Manufacturers maintain records of customer complaints, warranty claims, field service reports, and reported incidents. These records establish notice of a hazard and support similar incident evidence.
Scope and format disputes are common.
Alternative Names:
Customer Complaint Discovery, Complaint Records Discovery
Why it Matters?
These records are the primary source of notice evidence and the reason manufacturers face substantial exposure on hazards they documented internally, since a database showing dozens of similar reports before the plaintiff's incident establishes knowledge conclusively. Scope negotiation over product models, time periods, and complaint categories is where the dispute concentrates. Producing in a structured queryable format rather than as documents is worth negotiating.
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Frequently asked questions
Why are complaint records so significant?
What format should be negotiated?
