate. 

5. I have been retained to provide opinions in reference to the only remaining claim, which 

relate to a loyalty program used by Tricor in Canada that is set forth on a form that has 

Uniform Exhibit 141
been called in the Case the "New Tricor Form" and "Derivative LPLP Certificate" in this 

Case, and on which Allegiance performs administration for Tricor on the program. 

6. In the course and scope of my experience, I am very familiar with and have used loyalty 

and lifetime warranty programs in auto dealers with multiple administration companies. 

My familiarity is with not only the content or language of these type agreements, but also 

with the fees charged for administration services on loyalty programs by various 

administrators. 

7. Allegiance has stated in discovery that Allegiance received $40 for an administration fee 

to administer Tricor's lifetime contracts at issue in the Case. 

8. Based on my years of experience in this area, this administrative fee is consistent with the 

fair market value for the administration services required of Allegiance on the lifetime 

loyalty program at issue in this Case. 

9. Further, based on my years of experience in the relevant industry, the administration fee 

charged by Allegiance on this program is consistent with the range that competitors charge 

for administering this type of program. 

10. The fees charged for administration services typically include services such as data entry, 

record keeping, accounting, earnings tracking, intake of claims, adjudication of claims to 

determine liability, and paying of those claims when liability is established, etc. 

11. The administration fee for a particular program has little or nothing to do with the language 

or style of the form used. It is based on the fair market value for the services. Furthermore, 

based on my 20 plus years experience, I have repeatedly observed that most forms are 

substantially similar amongst the various providers of loyalty programs, vehicle service 

contracts, and other F&I products. 

12. Many vsc and loyalty programs use terms and conditions language that is nearly identical 

to other programs and tends to provide the same, or very similar, coverage. Many times, a 

client (dealer) will author the form used and the administrator simply does the 

administrative job and weren't even the author of the form. 

13. I've been retained by Defendants' counsel as expert witness on these matters at the rate of 

$200 per hour. 

14. I have reviewed the second amended complaint and the forms at issue, in conjunction with 

my extensive industry experience and expertise, to form my opinions in this matter. 

Lyle King 

LiNK Advisors, LLC 

Date 

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