BOWMAN, Circuit Judge.
This lawsuit is one of many brought by plaintiffs throughout the United States against Dow Chemical, DuPont, and other defendants for injuries resulting from jaw implants called temporomandibular joint ("TMJ") implants. In these lawsuits both Dow Chemical and DuPont have enjoyed consistent success. In 1994, all the TMJ cases then pending in federal court were consolidated in the District of Minnesota. The District Court
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