The laws in conflict are New York's common law of products liability and negligence, which permit actions to recover unlimited noneconomic damages for injuries caused by defective products and for serious injuries arising out of negligence in the use or operation of a motor vehicle (cf. Insurance Law § 5104 [a]), and Quebec's Automobile Insurance Act (RSQ ch A-25), a no-fault statute that, inter alia, prohibits actions to recover noneconomic loss for injuries...
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