For this kind of recall, the expense can be insanely low. It's just a software update that can be done over the air. Something that would warrant a recall is the type of thing they would fix for future builds. So they already put money into it to update the software for future builds. Just pushing it to older builds is simple. Ergo the part of the formula for "the cost of doing the recall" is, as previously mentioned, insanely low. This makes it very easy to have that cost be lower than the amount to settle out of court.