No US CRD's came from the factory with F37 because F37 came out in December of 2006 after the 06 model year production was stopped

Early on it was determined that even though F37 was just a TSB dealers were treating it as a recall. But that was before bankruptcy. A true recall is for safty issues and the NHATA (or whatever it is) was involved. All model year 2005 and those model year 2006s produced before November 2005 had the torque converter replaced. BUT all 2005 and 2006 CRD's got the ECM and TCM flashed.
As far as 'required" to make it work with third party scanners first you/they need to determine they can communicate with it with their gear. A good way to do that would be to replace the torque converter and flash the ECM and TCM.
F31 was a recall for not communicating with third party scanners and not many CRD's were effected and needed F31 because IT WAS CAUSED by a flash that came out in early June 06. After owning mine for only two weeks a cooling leak developed and while there they flashed it with an early version of what later was F37 and that early flash caused it to not communicate with third party scanners

Since there is already history of CRD's not communicating with third party scanners you may have a leg to stand on even if only one leg

Expecially since the service records of your jeep are questionable
But there's that puppet judge in NY that determined that "new car company" is not responsible for "old car company's" problems
