Feedback

Robinson V 3m Company

           UNITED STATES DISTRICT COURT                              
            MIDDLE DISTRICT OF FLORIDA                               
                   TAMPA DIVISION                                    

TINA ROBINSON,                                                            

Plaintiff,                                                           
v.                                   Case No. 8:24-cv-00828-WFJ-AAS       

3M COMPANY,                                                               
and ARIZANT HEALTHCARE, INC.,                                             

Defendants.                                                          
________________________________/                                         

                        ORDER                                        
Before  the  Court  are  Defendants  3M  Company  and  Arizant  Healthcare, 
Inc.’s (collectively “3M” or “Defendants”) Motion to Exclude Plaintiff’s General 
Causation Experts, Motion to Exclude Specific Causation Opinions of Plaintiff’s 
Expert Dr. Yoav Golan, and Motion for Summary Judgment. Dkts. 73, 74, & 76. 
Plaintiff Tina Robinson has responded to all three motions, Dkts. 79, 80, & 81, and 
Defendant 3M replied. Dkts. 88, 85, & 87. Upon careful consideration, the Court 
denies  Defendants’  Motion  to  Exclude  Plaintiff’s  General  Causation  Experts, 
denies Defendants’ Motion to Exclude Specific Causation Opinions of Plaintiff’s 
Expert Dr. Yoav Golan, and denies in part and grants in part Defendants’ Motion 
for Summary Judgment.                                                     
                    BACKGROUND                                       
This case was transferred to this Court from the District of Minnesota as part 

of the larger MDL proceeding In re: Bair Hugger Forced Air Warming Devices 
Products  Liability  Litigation,  MDL  15-2666-JNE  (D.  Minn.  Apr.  19,  2016). 
Plaintiff’s case was transferred to the Middle District of Florida and assigned to the 

undersigned on April 1, 2024. Dkt. 10 at 8.                               
On  April  23,  2021,  Plaintiff  Robinson  presented  to  the  emergency 
department at HCA Florida Brandon Hospital (“Brandon Hospital”) in Brandon, 
Florida, after a dog ran into the lateral aspect of her right knee, knocking her down. 

Dkt. 75 ¶ 23. A subsequent radiology scan revealed an unstable fracture to her 
right tibia, and surgery was recommended. Id. ¶ 24. Two weeks later, on May 6, 
2021,  Robinson  underwent  an  open  reduction  and  internal  fixation  (“ORIF”) 

procedure to repair her tibial plateau split depressed fracture,1 performed by Dr. 
Anjan Shah at Brandon Hospital. Id. ¶ 25. During the ORIF surgery, the surgeon 
and anesthesiologist used the Bair Hugger Force Air Warming System (the “Bair 
Hugger”). Id. ¶ 26. The Bair Hugger is a forced-air warming device used during 

surgical procedures to prevent a patient’s core body temperature from dropping, 
thereby mitigating the risk of hypothermia. Id. ¶¶ 4–5, 9. The product works by 


1 A tibial plateau fracture is an injury where the patient breaks the bone and damages the cartilage on top of the tibia 
(the bottom part of their knee).                                          
warming ambient air in the heating unit, and then a blower pushes the air through a 
hose into a perforated blanket placed over the patient’s chest and arms. Id. ¶¶ 4–5.  

Plaintiff  claims  that  the  Bair  Hugger  injured  her  by  introducing 
contaminants into her open surgical wound, leading to a Staphylococcus aureus 
(“S. aureus”) infection that required intervention, management, and two additional 

surgeries.  Id.  ¶  26;  Dkt.  53  ¶¶  90–95. Ms.  Robinson  was not  involved  in  the 
decision to use the Bair Hugger system during her surgery and was not aware that 
the product had been used until months later. Dkt. 75 ¶ 27. The initial decision to 
use the Bair Hugger system in Ms. Robinson’s surgery was the responsibility of 

her anesthesiologist, Dr. Calvin Kim. Id. ¶ 28. However, Dr. Shah, as the surgeon, 
was the ultimate decision-maker with the authority to overrule the decisions of 
other operating room (“OR”) staff. Dkt. 83 ¶ 35. Dr. Kim has worked with Dr. 

Shah in prior surgeries and was never ordered to stop using the Bair Hugger in 
Plaintiff’s  ORIF  surgery.  Dkt.  75  ¶  33.  Nor  has  Dr.  Kim  ever  experienced  a 
scenario  in  which  Dr.  Shah  was  involved  in  the  anesthesiologist’s  decision 
regarding the use of a warming device. Id. ¶ 34.                          

Plaintiff filed suit in the Bair Hugger MDL on August 7, 2023. Id. ¶ 40. On 
August  1,  2024,  Robinson  filed  an  Amended  Complaint  alleging  eight  claims 
against Defendant 3M: (1) negligence; (2) gross negligence; (3) failure-to-warn 

under Fla. Stat. § 768.81; (4) design defect under Fla. Stat. § 768.81; (5) breach of 
implied warranty of merchantability under Fla. Stat. § 672.314; (6) violation of 
Florida Deceptive and Unfair Trade Practices Act (“FDUTPA”); (7) misleading 

advertising under Fla. Stat. § 817.41; and (8) unjust enrichment. Dkt. 53 ¶¶ 96–
178. Plaintiff seeks compensatory and punitive damages pursuant to these claims. 
Id. ¶¶ 179–195. On March 18, 2025, Defendants filed their motions to exclude 

testimony from Plaintiff’s general and specific causation experts (Dkts. 73 & 74) 
and a motion for summary judgment (Dkt. 76). The Court will address each one in 
turn.                                                                     
           I.   Motion(s) to Exclude under Rule 702                  

Defendants have moved to exclude the testimony and opinions of Plaintiff’s 
one general causation medical expert (Dr. Yoav Golan), one general causation 
engineering expert (Dr. Said Elghobashi), and one specific causation expert (Dr. 

Golan, again) under Federal Rule of Evidence 702. The opinions of the general 
causation experts are offered to establish that the Bair Hugger can cause a non-
joint infection in ORIF surgical patients. The specific causation opinion is offered 
to establish that the Bair Hugger did, in fact, cause Plaintiff’s non-joint infection 

following ORIF surgery in 2021. See Chapman v. Procter & Gamble Distrib., 
LLC, 766 F.3d 1296, 1316 (11th Cir. 2014).                                
  a.  Legal Standard                                                 
A qualified witness may offer an expert opinion if it is more likely than not 

that “(a) the expert’s scientific, technical, or other specialized knowledge will help 
the trier of fact to understand the evidence or to determine a fact in issue; (b) the 
testimony is based on sufficient facts or data; (c) the testimony is the product of 

reliable principles and methods; and (d) the expert’s opinion reflects a reliable 
application of the principles and methods to the facts of the case.” Fed. R. Evid. 
702; see Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 597 (1993). “The 
party  offering  the  expert  testimony  bears  the  burden  of  establishing,  by  a 

preponderance  of  the  evidence,  the  expert’s  qualification,  reliability,  and 
helpfulness.” Payne  v.  C.R.  Bard,  Inc.,  606  F.  App’x  940,  942  (11th  Cir. 
2015) (citing United States v. Frazier, 387 F.3d 1244, 1260 (11th Cir. 2004) (en 

banc)). When determining the qualifications, reliability, and helpfulness/relevance 
of an expert’s testimony, “the judge performs a ‘gatekeeping’ function.” Chapman, 
766 F.3d at 1304 (quoting Daubert, 509 U.S. at 589 n.7).                  
The  first  requirement  for  the  admissibility  of  expert  testimony  is 

qualification. “A witness is qualified as an expert if he is the type of person who 
should be testifying on the matter at hand.” Moore v. Intuitive Surgical, Inc., 995 
F.3d 839, 852 (11th Cir. 2021) (citing Quiet Tech. DC-8, Inc. v. Hurel-Dubois UK 

Ltd., 326 F.3d 1333, 1341 (11th Cir. 2003)). For example, “scientific training or 
education may provide possible means to qualify, [and] experience in a field may 
offer another path to expert status.” Frazier, 387 F.3d at 1260–61. Importantly, the 

Eleventh  Circuit  has  warned  that  “the  qualifications  and  reliability  prongs  of 
Daubert are conceptually distinct inquiries that district courts may not collapse into 
each  other.”  Moore,  995  F.3d  at  853.  In  product  liability  cases,  there  is  no 

requirement “that an expert witness is qualified to testify regarding the cause of an 
injury only if he personally has used the allegedly defective product.” Id. at 854. 
Such a bright-line rule would set the qualified bar “too high” and “would bar all 
expert  medical  testimony  unless  the  expert  has  somehow  recreated  the  same 

conditions that the patient was under.” Id. (alterations accepted) (citing Adams v. 
Lab. Corp. of Am., 760 F.3d 1322, 1335 (11th Cir. 2014)).                 
Next, “[a]n expert opinion is reliable if it was arrived at through, among 

other things, a scientifically valid methodology.” Id. at 852 (citation omitted). The 
Eleventh Circuit has identified four factors to guide district judges in assessing the 
reliability prong of an expert’s methodology:                             
(1) whether the expert’s methodology has been tested or is capable of 
being tested; (2) whether the theory or technique used by the expert 
has been subjected to peer review and publication; (3) whether there is 
a known or potential error rate of the methodology; and (4) whether  
the technique has been generally accepted in the relevant scientific 
community.                                                           

Chapman,  766  F.3d  at  1305  (quoting  United  Fire  &  Cas.  Co.  v.  Whirlpool 
Corp., 704 F.3d 1338, 1341 (11th Cir. 2013) (per curiam)). While this inquiry is “a 
flexible one,” the focus “must be solely on principles and methodology, not on the 
conclusions that they generate.” Daubert, 509 U.S. at 594–95. “‘But conclusions 

and methodology are not entirely distinct from one another’; neither Daubert nor 
Federal Rule of Evidence 702 requires a trial judge ‘to admit opinion evidence that 
is connected to existing data only by the ipse dixit of the expert.’” Chapman, 766 

F.3d at 1305 (quoting Gen. Elec. Co. v. Joiner, 522 U.S. 136, 141–43 (1997)). 
“Instead, the judge is free to conclude that there is simply too great an analytical 
gap between the data and the opinion proffered.” Id. at 1305 (citing Hendrix ex rel. 
G.P. v. Evenflo Co., 609 F.3d 1183, 1194 (11th Cir. 2010) (internal quotations 

omitted)).                                                                
Third, under the relevance prong, expert testimony must be “relevant to the 
task at hand” by “logically advance[ing] a material aspect” of the case. Daubert at 

591. In other words, the “relationship must be an appropriate ‘fit’ with respect to 
the offered opinion and the facts of the case.” McDowell v. Brown, 392 F.3d 1283, 
1299 (11th Cir. 2004) (citing Daubert, 509 U.S. at 591). “[T]here is no fit where a 
large analytical leap must be made between the facts and the opinion.” Id. (citing 

Gen. Elec. Co., 522 U.S. at 146). Again, the trial court “may conclude that there is 
simply too great an analytical gap between the data and the opinion proffered.” 
Gen. Elec. Co., 522 U.S. at 146.                                          
Finally, the district court’s gatekeeper role is not supposed to “supplant the 
adversary system or the role of the jury.” McDowell, 392 F.3d at 1299 (citing 

Allison v. McGhan Med. Corp., 184 F.3d 1300, 1311 (11th Cir. 1999)). Instead, 
“vigorous  cross-examination,  presentation  of  contrary  evidence,  and  careful 
instruction on the burden of proof are the traditional and appropriate means of 

attacking shaky but admissible evidence.” Id. (internal quotations omitted).   
  b.  Analysis                                                       
Defendants challenge the admissibility of testimony by Plaintiff’s general 
and specific causation experts. Dkts. 73 & 74. A plaintiff seeking to establish the 

causation  element  of  a  products  liability  claim  must  present  admissible  expert 
testimony supporting both general causation and specific causation. Chapman, 766 
F.3d at 1316 (stating that, to prove a product caused the plaintiff’s injury, the 

plaintiff was “required to have Daubert-qualified, general and specific-causation-
expert testimony that would be admissible at trial to avoid summary judgment” 
(emphasis in original)); see Kilpatrick v. Breg, Inc., 613 F.3d 1329, 1334 n.4 (11th 
Cir.  2010);  McClain  v.  Metabolife  Int’l,  Inc.,  401  F.3d  1233,  1239  (11th  Cir. 

2005).                                                                    
General  causation  refers  to  whether  the  product  can  cause  the  injury  in 
question. Kilpatrick, 613 F.3d at 1334 n.4. Specific causation refers to whether the 

product did in fact cause the plaintiff's injury. Id. General causation is proven with 
expert  testimony  that  first  “rules  in”  possible  causes  of  the  plaintiff’s  injury. 
Hendrix, 609 F.3d at 1195 (“[T]he district court must ensure that, for each possible 

cause the expert ‘rules in’ at the first stage of the analysis, the expert’s opinion on 
general  causation  is  derived  from  scientifically  valid  methodology.”  (citation 
omitted)). Then, a specific causation expert must “rule out” other potential causes 

based on additional evidence, tests, or analysis, leading to a conclusion that the 
remaining possible cause is (more likely than not) the actual cause. See Chapman, 
766 F.3d at 1309–10; Kilpatrick, 613 F.3d at 1342–43. Specific causation can be 
established  by  experts  using  a  methodology  known  as  differential  etiology 

(sometimes  referred  to  as  “differential  diagnosis”). See  Chapman,  766  F.3d  at 
1308–09.                                                                  
        i.  Motion to Exclude Plaintiff’s General Causation Experts  

“General causation refers to the ‘general issue of whether a substance has 
the potential to cause the plaintiff’s injury.’” Chapman, 766 F.3d at 1306 (quoting 
Guinn v. AstraZeneca Pharms. LP, 602 F.3d 1245, 1248 n.1 (11th Cir. 2010)). As 
discussed above, this analysis can be done with expert testimony that first “rules 

in” possible causes. Thelen v. Somatics, LLC, No. 8:20-CV-1724-TPB-JSS, 2023 
WL 3947945, at *3 (M.D. Fla. June 12, 2023).                              
In Defendants’ motion to exclude Plaintiff’s general causation experts, 3M 

argues  that  Plaintiff  has  failed  to  meet  the  relevance  prong  of  Rule  702. 
Specifically, unlike the majority of cases in the Bair Hugger MDL, this case does 
not  involve  a  periprosthetic  joint  infection  (“PJI”)  following  a  knee  or  hip 

prosthetic  joint  arthroplasty  (“PJA”).  Dkt.  73  at  1.  As  such,  Plaintiff’s  expert 
opinions that the Bair Hugger system causes infections in tibia repair surgeries or 
an ORIF procedure are not appropriate since much of the scientific evidence (from 

the  Bair  Hugger  MDL)  does  not  “fit”  this  case.  Id.  Plaintiff  has  two  expert 
witnesses who will offer general causation testimony: Dr. Said Elghobashi and Dr. 
Yoav Golan. See Dkt. 79 at 1, 3.                                          
            1.  Dr. Said Elghobashi                                  

Dr. Said Elghobashi is an engineering expert in the field of computational 
fluid dynamics (“CFD”). Dkt. 73 at 2. As part of the larger Bair Hugger MDL, Dr. 
Elghobashi developed a CFD simulation that used a three-dimensional design to 

replicate  an  OR  and  analyze  how  forced-air  warming  devices  impact  the 
performance of ultra-clean ventilation systems. See Dkt. 79-1 at 2, 7–11.2 The 
results of this simulation showed that with the Bair Hugger’s blower on, “a large 
number of squames [human skin cells large enough to carry bacteria] are lifted 

upwards by the rising thermal plumes . . .  [which] are lifted above the surgeons[’] 
heads and are blown towards the [operating theater] by the downward moving 
ventilation air. . . . Statistically significant particles do enter the imaginary boxes of 

2 Dr. Elghobashi eventually published his expert report with several coauthors in a peer-reviewed journal. See X. He 
et al., Effect of Heated-Air Blanket on the Dispersion of Squames in an Operating Room, 34 Int’l J. Numerical 
Methods Biomedical Eng’g, May 2018 at 1.                                  
interest above the operating table and the patient’s knee. Few particles are also 
observed above the side tables [where surgical tools are located].” Id. at 61–62.3  

Here, Defendants do not challenge Dr. Elghobashi’s qualifications or the 
reliability of his opinions under Rule 702.4 Instead, Defendants seek to preclude 
Dr. Elghobashi’s expert report on the relevance prong, arguing that his testimony 

does not “fit” the facts of this case since his model does not show “how the Bair 
Hugger system would impact airflow in the context of Robinson’s specific type of 
surgery  (ORIF).”  Dkt.  73  at  2.  Plaintiff  responds  by  noting  that  while  Dr. 
Elghobashi’s study was modeled after a knee surgery, the study still “specifically 

looked at four different areas within the OR[:] areas over two side tables, the entire 
operating theater (including the patient’s entire body), and the surgical area in 
particular (which happened to be the patients knee area in the model). The study 

found that the [Bair Hugger] blew squames into all four areas.” Dkt. 79 at 8–9.  
Here,  the  Court  agrees  with  Plaintiff  and  rejects  Defendants’  relevance 
challenge to Dr. Elghobashi’s report. Defendants’ effort to differentiate the CFD 

3 More specifically, approximately three million 10-μm-sized squames were placed on the floor of the model OR 
around the operating table (on average, a person sheds about ten million squames a day). Dkt. 79-1 at 42, 60–61. 
Based on mathematical equations, Dr. Elghobashi simulated whether the Bair Hugger’s thermal plumes could blow 
these 10-μm-sized squames—large enough to carry bacteria—into four “regions of interest” in the OR, including the 
surgical site itself. Id. at 55–59.                                       
4 To the extent that Defendants are challenging the reliability of Dr. Elghobashi’s report, such arguments have 
already been rejected In Re: Bair Hugger Forced Air Warming Products Liability Litigation, 9 F.4th 768, 783 n.6 
(8th Cir. 2021). While not binding on this Court, the Eighth Circuit’s ruling on the limited admissibility of Dr. 
Elghobashi’s testimony, as it relates to reliability, is persuasive and has been proven by a preponderance of the 
evidence. See id. at 782–83 (“Dr. Elghobashi set out to determine whether forced-air warming ‘play[s] a role in 
transporting squame particles to the surgical site’; his CFD model tested this hypothesis; and he found that forced-air 
warming does play a role, at least in certain OR conditions with limited airflow disruptions from other sources. So 
limited, his conclusion was tested and supported by the CFD model, and the problematic analytical gap found by the 
MDL court is gone.”).                                                     
model  used  in  Dr.  Elghobashi’s  study  from  an  ORIF  surgery  is  a  distinction 
without  a  difference,  since  Dr.  Elghobashi’s  simulation  clearly  examined  the 

distribution of squames over a significantly larger area than just the knee. The CFD 
simulated the distribution of squames over four different areas: two side tables, the 
area above the operating theater, and the area above the patient’s knee. See Dkt. 

79-1  at  56  (showing  a  figure  of  the  four  zones).  The  study  concluded  that 
“[s]tatistically significant particles do enter the imaginary boxes of interest above 
the operating table and the patient’s knee.” Id. at 62 (emphasis added); see also id. 
(“Large number of squames are seen to be above the [operating theater], several 

are surrounding the surgeons[’] hands, above the side tables, and some are very 
close  to  the  patient’s  knee  and  the  surgical  site.”).  The  Court  finds  Dr. 
Elghobashi’s expert report sufficiently “rules in” the Bair Hugger as a possible 

cause for how squames could be transported to the surgical site in ORIF surgery 
for a tibial plateau fracture (only located a couple of inches from the knee). This is 
not so large an analytical leap—or in this case, not so large a physical gap between 
a knee PJA and ORIF surgery for a tibial plateau fracture—that would exclude Dr. 

Elghobashi’s  expert  report  under  Rule  702.   See McDowell, 392  F.3d  at 
1299 (noting “there is no fit where a large analytical leap must be made between 
the facts and the opinion,” such as proffering animal studies concerning a type 

of cancer in  mice  to  establish  a  different cancer in  humans  (citing Gen.  Elec. 
Co., 522 U.S. at 146)); see also Rosenfeld v. Oceania Cruises, Inc., 654 F.3d 1190, 
1193 (11th Cir. 2011) (“[I]n most cases, objections to the inadequacies of a study 

are more appropriately considered an objection going to the weight of the evidence 
rather than its admissibility.” (citation omitted)).                      
            2.  Dr. Yoav Golan                                       

While  Dr.  Elghobashi’s  expert  testimony  is  reliable,  Plaintiff  must  still 
bridge the analytical gap between the airflow disruption theory5 and a surgical site 
infection  following  ORIF  surgery.  Put  differently,  Plaintiff’s  general  causation 
expert  needs  to  “rule  in”  bacteria-carrying  squames  as  a  potential  cause  of 

infection in an ORIF surgery. To bridge this gap, Plaintiff points to testimony from 
Dr. Yoav Golan, an infectious disease expert, who opined that bacteria landing on 
the hardware inserted  into the  tibia during  an ORIF procedure  can  cause  a S. 

aureus infection. See Dkt. 79 at 11; Dkt. 73-4 at 6 (showing Dr. Golan’s expert 
report). To support this opinion, Dr. Golan adopted the report of another expert 
witness in the larger MDL case and referenced several studies. Dkt. 73-4 at 2, 7 
(listing references and noting Dr. Golan has “reviewed the report authored by Dr. 

5 In the Bair Hugger MDL, there are two general causation theories by which the Bair Hugger could introduce 
bacteria into a surgical site to cause infection. Under the “dirty-machine theory,” the Bair Hugger is the source of the 
infection-causing bacteria, and the hose blows the bacteria out of the perforated blanket onto the surgical site. Dkt. 
73 at 3. Under the “airflow-disruption theory,” the Bair Hugger system disrupts OR airflow by blowing squames (on 
the floor) up and over the operating table into the surgical site. Id. Here, Dr. Golan’s general causation opinion is 
based on the air-flow disruption theory since he opines that the Bair Hugger system “was the likely cause” of 
Robinson’s S. aureus infection because it “generates an uplifting of air carrying particles that are contaminated with 
microbes . . . capable of causing hardware infection[,]” and “[i]t is likely that a sufficient number of these 
contaminated particles landed in the surgical field and contaminated it.” Dkt. 73-4 at 6. However, as discussed in 
further detail below, Dr. Golan cites studies that relate more to the dirty-machine theory. Regardless, the Court finds 
Dr. Golan’s general causation opinion admissible under Rule 702.          
William Jarvis from 2017 . . . [and] agree[s] with the conclusions [Dr. Jarvis] 
reached  concerning  evidence  that  the  Bair  Hugger  is  capable  of  causing 

periprosthetic joint infections. I adopt his report and supplement it with reference 
to additional studies published since 2017”).                             
Defendants, however, argue that “nothing in Dr. Golan’s report or deposition 

testimony provides a valid scientific basis to extrapolate PJA/PJI-related general 
causation  opinions  to  the  facts  here.”  Dkt.  73  at  8.  Specifically,  Dr.  Golan’s 
general  causation  testimony  is  not  reliable  since  “he  failed  to  identify  a  valid 
scientific basis to extrapolate his PJA/PJI-related general causation opinions,” and 

“he cannot alone analogize between the Bair Hugger system’s impact on airflow in 
a PJA relative to an ORIF procedure.” Id. at 8–9.                         
The Eleventh Circuit has “identified some of the scientifically valid methods 

for  establishing  general  causation,”  including  expert  opinions  based  on 
“epidemiological studies, provided the expert explains how the findings of those 
studies may be reliably connected to the facts of the particular case.” Hendrix, 609 
F.3d at 1196–97 (citation omitted); see also Rider v. Sandoz Pharms. Corp., 295 

F.3d 1194, 1198 (11th Cir. 2002) (“It is well-settled that while epidemiological 
studies may be powerful evidence of causation, the lack thereof is not fatal to a 
plaintiff’s case.”).                                                      
Here,  Dr.  Golan’s  general  causation  testimony  is  sufficiently  reliable 
under Daubert to warrant admission at trial. As discussed above, epidemiological 

studies are strong evidence of causation, and Dr. Golan’s opinion is based on at 
least two such studies. First, Dr. Golan references P.D. McGovern et al., Forced-
Air  Warming  and  Ultra-Clean Ventilation  Do  Not  Mix, 93-B  J.  Bone &  Joint 

Surgery  1537  (2011)  (“McGovern  2011”).6  See  Dkt.  73-4  at  7  (referencing 
McGovern 2011); Dkt. 73-5 (showing the McGovern 2011 study); Dkt. 79-3 at 
175:15-176:19  (Dr.  Golan  testifying  that  he  relied  on  many  different  studies, 
including McGovern 2011). Following other federal courts, the Court finds that 

McGovern 2011 is a sufficiently reliable study for Dr. Golan to base his general 
causation opinion on. See e.g., Boncher v. 3M Co., No. 5:24-CV-01403-JMG, 2025 
WL 511116, at *7 (E.D. Pa. Feb. 14, 2025) (finding the “limitations and potential 

shortcomings in [McGovern 2011] do not make the study per se unreliable, as the 
strength of the study goes to its weight, not admissibility”). Indeed, as the Eighth 
Circuit In re Bair Hugger Forced Air Warming Devices Prods. Liab. Litig., 9 F.4th 
768 (8th Cir. 2021) already concluded, “it was not necessarily unreliable for the 


6 McGovern 2011 was an observational epidemiological study that explored whether forced-air warming was 
associated with an increased rate of PJIs by comparing a group of individuals warmed convectively to a group of 
individuals warmed conductively. See Dkt. 73-5 at 1537. The study reviewed infection data from hip or knee 
replacement surgeries performed at a single hospital for a 2.5-year period. Id. at 1537, 1540. During this period, 
patients were warmed with Bair Huggers and then slowly transitioned to being warmed with conductive patient-
warming devices. Id. at 1540, 1543. The researchers found an association between the use of the Bair Hugger in 
ORs and surgical site infections, but the study “[did] not establish a causal basis” for this increased risk. Id. at 1543. 
The researchers also acknowledged other limitations, including the “infection control measures instituted by the 
hospital” and being unable to fully examine patients’ medical histories for factors associated with PJIs. Id.  
experts to rely on McGovern 2011 to draw an inference of causation just because 
the study itself recognized . . . that the association did not establish causation. So 

long  as  an  expert  does  the  work  ‘to  bridge  the  gap  between  association  and 
causation,’ a study disclaiming having proven causation may nevertheless support 
such a conclusion.” 9 F.4th at 779–80 (quoting Federal Judicial Center, Reference 

Manual on Scientific Evidence at 218 (3d ed. 2011)).                      
Second, Dr. Golan references S.H. Kim et al., Relationship Between Types 
of  Warming  Devices  and  Surgical  Site  Infection  in  Patients  Who  Underwent 
Posterior Fusion Surgery Based on National Data, 20 Neurospine 1328 (2023) 

(“Kim 2023”). See Dkt. 73-4 at 7 (referencing Kim 2023); Dkt. 104-26 (showing 
the Kim 2023 study). In Kim 2023, researchers in South Korea examined 5,406 
patients in the Health Insurance and Review Assessment Service database who 

underwent posterior lumbar fusion surgery during 2014, 2015, and 2017. Dkt. 104-
26  at  1328.  The  goal  of  the  nationwide  study  was  to  examine  the  effects  of 
warming devices on surgical site infection rates during posterior fusion surgery. Id. 
Kim  2023  found  that  “[c]ompared  with  those  not  treated  with  intraoperative 

warming devices, those treated with forced air warming devices were 1.73-fold 
more  likely  .  .  .  to  develop  [surgical  site  infection]  after  adjusting  for  all 
covariates.” Id. at 1331. Further, “an analysis of patients administered antibiotics 

21 to 60 minutes before surgery showed that the risk of [surgical site infection] 
was  5.17-fold  .  .  .  higher  in  patients  treated  with  forced  air  than  with  no 
intraoperative warming device.” Id. As such, the researchers concluded that “the 

results of the present study showing that use of forced warming devices increases 
[surgical  site  infection]  rates  are  clinically  meaningful[,]”  and  “devices  using 
[electric] conduction seemed to have more advantages in preventing [surgical site 

infection] than forced air warming device[s].” Id. at 1334.               
Critically, Defendants do not attack the reliability of Kim 2023; instead, 
Defendants contend the study does not “fit” since the study did not examine ORIF 
procedures and there is no evidence that the Bair Hugger was the warming device 

used in South Korean hospitals. Dkt. 105 at 6. While Defendants are correct about 
the limitations of Kim 2023 (examining posterior lumbar fusion surgery) to an 
ORIF procedure,7 the argument does not undermine the reliability of Dr. Golan’s 

overall general causation opinion, since Kim 2023 is one of several studies Dr. 
Golan referenced in formulating his opinion that forced air warmers (like the Bair 
Hugger) can be a potential source of surgical site infection. Indeed, the Court finds 
Dr. Golan’s reliance on other medical studies beyond McGovern 2011 and Kim 

2023 supports his general causation opinion that the uplifting of bacteria by the 
Bair Hugger is generally capable of causing a hardware infection during an ORIF 

7 Interestingly, Defendants’ “different surgery” argument also cuts the other way in Plaintiff’s favor. Kim 2023 
provides empirical support that forced-air warmers may increase surgical site infection rates in a surgical procedure 
different from a PJA. As such, Dr. Golan opining that the Bair Hugger can be “ruled in” as a possible infection 
source in a different surgery from a PJA (i.e., an ORIF procedure) is not so large of an analytical jump as 
Defendants claim.                                                         
procedure. As Dr. Golan made clear in his deposition, his causation opinions were 
not  based  solely  on  McGovern  2011,  but  “on  [a]  multitude  of  references  and 

studies and not one particular study. . . . So my opinion is, based on all of those 
studies together, and none of those studies by itself, is the sole support to my 
opinion.” Dkt. 79-3 at 176:1-19.                                          

These additional (non-epidemiological) studies include A.J. Legg, et. al., Do 
Forced Air Patient-Warming Devices Disrupt Unidirectional Downward Airflow?, 
94-B J. Bone & Joint Surgery 254 (2012), where the authors found a statistically 
significant increase in particles measuring 5.0 μm in size over the surgical site 

when  forced-air  warming  was  used  (Dkt.  104-2  at  255–56); K.B.  Dasari,  et. 
al., Effect  of  Forced-Air  Warming  on  the  Performance  of  Operating  Theatre 
Laminar  Flow  Ventilation,  67  Anaesthesia  244  (2012),  where  the  researchers 

investigated whether the floor-to-ceiling temperatures around a draped manikin in 
a  laminar-flow  theatre  differed  when  using  three  types  of  warming  devices, 
including  the  Bair  Hugger,  and  found  that  forced-air  warming  “generates 
convection current activity in the vicinity of the surgical site. . . . [and] these 

currents may disrupt ventilation airflows intended to clear airborne contaminants 
from the surgical site” (Dkt. 104-20 at 244, 248); A.M. Wood, et al., Infection 
Control Hazards Associated with the Use of Forced-Air Warming in Operating 

Theatres, 88 J. Hosp. Infection 132 (2014), where the authors concluded, after a 
review of the literature, that forced-air warming “does contaminate ultra-clean air 
ventilation,”  though  acknowledging  that  “current  research”  had  not  shown  a 

“definite link” between forced-air warming and surgical-site infections (Dkt. 83-21 
at  132);  V.  Lange,  Forced  Air  Contamination  Risk  in  the  OR,  73  Annals  of 
Medicine  and  Surgery  1  (2022),  where  the  author  conducted  a  retrospective-

research  correlation  on  a  previous  2018  study  on  forced  air-warming 
contamination  and  found  that  “[forced  air  warming]  device-component 
contamination is a real risk in the OR. . . . Based on the correlation between 
pathogen and [surgical site infection] risk, it has been determined that infection 

risk  may  be  eliminated  through  the  use  of  alternate  patient-warming 
technologies/techniques”  (Dkt.  104-15  at  3);  J.G.  Brock-Utne,  et  al.,  Potential 
Sources of Operating Room Air Contamination: A Preliminary Study, 113 J. of 

Hosp. Infection 59 (2021), where the researchers specifically looked at two forced 
air-warmers (Neptune Surgical Suction system and the Bair Hugger), observed 
higher bacterial counts in the Bair Hugger outlet hose that blows air than in the 
surrounding  OR  air,  and  concluded  that  “the  [Bair  Hugger]  is  likely  a  direct 

contributor to an increased burden of airborne microbes in the OR” (Dkt. 104-16 at 
61, 63); and Mark Albrecht, et al., Forced-Air Warming Blowers: An Evaluation of 
Filtration  Adequacy  and  Airborne  Contamination  Emissions  in  the  Operating 

Room, 39 Am. J. Infection Control 321 (2011), where the authors compared five 
new  Bair  Hugger  intake  filters  to  52  Bair  Hugger  filters  currently  in  use  at 
hospitals  and  found  “[f]ifty-eight  percent  of  the  [forced  air-warming]  blowers 

evaluated  were  internally  generating  and  emitting  airborne  contaminants,  with 
microorganisms  detected  on  the  internal  air  path  surfaces  of  92.3%  of  these 
blowers[,]” including S. aureus (Dkt. 104-4 at 321).                      

Importantly, Defendants do not challenge the reliability of these studies, 
some of which have been cited by Amando and another district court (involved in 
Bair Hugger litigation) to support general causation under an airflow-disruption 
and dirty-machine theory. See Amando, 9 F.4th at 781–87; Boncher, 2025 WL 

511116,  at  *7–8.  Instead,  Defendants  contend  “Dr.  Golan  offers  no  scientific 
support  for what  amounts  to  a  series  of  analytical  leaps”  between  the  various 
studies and an ORIF procedure. Dkt. 73 at 9. But, as the Court’s sampling of the 

references show, Dr. Golan’s plausible mechanism (i.e., airflow-disruption theory 
from Dr. Elghobashi) in explaining the association between the use of the Bair 
Hugger in an OR and increased particle counts over the surgical site of an ORIF 
surgery (which can be a source of infection) is based on reliable methodology that 

draws causal inferences from associations identified in peer-reviewed scientific 
literature and case studies.                                              
As for the differences between ORIF and PJA surgery, Dr. Golan testified he 

was confident the literature he relied on showed “that the Bair Hugger in Ms. 
Robinson’s OR in May of 2021 was capable of doing the same thing that it does in 
other  cases  involving  a  total  joint  arthroplasty[.]”  Dkt.  79-3  at  153:17-23. 

Specifically, Dr. Golan articulated that:                                 
the  operation  of  the  Bair  Hugger  leads  to  contamination  of  the 
operating room with particles, so that there is a much, much larger  
number of particles in the operating room air. It interferes with the 
different measures that we use in the operating room to reduce the   
number of loading particles.                                         

And we know that many of those particles are contaminated, and it    
leads to landing of contaminated particles in the sterile field, whatever 
the  sterile  field  is  --  whether  it’s  an  exposed  tibia  or  whether  it's 
exposed end of the tibia -- you have to understand knee replacement  
surgery. It’s the tibia that's exposed.                              

The only other thing that's exposed is the femur, and here the tibia is 
exposed. And in addition to that, there’s hardware that's exposed. And 
it doesn’t matter at all whether the hardware has this shape or that 
shape.                                                               

So from my perspective, all the information that I saw that relates to 
the  Bair  Hugger  contaminating  the  operating  room  was  just  as 
applicable  to  tibia  fractures  as  it  is  to  prosthetic  joint  infection 
surgery.                                                             

Id. at 154:2-155:2. As such, Dr. Golan concluded that the “infection risk” and 
“what affects the infection risk” in both types of surgeries are “very similar.” Id. at 
247:9-248:15.                                                             
Defendants, of course, strongly dispute Dr. Golan’s finding that the type of 
hardware is not a significant factor in considering the infection risk. See Dkt. 105 
at 2–4. Indeed, Defendants persuasively argue that the hardware in a PJA/total 
joint arthroplasty—two large metal implants: a polyethylene spacer and a patella 
implant—provides a large, non-vascularized surface for bacteria to adhere to when 

it lands on the exposed surgical site. Id. at 3. Conversely, the hardware in Ms. 
Robinson’s ORIF surgery consists of thinner plates and screws that are buried into 
vascularized  bone  and  surrounded  by  vascularized  tissue,  resulting  in  a  less 

exposed  surface  area  that  impacts  the  ability  of  bacteria  to  attach.  Id.  at  4. 
Nevertheless, the Court admits Dr. Golan’s sufficiently reliable testimony since the 
“traditional and appropriate means of attacking shaky but admissible evidence” is 
for Defendants to present to the jury “contrary evidence” on the different infection 

risks in PJA and ORIF procedure. Allison, 184 F.3d at 1311 (citing Daubert, 509 
U.S. at 596).8                                                            
At bottom, this is not a case where the gap between the scientific studies and 

the  general  causation  opinion  is  “simply  too  great.”  Hendrix,  609  F.3d  1203 
(noting the expert “did not even attempt to provide any evidence to support a 
general  causal  link  between  traumatic  brain  injury  and  [Autism  Spectrum 


8 Defendants also fault Dr. Golan for simply “agree[ing]” and “adopt[ing]” the conclusion of Dr. Jarvis concerning 
the Bair Hugger causing periprosthetic joint infections. Dkt. 105 at 12. While Defendant is correct that “[e]xpert 
opinions ordinarily cannot be based upon the opinion of others[,]” Am. Key Corp. v. Cole Nat. Corp., 762 F.2d 1569, 
1580 (11th Cir. 1985), Dr. Golan’s general causation opinion is not simply a regurgitation of Dr. Jarvis’s findings. 
Dr. Golan assessed the validity of Dr. Jarvis’s report by reviewing the cited materials in the Jarvis report and then 
compiled his own report (based on empirical sources) to opine that airborne microbes caused a surgical site infection 
following Ms. Robinson’s surgery. See Dkt. 79-3 at 132:15-133:15 (Dr. Golan testifying he received Dr. Jarvis’s 
report and “reviewed the references used for the Jarvis report, because I wouldn’t take the Jarvis report just because 
it’s the Jarvis report”); Schoen v. State Farm Fire & Cas. Co., 638 F. Supp. 3d 1339, 1349 (S.D. Ala. 2022) (“Rule 
703 does not permit an expert to simply repeat or adopt the findings of another expert without attempting to assess 
the validity of the opinions relied upon.” (citing La Gorce Palace Condo. Ass’n, Inc. v. Blackboard Specialty Ins. 
Co., 586 F. Supp. 3d 1300, 1306 (S.D. Fla. 2022)).                        
Disorder]. He presented no medical literature, described no relevant physiological 
process, and provided no other support for his conclusion that traumatic brain 

injury can cause autism”). Although the Court is to serve as a gatekeeper to ensure 
the requirements of qualification, reliability, and fit are met, “[t]he judge’s role is 
to [also] see that the jury hears reliable and relevant evidence[.]” McDowell, 392 

F.3d at 1299. Thus, Defendants’ concerns regarding the strength of the studies that 
Plaintiff’s general causation experts relied on or the conclusions they have drawn 
from them as applied in the ORIF context can be challenged on cross-examination 
and with the presentation of contrary evidence during their case-in-chief. Plaintiff’s 

general causation opinions are reliable and admissible under Rule 702.    
       ii.  Motion to Exclude Plaintiff’s Specific Causation Expert  
Next, Defendants  move  to  exclude  the specific causation opinion of Dr. 

Yoav Golan. Dkt. 74 at 3. First, 3M contends that Dr. Golan’s specific causation 
theory—that  the  Bair  Hugger  can  cause  airflow  disruptions  that  moved 
contaminated squames into Ms. Robinson’s surgical site, causing her infection—
should be excluded since Dr. Golan is unqualified to offer an opinion on airflow 

disruption, his opinions are based on unreliable methods, and there is insufficient 
facts and data to support his causation theory. Id. Second, Dr. Golan’s differential 
diagnosis allegedly “fails to properly ‘rule in’ the Bair Hugger system (the source 
he ultimately implicates)” and “rule out” other surgical site infection sources. Id. 
The Court addresses each argument in turn.                                

Beginning  with  Dr.  Golan’s  qualifications,  the  Court  finds  Dr.  Golan  is 
qualified to provide expert opinion on infectious diseases. Indeed, with over three 
decades of education, training, and experience in the field of infectious diseases, 

Dr. Golan is undoubtedly qualified to offer expert testimony on the most likely 
cause of Ms. Robinson’s infection. See Dkt. 80-2 (showing Dr. Golan’s CV). As to 
Defendants’ arguments that Dr. Golan is unqualified to give opinions on how the 
Bair Hugger system disrupted the airflow in Ms. Robinson’s surgery, see Dkt. 74 

at 8, the Court finds such an argument is without merit. Defendants confused the 
distinction between an expert’s qualifications and the reliability of the proffered 
opinion.                                                                  

As  discussed  previously,  “qualifications  and  reliability  prongs 
of Daubert are conceptually distinct inquiries” that cannot be collapsed into each 
other. Moore, 995 F.3d at 853. In Moore, a district court erroneously found that a 
medical doctor was not qualified to testify because he had not used “the Intuitive 

robotic tools at issue and because he could not describe the differences between 
those tools and the traditional laparoscopic instruments.” Id. The Eleventh Circuit, 
however, reversed the district court since the doctor’s familiarity with the product 

at issue goes to the reliability of the opinion, not the expert’s qualification. Id. at 
858. Indeed, the medical doctor was “qualified to perform a differential etiology on 
a patient who suffered a thermal injury during a hysterectomy performed with a da 

Vinci robot[,] not because of his familiarity with the robot, but because of his 
familiarity with differential etiologies in the context of gynecological procedures.” 
Id. at 853.                                                               

Here,  as  in  Moore,  Dr.  Golan  is  qualified  as  an  expert  to  perform  a 
differential etiology on Ms. Robinson’s infection, not because of his familiarity 
with  the  Bair  Hugger  and  airflow  disruption  in  an  OR,  but  because  of  his 
familiarity with the (infectious disease) analysis he was tasked with performing. 

While Defendants are correct that Dr. Golan has repeatedly testified he is not 
qualified  to  opine  on  OR  airflow  disruptions,  see  e.g.,  Dkt.  80-3  at  232:3-6 
(testifying he is “definitely not an expert” in airflow, “but I understand the air flow 

in the operating room to some extent”), this concession does not mean Dr. Golan 
should  be  excluded  from  performing  the  “task  at  hand”—i.e.,  performing  a 
differential etiology on a patient who suffered a S. aureus infection following a 
ORIF surgery. See Daubert, 509 U.S. at 597.                               

To  complete  this  task  within  his  expertise,  Dr.  Golan  relied  upon  Ms. 
Robinson’s  medical  records,  medical  literature,  and  the  reasonable  opinions  of 
other  experts  who  are  qualified  to  opine  about  airflow  disruption  (i.e.,  Dr. 

Elghobashi) to determine that bacteria displaced by the Bair Hugger is a potential 
cause of Plaintiff’s infection. See Dkt. 74-1 at 6, 7 (“Peer-reviewed publications 
confirm that Bair Hugger generates an uplifting of air carrying particles that are 

contaminated with microbes that are virulent and capable of causing hardware 
infection” and referencing Dr. Elghobashi’s published report in X. He et al., Effect 
of Heated-Air Blanket on the Dispersion of Squames in an Operating Room, 34 

Int’l J. Numerical Methods Biomedical Eng’g, May 2018 at 1); see also Dkt. 80-3 
at  130:22-133:15  (discussing  Dr.  Jarvis’s  report  and  the  references  used  to 
determine  whether  the  Bair  Hugger  could  be  a  plausible  cause  of  Plaintiff’s 
infection). As discussed above in the general causation section of this Order, the 

Court has already found Dr. Elghobashi’s report to be admissible, and Dr. Golan 
could  rely  on  other  empirical  sources  when  “ruling  in”  the  Bair  Hugger  as  a 
potential  source  of  infection.  Defendants’  argument  about  Dr.  Golan’s  lack  of 

knowledge and expertise on OR airflow, including the Bair Hugger’s impact on 
OR airflow, is a credibility dispute that should be decided “within the crucible of 
cross-examination,” not by this Court at the Daubert stage. Moore, 995 F.3d at 
857; see also Quiet Tech., 326 F.3d at 1342 (noting that shortcomings regarding 

knowledge  of  the  specific  product  at  issue  do  not  bear  on  an  expert’s 
qualifications).                                                          
Defendants, however, argue that even if Dr. Golan is qualified, his airflow 

disruption opinions are “based on unreliable methods and insufficient facts and 
data.” Dkt. 74 at 10. Specifically, Defendants fault Dr. Golan for failing to take 
“meticulous care to track and account for [the OR design, layout, and sources of air 

turbulence] in Robinson’s May 2021 surgery[,]” not being an orthopedic surgeon, 
and having “little understanding of the different devices that are used in any given 
orthopedic procedure, let alone what happens in an OR during such procedures.” 

Dkt. 74 at 12. But such an argument sets an evidentiary burden that is much “too 
high.” Moore, 995 F.3d at 854. Rule 702 does not require Dr. Golan to be a 
surgeon who has used the Bair Hugger in ORIF surgeries in order to provide a 
differential etiology of Ms. Robinson’s infection. Indeed, the Eleventh Circuit has 

already rejected Defendants’ way of reasoning since it would seemingly “bar all 
expert  medical  testimony  unless  the  expert  has  somehow  recreated  the  same 
conditions that the [patient] was under[,] . . . [and] Rule 702 does not impose such 

a requirement.” Adams, 760 F.3d at 1335–36; see also Moore, 995 F.3d at 854 
(“Our caselaw does not support a bright line rule that an expert witness is qualified 
to  testify  regarding  the  cause  of  an  injury  only  if  he  personally  has  used  the 
allegedly defective product.”).                                           

Additionally, the list of airflow disruption sources that Dr. Golan failed to 
consider in his report—Brandon Hospital’s OR and HVAC schematics, Brandon 
Hospital’s protocols on sterility or infection control, the deposition transcripts of 

Dr. Shah and Dr. Kim, the drape and fluoroscopy (x-ray machine) used in Ms. 
Robinson’s surgery, and 3M’s expert reports (Dkt. 74 at 13)—“are of a character 
that impugn the accuracy of [Dr. Golan’s] results, not the general scientific validity 

of [differential etiology].” Quiet Tech, 326 F.3d 1345. Defendants’ “identification 
of such flaws in generally reliable scientific evidence is precisely the role of cross-
examination.” Id. Dr. Golan’s alleged failure to consider these other variables of 

airflow disruption during surgery is an argument that goes to the weight, not the 
admissibility, of the evidence offered. Id. at 1345–46 (“Normally, failure to include 
variables will affect the analysis’ probativeness, not its admissibility.” (quoting 
Bazemore v. Friday, 478 U.S. 385, 400 (1986)) (citation modified)).       

Next,  Defendants  challenge  the  reliability  of  Dr.  Golan’s  differential 
diagnosis itself, as it allegedly “fails to apply reliable principles and methods to 
‘rule in’ the Bair Hugger system as the source of Robinson’s S. aureus infection[,] 

[and] he fails to ‘rule out’ endogenous sources of S. aureus as the cause of her 
infection.” Dkt. 74 at 15. The Court disagrees.                           
“If properly followed, differential diagnosis can be a reliable methodology 
under  Daubert.”  Arevalo  v.  Mentor  Worldwide  LLC,  No.  21-11768,  2022  WL 

16753646, at *4 (11th Cir. Nov. 8, 2022) (citing Chapman, 766 F.3d at 1309). 
Differential diagnosis methodology is “a medical process of elimination whereby 
the possible causes of a condition are considered and ruled out one-by-one, leaving 

only one cause remaining.”  Chapman, 766 F.3d at 1308 (quotation marks  and 
citation  omitted).  The  methodology  requires  three  steps:  “(1)  the  patient’s 
condition is diagnosed, (2) all potential causes of the ailment are considered, and 

(3) differential etiology is determined by systematically eliminating the possible 
causes.” Id. (citation omitted). To be reliable, the expert’s differential diagnosis 
“need not rule out all possible alternative causes” but “must at least consider other 

factors that could have been the sole cause of the plaintiff’s injury.” Id. at 1308–09 
(quotation marks and citation omitted). Indeed, “an expert does not establish the 
reliability of his techniques or the validity of his conclusions simply by claiming 
that he performed a differential diagnosis on a patient.” McClain, 401 F.3d at 1253. 

“[A]  differential  diagnosis  that  fails  to  take  serious  account  of  other  potential 
causes may be so lacking that it cannot provide a reliable basis for an opinion on 
causation.” Guinn, 602 F.3d at 1253 (quotation marks and citation omitted). 

As  an  initial  matter,  Defendants’  arguments  about  Dr.  Golan  failing  to 
reliably “rule in” the Bair Hugger as a potential source of infection are a rehashing 
of Defendants’ general causation motion. See Dkt. 73 at 8; Dkt. 74 at 15; see 
Thelen, 2023 WL 3947945, at *3 (“General causation addresses how the possible 

causes are ‘ruled in’ in the first place, and cannot be established by differential 
diagnosis.”).  The  Court  has  already  previously  discussed  at  length  why  Dr. 
Elghobashi and Dr. Golan’s general causation opinions properly “ruled in” the Bair 

Hugger as a potential source of surgical site infection.                  
Turning to Defendants’ argument on whether Dr. Golan properly “ruled out” 
endogenous sources of S. aureus as the cause of Ms. Robinson’s infection, the 

Court finds Dr. Golan has shown he “at least consider[ed] other factors that could 
have been the sole cause of the plaintiff’s injury.” Chapman, 766 F.3d at 1309. Dr. 
Golan does not merely declare his specific causation opinion ipse dixit without 

citing  other  relevant  medical  information  that  establishes  a  causal  connection 
between the Bair Hugger device and Plaintiff’s infection during ORIF surgery. See 
generally Dkt. 80-1. Defendants, however, articulate three “obvious” alternative 
sources of Ms. Robinson’s S. aureus infection that Dr. Golan allegedly failed to 

consider: the presence of S. aureus on Ms. Robinson’s skin during surgery, a post-
surgery infection, and a breach of infection control measures during surgery. Dkt. 
74 at 17–20. The Court disagrees. A review of Dr. Golan’s report and deposition 

demonstrates that he adequately considered these alternative sources before ruling 
them out.                                                                 
First,  a  review  of  Dr.  Golan’s  expert  report  demonstrates  that  he 
acknowledged Ms. Robinson’s skin flora (during surgery) as a possible source of 

infection and then properly ruled it out:                                 
Because S. aureus, CNS, Corynebacterium and Propionibacterium are    
commonly found on humans’ skin, they are common pathogens in         
hardware infections. Each of these and other infecting pathogens can 
arise from an endogenous or exogenous source. Endogenous sources     
include the patients’ own flora- from their skin, mucous membranes,  
gastrointestinal tract, or seeding from a distant focus of infection via a 
bloodstream infection. In the case of hardware infection development, 
endogenous causes are implicated when the surgical site never heals  
and  becomes  infected  immediately  after  surgery,  usually  due  to 
problems with wound healing or the development of a bloodstream      
infection with secondary seeding of the hardware. . . .              

In support of the development of a bone hardware infection that is the 
result of contamination of the surgical field during surgery and to  
decipher whether any intra-surgery factor may be responsible for such 
contamination, the following questions need to be considered: . . . b) 
Was the hardware infection acquired during surgery or after surgery? . 
. .                                                                  

Ms. Robinson underwent her first right knee surgery on 5/6/21. Prior 
to the surgery, there were no local or systemic signs of infection and 
there were no violations to the skin’s integrity. During the surgery, the 
tissues appeared non-inflamed with no signs of infection, supporting a 
decision to proceed and place a plate and screws to repair the fracture. 
. . .                                                                

b) Was Ms. Robinson’s hardware infection acquired before the 5/6/21  
surgery,  during  the  5/6/21  surgery  or  was  it  acquired  after  that 
surgery? At the time of her 5/6/21 surgery, there were no signs of   
infection and none of her care providers suspected an infection. Intra-
operative  findings  on  5/6/21  were  inconsistent  with  an  existing 
infection at that time. It is therefore unlikely that Ms. Robinson was 
already infected on 5/6/21. After the 5/6/21 surgery, up to a few days 
before  Ms.  Robinson’s  6/16/21  follow  up  visit,  Ms.  Robinson’s 
surgical wound was healing well with no documentation of wound       
dehiscence or drainage. . . . Therefore, it is highly likely that Ms. 
Robinson’s infection was acquired during the 5/6/21 surgery.         

Dkt.  80-1  at  4–6;  see  also  Dkt.  80-3  at  186:9-192:3  (Dr.  Golan  discussing 
endogenous  flora  and  concluding  Ms.  Robinson’s  endogenous  flora  “is  a  very 
unlikely cause” of her infection). Defendant, however, contends that Dr. Golan 
could only rule out an “endogenous/direct-contact source” by quantifying that risk 
and weighing it against the risk from airborne sources. Dkt. 74 at 17. Dr. Golan’s 
failure to conduct a “quantitative assessment” of the Bair Hugger’s risk compared 

to  other  risks  in  the  OR  does  not  mean  his  differential  etiology  is  unreliable; 
instead, it means Dr. Golan’s opinion has inadequacies that should be brought up 
during cross-examination. See Quiet Tech, 326 F.3d at 1345–46. Based on the 

record, the Court cannot conclude that the elimination of Ms. Robinson’s flora as a 
potential cause of her infection was based on “subjective beliefs or unsupported 
speculation.” Chapman, 766 F.3d at 1310 (quoting Hendrix, 609 F.3d at 1197).  
Second, Dr. Golan sufficiently ruled out post-surgery inoculation from Ms. 

Robinson’s skin as a source of her infection. Defendants point out that Dr. Golan 
admitted that Ms. Robinson’s post-surgery wound dehiscence could have provided 
a pathway for deep infection, see Dkt. 74 at 19, but Dr. Golan’s admission is taken 

out of context. In Dr. Golan’s report, he fully considers Ms. Robinson’s wound 
dehiscence and ruled it out as a possible cause of infection, explaining: 
After the 5/6/21 surgery, up to a few days before Ms. Robinson’s     
6/16/21 follow up visit, Ms. Robinson’s surgical wound was healing   
well with no documentation of wound dehiscence or drainage. During   
this critical period of time post-surgery, there was no potential portal 
of entry of bacterial pathogens into the wound. A few days later, on 
7/1/21, when Ms. Robinson underwent surgery to explore the deep      
tissues,  bone,  and  hardware,  there  was  clear  evidence  of  deep 
infection affecting the hardware and the bone. The development of    
clinical signs of bone involvement, such that can be identified by a 
surgeon during surgery, requires a minimal period of 3-4 weeks to    
develop. In Ms. Robinson’s case, the first signs of wound dehiscence 
were observed approximately two weeks prior to the 7/1/21 surgery    
and not earlier. This leading time of 2 weeks would be insufficiently 
short to allow the development of clinical signs of infection in the 
bone and hardware. In addition, other intra-operative findings such as 
the  existence  of  extensive  fibrinous  tissue  is  consistent  with  an 
established infection that would have taken longer than 2 weeks to   
develop. Furthermore, even when wound dehiscence was observed,       
Ms. Robinson’s care providers did not express any concern regarding  
a deep wound, such that can lead to the bone and hardware, or the    
existence  of  a  deep  tissue  infection.  While  the  wound  dehiscence 
could have served as a contributing factor to the earlier diagnosis of 
hardware  and  bone  infection,  in  my  opinion,  for  the  reasons 
mentioned above, it is unlikely that the wound dehiscence caused the 
infection of hardware and bone. Therefore, it is highly likely that Ms. 
Robinson’s infection was acquired during the 5/6/21 surgery.         

Dkt. 80-1 at 5–6. On the topic of post-surgery infection, Dr. Golan’s deposition 
further articulated that:                                                 
Q. [D]id you rule in any of Ms. Robinson’s comorbid conditions as    
potential risk factors for her to develop an infection as part of your 
differential diagnosis?                                              

A. I looked at all her information. I considered any of her risk factors 
as factors that may increase her risk of infection in general. And in my 
differential diagnosis, I focused on the translocation of bacteria into 
the  sterile  site  and  whether  it  happened  before,  during  and  after 
surgery, because this is the question in hand.                       

Q. Did you rule out the possibility that the bacteria that caused Ms. 
Robinson's infection got into the joint after her surgery?           

A. To a -- an extent of high likelihood, I did.                      

Q. And how did you do that?                                          

A. I looked at her wound healing, particularly her immediate wound   
healing, as reflected in the medical chart, to make sure that there were 
no issues with the wound healing, particularly not over the first week 
or two, that there were no dehiscence during this period of time; that 
there were no -- no drainage during this period of time. During this 
period of time, it takes time for the deeper tissues to seal from the 
outside world. And during this period of time, if the wound wouldn't 
heal, bacteria could have penetrated the wound from the outside. I   
also looked at the way she developed her infection. I also looked at 
the operative report and what they actually observed during surgery in 
terms of the infected tissues and where was most of the infection. It 
was deeply within the deep tissues. And when I looked at all of this 
information and the totality of data, it appeared like the likelihood that 
she developed the infection after surgery is very low.               

Dkt. 80-3 at 211:23-213:13.                                               
But  Dr.  Golan’s  differential  diagnosis  did  not  stop  there.  Contrary  to 
Defendants’ assertion that Dr. Golan “ignore[d] Robinson’s multiple risk factors 
for delayed wound healing” that could have “extended the opportunity for wound 
inoculation”  post-surgery,  see Dkt. 74  at  19, Dr. Golan’s  deposition shows he 
considered Ms. Robinson’s post-surgery “noncompliance with physician orders,” 
including  her  “weight  bearing  [as]  a  risk  factor  for  wound  non-healing,”  but 
dismissed it as a cause of her infection “because her weight bearing did not lead to 
wound-healing issues, particularly not during the first two or three weeks after 
surgery, [so Dr. Golan] didn’t consider the wound non-healing to be an important 
or likely factor contributing to infection in her case.” Dkt. 80-3 at 214:20-218:10 
(showing Dr. Golan being questioned on Ms. Robinson’s weight bearing as a risk 
factor for infection and concluding “for weight bearing to serve as a risk factor for 
infection is through wound dehiscence and wound non-healing [which] happens 
early. And this hasn’t happened in this case”); see also id. at 203:13-211:2 (Dr. 
Golan also considering Ms. Robinson’s smoking and malnutrition as risk factors 
for infection). Again, Dr. Golan properly ruled out a post-surgery infection based 

on relevant medical information and his expertise as an infectious disease expert.  
Third, Dr. Golan addressed a possible breach of infection control measures 
during  surgery  and  explained  why  it  was  excluded  as  a  potential  source  of 

infection. As described in his expert report, Dr. Golan opined that:      
During the 5/6/21 surgery, [were] there any factors that are known to 
increase the risk of intra-surgery contamination? A careful review of 
all medical records revealed no evidence of a breach of any of the   
infection control measures which are practiced in the operating room 
during surgery to prevent hardware infections. Specifically, there was 
no  prolonged  pre-surgery  hospital  stay,  the  surgery  was  not  
complicated, there were no documented problems with the sterility of 
instruments or solutions which were used during surgery, and there   
was no documented breach of sterile technique by the surgeons and    
those present at surgery.                                            

Dkt. 80-1 at 6.9 In the absence of any evidence of a breach of sterile treatment of 
instruments  and  hardware,  there  is  sufficient  evidence  to  support  Dr.  Golan’s 
opinion that the hardware was the likely source of the S. aureus infection after 
being contaminated by bacteria blown by the Bair Hugger. Defendants’ argument 
that  “infection  prevention  measures”  at  the  hospital  only  “reduce  the  risk  of 
infection, [but] they do not eliminate it” is an issue that can be raised at trial, not at 
the Daubert stage. Dkt. 74 at 19.                                         

9 Additionally, Dr. Kim and Dr. Shah both testified that neither doctor recalled a breach of sterility protocol, and if 
there were a breach during Ms. Robinson’s surgery, they would have documented it in a report. See Dkt. 83-34 at 
95:3-12; Dkt. 83-38 at 149:5-19.                                          
In  sum,  Dr.  Golan’s  differential  diagnosis  sufficiently  enumerates  a 
comprehensive list of alternative causes and then systematically eliminates those 

potential causes. See Guinn, 602 F.3d at 1254. The Court finds Dr. Golan offered a 
sufficient  explanation  as  to  why  his  specific  causation  opinion—that  Ms. 
Robinson’s infection was acquired during her ORIF surgery, and that the Bair 

Hugger was the most likely cause of this infection—is reliable under Rule 702. 
        II.  Defendants’ Motion for Summary Judgment                 
In  addition  to  the  motions  to  exclude,  Defendants  bring  a  motion  for 
summary judgment on all of Plaintiff’s claims. Defendants argue that “[a]part from 

causation, many of Robinson’s claims (including gross negligence, failure-to-warn, 
implied  warranty,  violation  of  [FDUTPA],  misleading  advertising,  unjust 
enrichment,  and  punitive  damages)  fail  for  additional  reasons.”  Dkt.  76  at  2. 

Plaintiff responds, contending she has “proffered sufficient evidence to create a 
genuine issue of material fact in favor of negligence (Count I), gross negligence 
(Count II), failure to warn (Count III), defective design (Count IV) and misleading 
advertising (Count VII), as well as her prayer for punitive damages.” Dkt. 81 at 

4.10                                                                      



10 As for the other counts not listed, Plaintiff states that “Ms. Robinson does not intend to pursue her claims for 
unjust enrichment, violation of FDUTPA, and breach of implied warranty at trial and therefore does not respond to 
Defendants’ arguments on these claims.” Dkt. 81 at 4 n.2. As such, the Court grants Defendants’ motion for 
summary judgment as to Counts V, VI, and VIII.                            
  a.  Legal Standard                                                 

Summary judgment is only appropriate when there is “no genuine issue as to 
any material fact [such] that the moving party is entitled to a judgment as a matter 
of law.” Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986); Fed R. Civ. P. 56(a). 

An issue of fact is “material” if it might affect the outcome of the case under the 
governing law. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). It is 
“genuine” if the evidence could lead a reasonable jury to find for the non-moving 
party. See id.; see also Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 

574, 587 (1986).                                                          
The moving party has the burden of proving the absence of a genuine issue 
of material fact, and all factual inferences are drawn in favor of the non-moving 

party.  See  Allen  v.  Tyson  Foods  Inc.,  121  F.3d  642,  646  (11th  Cir.  1997); 
Pennington v. City of Huntsville, 261 F.3d 1262, 1265 (11th Cir. 2001) (noting a 
court  must  “review  the  facts  and  all  reasonable  inferences  in  the  light  most 
favorable to the non-moving party”). Once the moving party satisfies its initial 

burden, it shifts to the non-moving party to come forward with evidence showing a 
genuine issue of material fact that precludes summary judgment. Bailey v. Allgas, 
Inc., 284 F.3d 1237, 1243 (11th Cir. 2002); Celotex, 477 U.S. at 324; Fed. R. Civ. 
P. 56(e), (c). Speculation or conjecture cannot create a genuine issue of material 
fact. Cordoba v. Dillard’s, Inc., 419 F.3d 1169, 1181 (11th Cir. 2005).   

The court may not weigh evidence to resolve a factual dispute; if a genuine 
issue  of  material  fact  is  present,  the  court  must  deny  summary  
judgment. Hutcherson v. Progressive Corp., 984 F.2d 1152, 1155 (11th Cir. 1993). 

Likewise, the court should deny summary judgment if reasonable minds could 
differ on the inferences arising from undisputed facts. Miranda v. B & B Cash 
Grocery Store, Inc., 975 F.2d 1518, 1534 (11th Cir. 1992).                
Importantly, a district court is only required to consider “the cited materials” 

when  deciding  a  summary  judgment  motion,  Fed.  R.  Civ.  P.  56(c)(3),  and 
“[m]aking district courts dig through volumes of documents and transcripts would 
shift the burden of sifting from petitioners to the courts . . . [D]istrict court judges 

are not required to ferret out delectable facts buried in a massive record.” Chavez v. 
Sec’y Fla. Dep’t of Corr., 647 F.3d 1057, 1061 (11th Cir. 2011). “[T]here is no 
burden upon the district court to distill every potential argument that could be 
made based on the materials before it on summary judgment. Rather, the onus is 

upon the parties to formulate arguments; grounds alleged in the complaint but not 
relied  upon  in  summary  judgment  are  deemed  abandoned.”  Solutia,  Inc.  v. 
McWane, Inc., 672 F.3d 1230, 1239 (11th Cir. 2012) (per curiam) (citing Resol. Tr. 

Corp. v. Dunmar Corp., 43 F.3d 587, 599 (11th Cir. 1995) (en banc)).      
  b.  Discussion                                                     
Defendants moves for summary judgment on several grounds, arguing all of 
Ms. Robinson’s claims fail because she lacks admissible evidence of causation 

(Counts I–VIII); Florida does not recognize a stand-alone cause of action for gross 
negligence (Count II); Ms. Robinson’s failure-to-warn claim fails for lack of a duty 
to warn and lack of causation (Count III); Ms. Robinson’s misleading advertising 
claim fails because Fla. Stat. § 817.41 does not apply to personal injury cases in 

the absence of a direct transaction between the parties (Count VII); and Plaintiff’s 
prayer for punitive damages fails. Dkt. 76 at 9, 11, 16, 21. The Court will address 
each argument in turn.                                                    

        i.  General and Specific Causation                           
To prove causation under Florida law, which applies to Ms. Robinson’s tort 
claims,11 the plaintiff must introduce evidence that “it is more likely than not that 
the conduct of the defendant was a substantial factor in bringing about the result.” 

Guinn, 602 F.3d at 1256 (quoting Gooding v. Univ. Hosp. Bldg., Inc., 445 So. 2d 
1015, 1018 (Fla. 1984)). To avoid summary judgment in this products liability 
case, Ms. Robinson must have “Daubert-qualified, general and specific-causation-

11 In diversity cases, federal courts apply the substantive law of the state in which the case arose—here, Florida law. 
Pendergast v. Sprint Nextel Corp., 592 F.3d 1119, 1132–33 (11th Cir. 2010).  
expert testimony that would be admissible at trial.” Chapman, 766 F.3d at 1316; 
see also Shepard v. Barnard, 949 So. 2d 232, 233 (Fla. 5th DCA 2007) (approving 

trial court’s grant of summary judgment against plaintiff after excluding plaintiff's 
medical experts’ testimony, because the doctors were needed “to provide opinions 
regarding any causal link between the alleged injury and the medical treatment”).  

Here, for the reasons discussed above, and in light of the Court’s decision to 
deny Defendants’ motions to exclude Plaintiff’s  general and specific causation 
experts, the Court finds there is sufficient evidence of the required element of 
causation for a reasonable juror to find in Plaintiff’s favor on her tort claims. As 

such, the Court rejects Defendants’ causation arguments as to all counts.  
       ii.  Gross Negligence (Count II)                              
Defendants argue that Florida law does not allow for a “stand-alone” cause 

of action for gross negligence. Dkt. 76 at 11. Plaintiff appears to concede that her 
stand-alone gross negligence claim may not be a permitted cause of action under 
Florida law, but still asserts that Florida jurisprudence acknowledges it as a distinct 
claim. Dkt. 81 at 10 n.5 (“Plaintiff acknowledges that some courts, primarily in the 

Northern District of Florida, have held that gross negligence is not a stand-alone 
claim.”).                                                                 
Interestingly, Plaintiff fails to cite a single Florida Supreme Court or Florida 

District Court of Appeal case that demonstrates gross negligence can be pled as a 
standalone  count.  Conversely,  there  is  ample  case  law  indicating  that  gross 
negligence is not a standalone count, but rather a legal standard that must be met 

when seeking punitive damages under Fla. Stat. § 768.72(2). See Geery v. Ethicon, 
Inc., No. 6:20-CV-1975-RBD-LRH, 2021 WL 2580167, at *3 (M.D. Fla. Apr. 20, 
2021) (granting summary judgment to the Defendant on a gross negligence claim 

in light of the parties’ agreement that gross negligence “is not a standalone cause 
of action under Florida law” and noting that “[t]his does not preclude Plaintiff from 
seeking  punitive  damages  in  her  surviving  claims  under  the  gross  negligence 
standard”); Hughes-Payne v. Argon Med. Devices, Inc., No. 3:22-CV-1944-TKW-

ZCB, 2022 WL 19408078, at *2 (N.D. Fla. July 29, 2022) (“[The plaintiff] should 
also  consider  whether  it  is  necessary  or  proper  to plead ‘gross negligence’  as 
a separate stand-alone count.”);  Smith  v.  Ethicon,  Inc.,  No.  4:20-CV-394-

MW/MAF,   2020  WL  9071685,  at  *3  (N.D.  Fla.  Dec.  28,  2020)  (“[G]ross 
negligence is a heightened standard of proof to receive punitive damages under 
Florida law and not a stand-alone claim.”); Duff v. Racine, --- So.3d ----, 2025 WL 
1646730,  at  *2,  4  (Fla.  4th  DCA  June  11,  2025)  (reversing  trial  court  order 

granting the plaintiff’s motion for leave to assert a punitive damages claim since 
the  trial  court  failed  to  determine  if  there  was  sufficient  showing  of  gross 
negligence); Cleveland Clinic Fla. Health Sys. Nonprofit Corp. v. Oriolo, 357 So. 

3d 703, 706 (Fla. 4th DCA 2023) (noting a claim for punitive damages can only be 
brought when the proffered evidence meets a gross negligence standard under Fla. 
Stat. § 768.72(2)); Brady v. SCI Funeral Servs. of Fla., Inc., 948 So. 2d 976, 978–

79  (Fla.  1st  DCA  2007)  (declining  to  require  the  plaintiffs  to  plead  a  gross 
negligence count separate from their ordinary negligence count).          
As such, the Court enters summary judgment for Defendants on Count II. 

However, this does not preclude Plaintiff from seeking punitive damages in her 
surviving claims under the gross negligence standard of Fla. Stat. § 768.72(2)(b).  
       iii.  Failure-to-Warn (Count III)                             
Defendants  contend  that  Plaintiff’s  failure-to-warn  claim  fails  since  Ms. 

Robinson “cannot establish that 3M owed a duty to warn of an increased risk of 
surgical site infections with the Bair Hugger system; and [] because Robinson has 
no evidence that any purported failure to warn by 3M caused her injuries.” Dkt. 76 

at 16.                                                                    
To succeed on a failure-to-warn claim, the “plaintiff must show (1) that the 
product warning was inadequate; (2) that the inadequacy proximately caused her 
injury; and (3) that she in fact suffered an injury from using the product.” Salinero 

v. Johnson & Johnson, 995 F.3d 959, 964 (11th Cir. 2021) (first citing Eghnayem 
v. Bos. Sci. Corp., 873 F.3d 1304, 1321 (11th Cir. 2017), then citing Hoffmann-La 
Roche Inc. v. Mason, 27 So. 3d 75, 77 (Fla. 1st DCA 2009)).               
However, in cases involving medical products like the Bair Hugger, “the 
duty of a device manufacturer to warn of dangers involved in the use of a device is 

satisfied if it gives adequate warning to the physician who prescribes the device.” 
Salinero, 995 F.3d at 965 (citing Buckner v. Allergan Pharms., Inc., 400 So. 2d 
820, 823 (Fla. 5th DCA 1981) (alterations accepted)); see also Eghnayem, 873 

F.3d  at  1321.  “The  physician  acts  as  a  ‘learned  intermediary’  between  the 
manufacturer and the patient, ‘weighing the potential benefits of a device against 
the dangers in deciding whether to recommend it to meet the patient’s needs.’” 
Salinero, 995 F.3d at 965 (quoting Eghnayem, 873 F.3d at 1321). As such, to meet 

the causation element in a medical device failure-to-warn claim, “a plaintiff must 
show that her treating physician would not have used the product had adequate 
warnings been provided.” Id. Moreover, “[t]he causal chain may still be broken 

even if the manufacturer provides an inadequate warning so long as the physician 
is aware of the risks or would still recommend the device despite those risks.” Id. 
Here, Defendants argue they had no duty to warn because there were no 
risks known to them from the scientific and medical data available at the time of 

Plaintiff's surgery. Dkt. 76 at 12. To support this argument, Defendants point to a 
2017 “Safety Alert” from the FDA that reminded “health care providers that using 
thermoregulation  devices  during  surgery,  including  forced  air  thermoregulating 

systems, ha[s] been demonstrated to result in less bleeding, faster recovery times, 
and decreased risk of infection for patients.” Dkt. 83-37 at 1 (showing FDA Safety 
Alert); see Dkt. 76 at 12.                                                

However, Plaintiff points to various types of rebuttal evidence in support of 
her argument that 3M knew (or should have known) of the risk of infections from 
the use of the Bair Hugger. First, as discussed above, some of the scientific studies 

Plaintiff’s  experts  relied  on  in  reaching  their  general  causation  opinions  were 
published  before  Plaintiff’s  2021  ORIF  surgery  and  identified  an  association 
between  the  use  of  the  Bair  Hugger  and  an  increased  risk  of  airborne 
contamination. See e.g., Dkt. 73-5 at 1537 (showing the McGovern 2011 study). 

Second, Plaintiff has provided a sworn filing submitted to the FDA in January 
1996  where  3M  admitted  that  “[a]irborne  contamination  from  air  blown  intra-
operatively across the surgical wound may result in airborne contamination.” S-

Dkt. 82-1 at 3. Third, Defendants’ own Clinical Research Director acknowledged 
in 2010 that “[a]ctually, there is evidence that [forced-air warming] increases risk” 
of surgical site infections. S-Dkt. 82-4 at 2. Lastly, Plaintiff has provided evidence 
that Defendants included warning labels on the original Bair Hugger model, which 

warned of the possibility of airborne contamination and against the use of the 
machine in an OR. Dkt. 104-29 at 3–5. Construing the facts in the light most 
favorable to Plaintiff, the Court finds a reasonable jury could conclude Defendants 

had knowledge of the risk of surgical site infection from use of the Bair Hugger. 
Nevertheless,  Defendant  argues  that  even  if  Plaintiff  is  correct  about  an 
inadequate warning, Dr. Kim’s testimony severs the causal chain since he stated 

that he would not have changed his decision to use the Bair Hugger system during 
Ms. Robinson’s May 2021 surgery and would even use the Bair Hugger again if he 
had to redo Ms. Robinson’s surgery. Dkt. 76 at 15; see Dkt. 83-34 at 82:18-84:21, 

119:24-120:5. The Court disagrees. Setting aside the fact that Dr. Shah indicated 
he had ultimate decision-making authority as the surgeon, Dkt. 83-38 at 152:24-
153:3, it is undisputed that Dr. Kim (and the anesthesiology department) never 
received any warning from 3M regarding the Bair Hugger. Dkt. 83-34 at 96:10-13 

(“But at this point, there was -- there has been no warnings about using the Bair 
Hugger  as  a  warming  device  to  prevent  infection,  so  that’s  not  one  of  the 
guidelines that’s been proposed by our department.”); id. at 98:16-19 (“When was 

the last time that you looked at the instructions to see if there were any warnings or 
contraindications  related  to  the  use  of  the  Bair  Hugger?  Well,  I  can’t  say  I 
remember any of those times.”). Indeed, the deposition questions directed at Dr. 
Kim  primarily  focused  on  what  he  would  do  if  3M  provided  a  hypothetical 

warning to him about the risks associated with the Bair Hugger. See e.g., id. at 
95:25-96:4,  98:20-22.  As  such,  the  Court  cannot  even  apply  the  learned 
intermediary doctrine to determine if the warning was adequate because there was 

no warning to the physicians in this case.                                
Nor is this a case where, even if 3M provided an inadequate warning, the 
causal chain is still broken because the physician was actually aware of the risks or 

would continue using the Bair Hugger despite those risks. See Small v. Amgen, 
Inc.,  723  F.  App’x  722,  725  (11th  Cir.  2018) (explaining  that  the  learned 
intermediary doctrine applies, “regardless of the sufficiency of the warning, where 

a  learned  intermediary  has  actual  knowledge  of  the  substance  of  the  alleged 
warning and would have taken the same course of action even with the information 
the  plaintiff  contends  should  have  been  provided”  to  the  physician  (emphasis 
added)  (citation  and  quotations  omitted)).  Dr.  Kim’s  testimony  forecloses  any 

argument that he had actual knowledge of any alleged risks with the Bair Hugger, 
see Dkt. 83-34 at 72:6-75:7 (Dr. Kim testifying he is unaware of the alleged risks 
with the Bair Hugger and surgical site infections), and affirms he would no longer 

use the Bair Hugger if warned by 3M about alleged risks. Id. at 99:1-5 (“If 3M had 
warned you that the Bair Hugger was contraindicated in orthopedic procedures, 
you would no longer use it for orthopedic procedures. Would you agree with that? 
Yes, correct. Yes.”); see also id. at 95:25-96:14, 100:16-25. Dr. Shah also testified 

that he was not aware of the risks associated with the Bair Hugger and would have 
stopped using it in orthopedic surgeries if he had been warned by 3M. See Dkt. 83-
38 at 155:7-156:18. Thus, the Court finds Plaintiff has demonstrated a genuine 
dispute of material fact over her failure-to-warn claim. Defendants’ motion for 
summary judgment as to Count III is denied.                               


       iv.  Misleading Advertising Claim (Count VII)                 
Florida law prohibits any person from making or disseminating before the 

general  public  of  the  State  any  misleading  advertisement.  See  Fla.  Stat.  § 
817.41(1). A “misleading advertisement” is defined by statute as:         
[A]ny statements made, or disseminated, in oral, written, electronic, or 
printed  form  or otherwise,  to  or  before  the  public,  or  any  portion 
thereof, which are known, or through the exercise of reasonable care 
or investigation could or might have been ascertained, to be untrue or 
misleading, and which are or were so made or disseminated with the   
intent or purpose, either directly or indirectly, of selling or disposing 
of  real  or  personal  property,  services  of  any  nature  whatever, 
professional or otherwise, or to induce the public to enter into any 
obligation relating to such property or services.                    

Fla. Stat. § 817.40(5). To prove a misleading advertising claim, a plaintiff must 
show that: “(1) the representor made a misrepresentation of a material fact; (2) the 
representor knew or should have known of the falsity of the statement; (3) the 
representor intended that the representation would induce another to rely and act 
on  it;  and  (4)  the  plaintiff  suffered  injury  in  justifiable  reliance  on  the 
representation.” Akai Custom Guns, LLC v. KKM Precision, Inc., 707 F. Supp. 3d 
1273, 1286 (S.D. Fla. 2023) (citing Vance v. Indian Hammock Hunt & Riding 
Club, 403 So. 2d 1367, 1370-72 (Fla. 4th DCA 1981)).                      
Additionally,  when  the  plaintiff  is  a  consumer,  there  must  be  “direct 
reliance” on the misrepresentation. See Westgate Resorts, Ltd. v. Reed Hein & 

Associates, LLC, No. 6:18-CV-1088-ORL-31DCI, 2018 WL 5279156, at *8 (M.D. 
Fla. Oct. 24, 2018); Serv. Experts LLC v. Am. Serv. Experts, LLC, No. 5:23-CV-
199-GAP-PRL, 2023 WL 11257417, at *3 (M.D. Fla. Oct. 30, 2023) (citing Third 

Party Verification, Inc. v. Signaturelink, Inc., 492 F. Supp. 2d 1314, 1322 (M.D. 
Fla. 2007)); see also Joseph v. Liberty Nat’l Bank, 873 So. 2d 384, 388 (Fla. 5th 
DCA 2004) (“[T]he adoption of section 817.41(1) requires one seeking to maintain 
a civil action for violation of the statute to prove each of the elements of common 

law fraud in the inducement, including reliance and detriment, in order to recover 
damages.”).                                                               
Here, the parties dispute whether Section 817.41 even applies to personal 

injury claims. See Dkt. 76 at 16; Dkt. 81 at 16. To resolve this motion for summary 
judgment,  the  Court  assumes  (without  holding)  that  Plaintiff  can  bring  a 
misleading advertising claim and that she engaged in a “commercial transaction” 
with  3M.  See  Brown  v.  Oceania  Cruises,  Inc.,  No.  17-22645-CIV,  2017  WL 

10379580, at *7 (S.D. Fla. Nov. 20, 2017) (rejecting the defendant’s argument that 
a misleading advertising claim under Section 817.14 cannot be brought in personal 
injury cases since the plaintiff’s purchase of the defendant’s cruise ticket was a 

“commercial transaction”). Nevertheless, the Court grants summary judgment in 
Defendants’ favor on Count VII since Plaintiff has not proven that 3M made any 
misrepresentations or false statements in connection with an advertisement that 

was  intended  to  induce  Ms.  Robinson’s  reliance  and  ultimate  use  of  the  Bair 
Hugger in her ORIF surgery.                                               
First, the record is unclear about which material statements are at issue. The 

Amended Complaint alleges that “[t]he information distributed by Defendants to 
the public, the medical community, and Plaintiff’s healthcare providers, including 
reports,  press  releases,  advertising  campaigns,  labeling  materials,  print 
advertisements,  and  commercial  media  containing  material  representations  was 

false  and  misleading,  and  contained  omissions  and  concealed  facts  about  the 
dangers of the use of the Bair Hugger device.” Dkt. 53 ¶ 156. But Plaintiff’s 
response to the motion for summary judgment fails to point to any reports, press 

releases,  advertising  campaigns,  labeling  materials,  print  advertisements,  and 
commercial media in the record that support this allegation. Instead, the only thing 
Plaintiff cites is a single sealed exhibit to prove 3M misrepresented material facts, 
see Dkt. 81 at 19 (citing Plaintiff’s exhibit 33), but Plaintiff’s exhibit 33 is a 

confidential clinical trial protocol from 2007 by Defendant Arizant. See S-Dkt. 82-
2.  The  Court  is  unsure  whether  this  (sealed)  clinical  trial  protocol  was  even 
disseminated to the general public, much less a study that Ms. Robinson (or her 

treating physicians) relied on to use the Bair Hugger in her May 2021 surgery.  
Second,  even  assuming  the  2007  clinical  trial  protocol  is  an  adequate 
misrepresentation, Plaintiff has not shown she was injured acting in justifiable 

reliance on that misrepresentation. There is no dispute that Ms. Robinson was not 
involved in the decision to use the Bair Hugger during her May 2021 surgery and 
was not aware that a Bair Hugger had been used until months later. Dkt. 75 ¶ 27; 

Dkt. 83 ¶ 27. No reasonable jury could find that Ms. Robinson directly relied on 
any misrepresentation to use the Bair Hugger in her surgery. Plaintiff’s confusing 
citations to Dr. Golan’s expert report and deposition (without any page citations) to 
prove Ms. Robinson’s reliance do not create a genuine dispute of material fact. See 

Dkt.  81  at  19  (citing  Plaintiff’s  exhibits  34  and  37).  As  for  Ms.  Robinson’s 
physicians (Dr. Kim and Dr. Shah), Plaintiff has pointed to no evidence in the 
record that either of them relied on any misrepresentation from 3M in using the 

Bair Hugger in the May 2021 surgery. Indeed, Plaintiff cannot show any reliance 
since  her  failure-to-warn  claim  is  premised  on  the  allegation  that  no 
statements/warnings from 3M (about the Bair Hugger’s risks) were ever made to 
Dr. Shah or Dr. Kim.                                                      

Third, to the extent Plaintiff is bringing her theory of liability for misleading 
advertising on a misrepresentation by omission (either to Ms. Robinson or her 
physicians),  Section  817.41  forecloses  this  argument.  The  statute  explicitly 

references “any statement” in defining and proscribing misleading advertising, but 
there is no reference to a misrepresentation or false advertisement by omission. 
Compare Fla. Stat. § 817.40(5) (“The phrase ‘misleading advertising’ includes any 

statements made, or disseminated, in oral, written, electronic, or printed form . . 
.”), with Fla Stat. § 634.436(1) (defining false advertising of insurance policies as 
“[k]nowingly  making,  issuing,  circulating,  or  causing  to  be  made,  issued,  or 

circulated, any estimate, illustration, circular, statement, sales presentation, [or] 
omission . . .”). As another district court has already recognized:       
[i]f  the  Florida  Legislature  had  intended  that  liability  for  false 
advertising  under  section  817.41  encompass  misrepresentations  by 
omission, it could have so stated, as it has done in the context of false 
advertising in the insurance industry. But it did not, and Plaintiffs 
have not cited any case law for the proposition that false advertising 
encompasses  misrepresentations  by  omission  under  the  applicable 
Florida statute. Thus, any omission on SCI's website relating to KKM 
barrels does not rise to the level of a misrepresentation of a material 
fact for purposes of a misleading advertising claim.                 

Akai  Custom  Guns,  707  F.  Supp.  3d  at  1287–88.  Because  any  alleged 
representation by 3M did not induce Plaintiff’s reliance and use of the Bair Hugger 
in her surgery, the Court grants summary judgment for Defendants on Count VII.  
       v.  Punitive Damages                                          
Finally, Defendants argue that Plaintiff has not shown that “3M acted with 
evil  motive  or  engaged  in  intentional,  willful,  wanton,  or  reckless  conduct  in 
manufacturing  the  Bair  Hugger  system.”  Dkt.  76  at  22.  Plaintiff  responds  by 
summarily  stating,  “[b]ecause  Plaintiff  proffered  sufficient  evidence  to  survive 
summary judgment on gross negligence, Plaintiff survives summary judgment on 
punitive damages.” Dkt. 81 at 20.                                         

“A defendant may be held liable for punitive damages only if the trier of 
fact,  based  on  clear  and  convincing  evidence,  finds  that  the  defendant  was 
personally  guilty  of  intentional  misconduct  or  gross  negligence.”  Fla.  Stat.  § 

768.72(2). “Gross negligence” occurs when the defendant’s conduct is “so reckless 
or wanting in care that it constituted a conscious disregard or indifference to the 
life, safety, or rights of persons exposed to such conduct.” Id. § 768.72(2)(b). To 
be “clear and convincing,” evidence “must be of such weight that it produces in the 

mind of the trier of fact a firm belief or conviction, without hesitancy, as to the 
truth of the allegations sought to be established.” Acevedo v. State, 787 So. 2d 127, 
130 (Fla. 3d DCA 2001); Slomowitz v. Walker, 429 So. 2d 797, 800 (Fla. 4th DCA 

1983). “To avoid summary judgment, Plaintiff must point to evidence that would 
allow a reasonable jury, applying the clear and convincing standard, to find that 
punitive damages are appropriate.” Thelen v. Somatics, LLC, 672 F. Supp. 3d 1216, 
1227 (M.D. Fla. 2023) (citing Anderson, 477 U.S. at 255–56).              

Here, while it is a close call, the Court rejects Defendants’ assertion that 
there is insufficient evidence of punitive damages to survive summary judgment. 
Plaintiff has at least pointed to some evidence that could allow a reasonable jury to 

find by clear and convincing evidence that Defendants were grossly negligent. 
Indeed, there is testimony from 3M’s representative that they had some knowledge 
about the risk of surgical site infections, internal correspondences and documents 

from 3M employees that suggest that 3M was aware that some orthopedic surgeons 
had “amazing concern” about forced-air warmers moving particulates in the air, 
the removal of warning labels in early Bair Hugger models that warned against 

using  the  device  in  ORs,  and  all  the  previously  discussed  empirical  and  case 
studies showing a growing concern of surgical site infection when using forced-air 
warmers (like the Bair Hugger). See Dkt. 104-29; see also Boncher, 2025 WL 
511116, at *17 (permitting punitive damages claim under Pennsylvania law in Bair 

Hugger litigation). Taken together, this evidence amounts to more than just mere 
negligence—it creates a triable issue of fact for the jury as to whether Defendants’ 
conduct is grossly negligent under a clear and convincing standard. Drawing all 

inferences from this evidence in Plaintiff’s favor, a reasonable jury could find 
Defendant acted with reckless indifference to the safety of patients. Defendants’ 
motion for summary judgment is denied on Plaintiff’s prayer for punitive damages.  
                     CONCLUSION                                      

Accordingly, it is hereby ORDERED and ADJUDGED that:                 
1.  Defendants’ Motion to Exclude Plaintiff’s General Causation Experts, 
  Dkt. 73, is DENIED.                                                
2.  Defendants’  Motion  to  Exclude  Specific  Causation  Opinions  of 
  Plaintiff’s Expert Dr. Yoav Golan, Dkt. 74, is DENIED.             

3.  Defendants’ Motion for Summary Judgment, Dkt. 76, is GRANTED in  
  part and DENIED in part.                                           
     a.  Summary judgment is GRANTED on Counts II, V, VI, VII, and   

       VIII.                                                         
     b.  Summary judgment is DENIED on Counts I, III, and IV.        
     c.  Plaintiff Robinson is also permitted to bring her prayer for punitive 
       damages under Fla. Stat. § 768.72. See Dkt. 53 at 28.         

DONE AND ORDERED at Tampa, Florida, on July 23, 2025.                

                         /s/ William F. Jung                                          
                         WILLIAM F. JUNG                             
                         UNITED STATES DISTRICT JUDGE                


COPIES FURNISHED TO:                                                      
Counsel of Record