 Some scholars have expressed reservations about the relevance of hypothetical scenarios featuring naked statistical evidence. Since these scenarios are removed from trial practice, they might be an unreliable guide for theorizing about the trial (Allen and Leiter 2001; Dant 1988; Schmalbeck 1986). These scenarios, however, are partly modeled on real cases. For example, Blue Bus is modeled on Smith v. Rapid Transit, Inc. 317 Mas. 469 (1945). The hypothetical also bears a similarity with the landmark case Sindell v. Abbott Laboratories, 26 Cal. 3d 588 (1980) in which different companies marketed the same drug that was later shown to have caused cancer to a particular individual. Since the drug was sold by multiple companies, it was impossible to determine which company was responsible. Statistics about the market share of the two companies were used to attribute liability in absence of better, more individualized evidence.