A lawsuit filed in San Francisco by a Tesla owner claims the automaker and its CEO / Technoking Elon Musk are “deceptively and misleadingly” marketing the Autopilot and “Full Self-Driving” advanced driver assistance features that are available as paid software add-ons (via Automotive News).

The filing claims Tesla and Musk “deceived and misled consumers regarding the current abilities of its ADAS [advanced driver-assistance system] technology and by representing that it was perpetually on the cusp of perfecting that technology and finally fulfilling its promise of producing a fully self-driving car,” and that “contrary to Tesla’s repeated promises that it would have a fully self-driving car within months or a year, Tesla has never been remotely close to achieving that goal.”

The plaintiff, Briggs Matsko, says he spent $5,000 for the package in 2018, like many Tesla drivers who’ve paid thousands of dollars for Enhanced Autopilot. That was sold as a precursor to “Full Self-Driving” tech,a now $15,000 software add-on package that still isn’t ready to ship. Matsko is seeking class-action status for the lawsuit, while the company is already facing another class-action lawsuit targeting “phantom breaking incident” that have plagued the adaptive cruise control features on Teslas for years.

The lawsuit calls out Tesla’s features terminology, including the name “Autopilot,” as well as Elon Musk’s public statements and tweets regarding the perpetually unfinished Full Self-Driving system. It specifically mentions Musk’s claim that an autonomous US cross-country trip will be performed by 2018, and his 2019 claims about putting 1 million robotaxis on the road, saying, “A year from now, we’ll have over a million cars with full self-driving, software… everything.”