The alleged violations occurred as a result of a discrepancy between the applications Defendants submitted for Certificates of Conformity and the actual specifications of the Subject Vehicles. Certificates of Conformity are required for new model vehicles pursuant to the CAA and include various specifications related to vehicle emissions. If a vehicle which is nominally covered by a given Certificate does not actually meet the specifications in that Certificate, the EPA deems that vehicle not covered by the Certificate at all, leaving it in violation of the CAA. In this case, Defendants submitted applications for Certificates which reported the Subject Vehicles' road load force. Road load force directly impacts the calculation of fuel economy rates and whether a vehicle meets air pollution emission standards. EPA determined that the road load force for the Subject Vehicles did not match the specifications in their Certificates due to Defendants' improper testing, analysis, and reporting. The Subject Vehicles had a higher road load force than Defendants' originally represented, meaning the vehicles had lower fuel economy and higher emissions compared to what Defendants stated in their applications. Because the actual road load force did not match the road load force in the Certificates, the Subject Vehicles were allegedly in violation of the CAA. See 42 U.S.C. §§ 7522-24.