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It definitely has to be more than 1200 miles if you want BMW to pay for it. The dealership has to submit the receipt to BMW for reimbursement and it's based on the odometer reading. It's a different story whether BMW will cover for M235i or not. If the dealer make you pay for it or they cover it as a goodwill, then it doesn't matter how many miles you've got on it.
As far as I know, there has only been one member of this forum, or any forums for that matter, who got it for free and even he wasn't sure whether the dealership did it as a favor or BMW actually paid for it.
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