On June 12, 2014, plaintiff Richard Fatu, 34, a truck driver, was delivering lumber to customers in the Bay Area. His trailer was designed so that the sides could slide open to allow access to cargo anywhere in the cargo area, whereas conventional trailers allow access only from the rear. The side areas were shielded by a sliding curtain that was designed by Arlington, Texas-based Roland Curtains Inc. In designing the system, Roland Curtains integrated a cylinder, made by AVM Industries, LLC, that contained a gas-loaded spring mechanism. When the operator released a lever that opened a post/pillar attached to the curtain, the spring mechanism intervened to limit the speed at which the post/pillar would extend toward the operator. After the post had been slackened, the operator would pull the post out of its sliding track so that the curtain could be opened by sliding the post/pillar along the side of the trailer. When Fatu attempted to open the curtain on June 12, 2014, he was struck by the pillar. He claimed that he suffered of his face and head. Fatu sued Roland Curtains Inc.; a related entity, Roland Curtains (USA) Inc.; AVM Industries, LLC; and a company that was believed to have installed the curtain system, Utility Trailer Manufacturing Co. Fatu alleged that the curtain system was defectively designed and/or manufactured, that it was negligently installed, and that the defendants negligently failed to provide a warning that disclosed the hazards that could have stemmed from it use. Utility Trailer Manufacturing was ultimately dismissed, as it was discovered that Roland Curtains Inc. had installed the system on Fatu’s trailer. Roland Curtains (USA) Inc. was also dismissed, as it was not the proper party in interest. Plaintiffs’ counsel contended that Roland Curtains Inc. defectively designed and manufactured the curtain system and that AVM Industries was negligent in the manufacturing of a component part. Counsel also contended that Roland Curtains and AVM Industries failed to warn consumers that the safety cylinders could loosen, but Fatu later discontinued his failure-to-warn claim. Roland Curtains Inc. and AVM Industries both claimed the curtain system and its components were not defective. Defense counsel noted that the post/pillar contained a clear warning sticker that warned the operator not to stand directly in front of the post/pillar when releasing it. As a result, defense counsel argued that Fatu misused the system, despite using the system numerous times before, and that any alleged failure of the system was not caused by normal operation but by an unintended and unforeseen force. Counsel further argued that the system contained adequate warnings, which Fatu saw and failed to heed., Fatu sustained a cut to the left eyebrow area and then finished his route. However, he went to urgent care a few hours later, claiming he sustained a concussion. He also claimed he suffered a traumatic brain injury and suffers from post-concussion syndrome. The eyebrow laceration did not require sutures, and Fatu was released to return to full duty work after a week. In October 2014, Fatu was committed to Marin General Hospital, in Greenbrae, on a 5150 hold after allegedly expressing suicidal ideations. Shortly after his release, he began seeing various physicians who determined that he had allegedly sustained a traumatic brain injury, causing a change in his personality and thought process. Fatu later treated with a neurologist and psychologist (through workers’ compensation) for his alleged post-concussion syndrome and TBI. Fatu claimed his TBI caused him to have psychological problems, which have impacted both his emotional coping skills and his relationships with his wife and two children. He alleged that as a result, he will require ongoing mental health treatment with a neurologist, a neuropsychologist, a psychologist, a therapist and a psychiatrist. He also treats with massage and sacral cranial massage, and by doing yoga. However, Fatu claimed he could not continue working and could never return to work as a truck driver. The plaintiff’s psychiatry expert opined that Fatu had suffered a TBI, but that Fatu’s future was “hopeful.” He also expressed that additional counseling would be beneficial. The plaintiff’s treating neuropsychologist also felt Fatu had sustained a TBI and would need further cognitive therapy. Fatu sought recovery of noneconomic damages for his past and future physical pain, mental suffering, loss of enjoyment of life, inconvenience, grief, anxiety, humiliation, emotional distress, post-traumatic stress disorder, depression, suicidal ideation, personality changes, vivid nightmares, sleep disturbance, anger control problems, fatigue, sexual dysfunction, vertigo, ringing in ears, nausea, and difficulty concentrating. His wife, Sairah Fatu, sought recovery for her loss of consortium. Plaintiffs’ counsel asked the jury to award $10 million to $15 million for Mr. Fatu’s damages and $5 million for Ms. Fatu’s damages. Defense counsel presented a YouTube video of Mr. Fatu, which was published on Mr. Fatu’s son’s dedicated YouTube channel. The video showed Mr. Fatu actively participating in his son’s sprint race car career. Defense counsel used the video to impeach the plaintiffs.