A California Court of Appeal decision recognizing an unusual and potentially far-reaching negligence duty for product manufacturers is now before the California Supreme Court. In the 
Gilead Tenofovir Cases, the Court held that, in “appropriate circumstances,” a manufacturer’s duty of reasonable care to users of its product can extend beyond the traditional obligation not to place a defective product into the stream of commerce. The decision may have wide implications for all manufacturers as the newly articulated duty is grounded in general negligence principles, not limited to drug manufacturers.