Attorneys representing consumers in a class action lawsuit against a heating, ventilation and air conditioning manufacturer needed an expert in consumer products recall management. The lawsuit alleged that the manufacturer committed breach of warranty, as well as other negligence, by mismanaging a product recall and not replacing the defective product. Instead the manufacturer offered a solution that not only disabled the immediate hazard but also key product functionality. As such, the expert would need to be someone who had managed recalls and could advise on how it could have been better crafted and, more importantly, confirm whether or not it was inadequate and left consumers in danger. Plaintiffs were seeking replacement of the defective product so the expert would also need to be able to deliver an informed opinion on the appropriateness of that remedy.