I thought the 37k fine was for the first few vehicles and reduced on a sliding scale thereafter.
Nope, each and every, plus some change:
up to $32,500 per 2.0L Subject Vehicle and 3.0L Subject Vehicle for each violation occurring before January 13, 2009, and up to $37,500 per 2.0L Subject Vehicle and 3.0L Subject Vehicle for each violation occurring on or after January 13, 2009 for violations of Section 203(a)(1) of the Act;
ii. up to $32,500 per 2.0L Subject Vehicle and 3.0L Subject Vehicle for each violation occurring before January 13, 2009, and up to $37,500 per 2.0L Subject Vehicle and 3.0L Subject Vehicle for each violation occurring on or after January 13, 2009 for violations of Section 203(a)(3)(A) of the Act;
up to $2,750 per “defeat device” per 2.0L Subject Vehicle and 3.0L Subject Vehicle for each violation occurring before January 13, 2009, and up to $3,750 per “defeat device” per 2.0L Subject Vehicle and 3.0L Subject Vehicle for each violation occurring on or after January 13, 2009 for violations of Section 203(a)(3)(B) of the Act; and
iv. up to $32,500 per day of violation occurring before January 13, 2009, and up to $37,500 per day of violation occurring on or after January 13, 2009 for violations of Section 203(a)(2) of the Act.