recently, this doctrine has been called into question due to the increased use of direct to consumer advertising, whereby drug manufacturers market pharmaceutical products to individuals rather than to doctors. for example, in "rimbert v. eli lilly & co.", 577 f. supp. 2d 1174, 1218-19 (d. n.m. 2008), the district court of new mexico reasoned that the "dramatically increased marketing directed to consumers . . . would persuade the supreme court of new mexico that the justification for the learned-intermediary doctrine is quickly becoming, if not already the case, outdated." however, other recent cases have declined to adopt this so-called "direct-to-consumer advertising" exception to the learned intermediary doctrine. "see dibartolo v. abbott labs.", 2012 wl 6681704 (s.d.n.y. dec.21, 2012), "centocor inc. v. hamilton", 372 s.w.3d 140, 161 (tex. 2012), "calisi v. abbott labs.", 2013 wl 5462274 (d. mass. feb. 25, 2013).