UPDATE 3:45pm: This is the response I got from Metro ExpressLanes:
As of November 10th, 2012 at 10:00 pm, all vehicles in the I-110 ExpressLanes were required to have a transponder. As of February 23rd at 12:01 am, 2013, all vehicles in the I-10 ExpressLanes were required to have a transponder. If you used the ExpressLanes after that time without
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