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With the U.S. Supreme Court holding last year in Pliva, Inc. v. Mensing that the manufacturer of a generic pharmaceutical product cannot be liable under a failure-to-warn theory, pharmaceutical plaintiffs are searching for new theories to hold nonmanufacturers liable for alleged injuries. The 2009 case Conte v. Wyeth Inc., et al. was widely publicized for allowing plaintiffs injured by a generic pharmaceutical to hold the “innovator,” or brand-name manufacturer, liable even though it did not manufacture the product, but Conte has not found favor with other courts. In the wake of Mensing and Conte’s failure to gain traction, one has to wonder which nonmanufacturer is the next target.