Last week we brought you the first two of three strategies developed by Bill Lee of Wilmer Cutler Pickering Hale and Dorr and trial consultant Jamie Laird to deal with the uptick in $10 million-plus damages awards in the wake of the pandemic. 

Quick refresher: Those first two strategies were (1) to encourage courts to be more consistent in how they apply Daubert in challenges to damages demands disconnected from the facts at hand and (2) to re-think jury selection to do a better job of identifying potential jurors apt to award big damages.