Volkswagen’s Goodwill Program in the U.S., which may cost the company nearly half a billion dollars all told, may be a form of corporate apology that could insulate the automaker from further lawsuits.

Michael Siebecker, a professor of law at the University of Denver, says the company’s gift cards could be a form of “corporate apology” that studies have shown help shield some doctors from medical malpractice lawsuits.

“I believe that this is a type of watered-down apology. They may be saying ‘You must be hurting, here’s a little something to get by.’ I don’t know what exactly they think consumers need right now,” Siebecker said.

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