Not quite accurate. The owner had receipts, but not all of the requested/needed receipts. There's a difference between "no receipts" as you state, and missing some receipts (how many we don't know). The article states:
The car’s owner’s manual does say: “Maintenance service and record retention are the owner’s responsibility. You should retain documents that show proper maintenance has been performed on your vehicle in accordance with the scheduled maintenance service charts shown on the following pages. You need this information to establish your compliance with the servicing and maintenance requirements of your vehicle warranties.”
Walker didn’t have a copy of the photo of the alleged “sludge,” but we asked her to see if she could obtain any of the oil change receipts.
Some showed on a Carfax report, but not all.
So Walker kept trying. She was able to get some from one provider, but she struck out with another that had changed ownership since she was a customer.
The records she did receive showed regular oil changes, but there were some gaps in time, she said, because of the missing receipts. We sent the documentation to Hyundai and asked it to take another look.