ORS 822.048: Remedy for failure to submit title.

If a vehicle dealer fails to comply with ORS 822.042 (1)(b) or (d) or 822.045 (1)(k), the retail customer of the subject vehicle may bring an individual action against the vehicle dealer in the appropriate court. The court may award reasonable attorney fees to a prevailing plaintiff who brings an action under this section if the court finds all of the following:

      (1) A written demand was made on the defendant not less than 30 days before commencement of the action requesting compliance or other remedy.

      (2) The defendant failed to comply or provide the remedy, including paying the plaintiff reasonable attorney fees and costs incurred by the plaintiff, within 30 days of the date of the written demand.