Christiansen v. Wright Medical Technology Inc. (127 F. Supp. 3d 1306, 2015)

OPINION AND ORDER

WILLIAM S. DUFFEY, JR., District Judge.

I. INTRODUCTION

On February 27, 2012, the United States Judicial Panel on Multidistrict Litigation (the “Panel”) ordered the centralization-of five actions pending in five districts, involving alleged defects in Wright Medical Technology Inc.’s Conserve line of hip implant products. (In re: Wright Medical Technology, Inc., Conserve Hip Implant Products Liability Litigation, 1:12-md-2329 (“MDL”), [1] (the “February 27, 2012, MDL Order”)). Most of the plaintiffs’ claims focus on the alleged propensity of the metal-on-metal design of the Conserve products “to generate high levels of metal debris, causing metallosis in the surrounding tissue [and to] fail early (including loosening of the acetabular cup).” (Id. at 1).

On May 23, 2013, the Court ordered that any plaintiff whose case is subject to transfer to the MDL was allowed to file their claims directly in the MDL. (MDL [86]). The Court approved an Abbreviated Short Form Claim (“Short Form Complaint”) to facilitate the filing of cases. On January 30, 2013, Plaintiff Robyn Christiansen (“Plaintiff’) filed her Short Form Complaint in the MDL. (MDL [404]).

The parties identified ten (10) cases they proposed to submit to the Bellwether trial process (the “Bellwether Nominees.”). (MDL [1037] at 1). Plaintiff’s case was selected as the first Bellwether case to be tried.

II. BACKGROUND OF PLAINTIFF’S CASE

A. Plaintiffs Allegations

Plaintiffs Short Form Complaint [l] names Defendants Wright Medical Teeh-nology, Inc. (“Wright Medical”) and Wright Medical Group, Inc. (‘WMG”) (together, “Defendants”) as defendants in this action. On October 6, 2014, Plaintiff filed her First Amended Complaint [10] and, on October 10, 2014, she filed a Second Amended Complaint [11] (“Second Amended Complaint”).

Plaintiff alleges that, on April 24, 2006, she was implanted with the Wright Conserve Hip Implant System (the “Conserve Hip Implant System” is sometimes referred to as the “Conserve implant”). (Second Am. Compl. ¶ 13). A hip joint can be replaced by an artificial replacement system implanted to replace the body’s natural joint. The typical replacement joint

consists of four separate components: (1) a femoral stem, (2) a femoral head, (3) an acetabular shell, and (4) a liner. To replace a patient’s hip joint, a surgeon hollows out a patient’s femur bone and implants a femoral stem. Then a metal ball is fixed on top of the femoral stem to become the new femoral head. The surgeon also reams out the acetabu-lum and fits an artificial acetabular shell into the bone. Then ... a liner made of polyethylene would be inserted into a titanium acetabular shell, and the new femoral head (made of metal or ceramic) would rotate inside the shell, creating a metal-on-polyethylene or ceramic-on-polyethylene articulation.

(Id. ¶ 15).

Plaintiff asserts that the Conserve Hip Implant System “omits the polyethylene liner and instead puts the Cobalt-Chromium metal Conserve femoral ball directly in contact with a Cobalt-Chromium metal Conserve acetabular cup.” (Id. ¶ 16). The “movement of this artificial joint [Plaintiff claims] produces metal-on-metal wear debris, and the amount of toxic metal debris produced increases as a patient’s activity increases.” (Id.).

Dr. Lynn G. Rasmussen (“Rasmussen”) has provided Plaintiff with orthopedic medical treatment since 1995. (Id. ¶¶ 20-21). In 1995, Rasmussen completed a total hip revision surgery on Plaintiffs left hip, utilizing a ceramic femoral ball and a polyethylene liner in a metal acetabular shell. (Id. ¶ 21).

Rasmussen later told Plaintiff she met the criteria for a total hip replacement of her right hip, and recommended replacement with the Conserve Hip Implant System. (Id. ¶¶ 22-23). Plaintiff alleges that Rasmussen made this recommendation based on information he received from Defendants, specifically: (1) that the Conserve implant was a good option for active patients, such as Plaintiff; (2) that the Conserve implant “should [last] longer than a hip replacement utilizing a polyethylene liner because the cobalt-chromium cup was touted to last longer than a polyethylene liner;” and (3) “that there were no known issues with Cobalt and Chromium ions.” (Id. ¶ 23).

Based on Rasmussen’s recommendation and the information provided by Defendants, Plaintiff elected a total hip replacement of her right hip using the Conserve Hip Implant System. (Id. ¶ 24). On April 24, 2006, “Dr. Rasmussen implanted the following Conserve [implant] components: a Wright Conserve Plus Cup, a Wright ProFemur RAZ Stem, a Wright ProFemur Neck, and a Conserve Total A-Class head, into [Plaintiffs] right hip.... ” (Id. ¶ 25).

Plaintiff claims that, on or about October 24, 2012, she was doing yoga “when she felt and heard a crunching sound and then felt immediate, severe pain in her right hip and groin.” (Id. ¶ 27). Plaintiff alleges the pain prohibited her from ambulating without assistance, and she called Dr. Rasmussen’s office. (Id.). Rasmussen saw Plaintiff on October 25, 2012. (Id. ¶ 28).

Rasmussen diagnosed Plaintiff as having a loose and displaced acetabular cup in her right hip replacement, which required revision surgery. (Id.). The surgery was performed on October 29, 2012. (Id. ¶ 29). During the surgery, Rasmussen noted signs of a “metalosis [sic] reaction of her hip, with an inflammatory synovium” and he “removed the displaced acetabular component [and] soft tissue that had been damaged by the metal debris.” (Id.).

Plaintiff “endured a painful recovery from her right [hip] revision surgery and continues to suffer from injuries of a permanent and lasting nature and discomfort as a result of the failed Conserve Hip Implant System[,] takes ibuprofen on a daily basis, [and although] she has been able to return to many of her activities, she can no longer run.” (Id. ¶ 30). Plaintiff alleges that she “requires continuous medical monitoring and treatment as a direct and proximate cause of her failed Conserve Hip Implant System.” (Id. ¶ 31).

Plaintiff asserts that the design of the Conserve Hip Implant System was defective and dangerous because it omits a liner separating the cobalt/chromium acetabular cup from the cobalt/chromium femoral head, resulting in the creation of metal-on-metal wear debris. (Id. ¶ 16). She claims that the “Conserve Thin Shell, marketed as the Conserve Plus Cup,” which was used in her 2006 implant, “was not cleared for marketing until 2012.” (Id. ¶ 17). Pri- or to 2012, Plaintiff claims this component was sold to. the public pursuant to an “internal Wright letter to file” that Defendants “knew was inappropriate and in violation of FDA requirements.” (Id.).

Plaintiff asserts claims for: (1) Strict Product Liability (Design Defect) (Count I); (2) Strict Product Liability (Failure to Warn) (Count II); (3) Negligence (Design Default and Failure to Warn) (Count III); (4) Fraudulent Misrepresentation (Count V); (5) Fraudulent Concealment (Count VI); and (6) Negligent Misrepresentation (Count VII). (Id. ¶¶ 32-109). Plaintiff seeks compensatory damages, punitive damages, and prejudgment interest. (Id. at 42).

B. Pending Motions

1. Daubert Motions

On January 15, 2015, Defendants filed their: (1) Motion to Exclude the Expert Testimony of Lance A. Waller, Ph.D. [49] (“Waller Motion”); (2) Motion to Exclude the Expert Testimony of Jay M. Vincelli, MSc, and John D. Jarrell, Ph.D., PE [50] (“Vincelli Motion”); (3) Motion to Exclude the Expert Testimony of Reed Ayers, Ph.D. [51] (“Ayers Motion”); and (4) Motion To Exclude Testimony Relating to Metallosis [52] (“Metallosis Motion”) (together, the “Daubert Motions”).

2. Motions for Summary Judgment

On January 9, 2015, Plaintiff filed her Motion for Partial Summary Judgment [20] (“Plaintiffs MSJ”). Plaintiff argues that Defendants are, as a matter of law, foreclosed from arguing that the Medical Device Amendment of 1976 preempts Plaintiffs design defect claims. Plaintiff also argues that Defendants provided false and misleading information to Rasmussen and, for that reason, the learned intermediary defense does not apply. Also on January 9, 2015, Defendants filed their Motion for Summary Judgment [24].

On March 31, 2015, the Court held a teleconference to discuss the pending motions. The Court noted- that Plaintiffs MSJ generally raised and advanced argu- ■ ments in anticipation of claims and arguments Plaintiff expected would be raised in Defendants’ summary judgment motion. To facilitate the efficient consideration of the motions, particularly the preemption and learned intermediary defenses, the Parties and the Court agreed that the Parties would submit substitute summary judgment briefs in which Plaintiff would raise her preemption and learned intermediary arguments in her response to Defendants’ summary judgment motion.

On April 7, 2015, Defendants refiled their Motion for Summary Judgment [140] (“Defendants’ MSJ”), and, on April 23, 2015, Plaintiff filed her Response in Opposition to Defendants’ MSJ [143]. The filing of Defendants’ motion for summary judgment and Plaintiffs response addressing all of the arguments raised by Defendants in their summary judgment motion succinctly presented the Parties’ arguments and helped the Court to evaluate each party’s position.

On January 9, 2015, Defendant WMG filed its separate Motion for Summary Judgment [38] (‘WMG’s MSJ”) on grounds applicable only to WMG.

The Court first considers the Daubert Motions.

III. DAUBERT MOTIONS

A. Legal Standard

The admissibility of expert opinions is governed by Rules 702 and 703 of the Federal Rules of Evidence.

1. Rule 702

Rule 702 of the Federal Rules of Evidence addresses the sufficiency and reliability of an expert’s opinion. Rule 702 provides:

If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise, if (1) the testimony is based upon sufficient facts or data, (2) the testimony is the product of reliable principles and methods, and (3) the witness has applied the principles and methods reliably to the facts of the case.

Fed.R.Evid. 702. The proponent of expert testimony must establish by a preponderance of the evidence that the Rule 702 requirements have been satisfied. United States v. Frazier, 387 F.3d 1244, 1260 (11th Cir.2004).

The criteria for evaluating the admissibility of expert opinion evidence under Rule 702 are stated by the Supreme Court in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993), and have been summarized as follows:

Expert testimony may be admitted into evidence if: (1) the expert is qualified to testify competently regarding the matters he intends to address; (2) the methodology by which the expert reaches his conclusions is sufficiently reliable as determined by the sort of inquiry mandated in Daubert; and (3) the testimony assists the trier of fact, through the application of scientific, technical, or specialized expertise, to understand the evidence or to determine a fact in issue.

City of Tuscaloosa v. Harcros Chems., Inc., 158 F.3d 548, 562-63 (11th Cir.1998) (footnote omitted) (citing Fed.R.Evid. 702; Daubert, 509 U.S. at 589, 113 S.Ct. 2786). Daubert sets several factors for use in assessing whether expert testimony is admissible. They include (1) whether a theory or technique applied by the expert can be or has been tested, (2) whether the theory has been subjected to peer review and publication, (3) in the case of a particular scientific technique, the Court should consider the known or potential rate of error, (4) and whether the theory or technique has gained general acceptance in the relevant community. Daubert, 509 U.S. at 593-94, 113 S.Ct. 2786. The Rule 702 inquiry is ultimately a flexible one. Id. at 594, 113 S.Ct. 2786.

Daubert focused on the admissibility of scientific testimony. Six years later, in Kumho Tire Co. v. Carmichael, 526 U.S. 137, 119 S.Ct. 1167, 143 L.Ed.2d 238 (1999), the Supreme Court extended Dau-bert’ s methodology to experts in other fields. The Supreme Court held that the specific factors mentioned in Daubert may be used to assess non-scientific expert testimony, and a trial court retains discretion to decide if non-scientific expert testimony is sufficiently reliable and relevant to be admissible. Kumho Tire, 526 U.S. at 141, 119 S.Ct. 1167. To determine admissibility, the trial court must

make certain that an expert, whether basing testimony upon professional studies or personal experience, employs in the courtroom the same level of intellectual rigor that characterizes the practice of an expert in the relevant field____ [T]he trial judge must have considerable leeway in deciding in a particular case how to go about determining whether particular expert testimony is reliable. That is to say, a trial court should consider the specific factors identified in Daubert where they are reasonable measures of the reliability of expert testimony.

Id. at 152,119 S.Ct. 1167.

The Court’s gatekeeping role under Rule 702 “is not intended to supplant the adversary system or the role of the jury: ‘vigorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof are the traditional and appropriate means of attacking shaky but admissible evidence.’ ” United States v. Alabama Power Co., 730 F.3d 1278, 1282 (11th Cir.2013) (quoting Allison v. McGhan Med. Corp., 184 F.3d 1300, 1311-12 (11th Cir.1999)). But the Court must first decide if an expert’s opinion is admissible.

2. Rule 70S

The basis for an expert’s opinion— that is, the type of facts or data an expert may rely upon in reaching their opinion— is evaluated under Rule 703 of the Federal Rules of Evidence. Rule 703 provides:

An expert may base an opinion on facts or data in the case that the expert has been made aware of or personally observed. If experts in the particular field would reasonably rely on those kinds of facts or data in forming an opinion on the subject, they need not be admissible for the opinion to be admitted. But if the facts or data would otherwise be inadmissible, the proponent of the opinion may disclose them to the jury only if their probative value in helping the jury evaluate the opinion substantially outweighs their prejudicial effect.

Fed.R.Evid. 703. Experts, thus, are entitled to rely on facts or data in the case that they (1) personally have observed, or (2) of which they have been made aware. See id.

“When an expert relies on inadmissible information, Rule 703 requires the trial court to determine whether that information is of a type reasonably relied on by other experts in the field. If so, the expert can rely, under Rule 703, on the information in reaching an opinion.” Fed.R.Evid. 702, Advisory Committee’s Notes (2000 Amendments); see also Broussard v. Maples, 535 Fed.Appx. 825, 828 (11th Cir.2013) (Rule 703 of the Federal Rules of Evidence “allows an expert to base his opinion on facts or data that would otherwise be inadmissible, such as hearsay, if other ‘experts in the particular field would reasonably rely on those kinds of facts or data in forming an opinion.’ ”) (quoting Fed.R.Evid. 703); Greenwood Utilities Comm’n v. Mississippi Power Co., 751 F.2d 1484, 1495 (5th Cir.1985) (“[W]hen an expert’s opinion is based on facts not admissible in evidence the court should make a threshold factual inquiry to determine whether the data providing the basis for the opinion is of a type reasonably relied on by experts in that field to form such opinions.”).

The “case law under F.R.E. 703 is not particularly enlightening on the subject of standards to be employed in assessing an expert’s reliance [on inadmissible evidence].” Zenith Radio Corp. v. Matsushita Elec. Indus. Co., 505 F.Supp. 1313, 1326 (E.D.Pa.1980). The Third Circuit, setting the bottom line for considering whether reliance on inadmissible evidence is reasonable under Rule 703, opined that if “the data underlying the expert’s opinion are so unreliable that no reasonable expert could base an opinion on them, the opinion resting on that data must be excluded.” In re TMI Litig., 193 F.3d 613, 697 (3d Cir.1999), amended, 199 F.3d 158 (3d Cir.2000). One district court has stated, “[t]o serve as the basis of the expert’s opinion, evidence need not meet any specific standard of reliability — or even be admissible on its own — so long as ‘experts in the particular field would reasonably rely on those kinds of facts or data in forming an opinion on the subject....’” Burton v. Riverboat Inn Corp., No. 4:12-CV-40-WGH-RLY, 2013 WL 6153231, at *8 (S.D.Ind. Nov. 20, 2013) (quoting Fed. R.Evid. 703).

The facts and data upon which an expert may rely in reaching an expert opinion includes the opinions and findings of other experts, if experts in their respective field would reasonably rely on other expert’s opinions and findings. See United States v. Winston, 372 Fed.Appx. 17, 20 (11th Cir.2010) (allowing an expert witness’s testimony that was based in part on an opinion of a non-testifying expert, noting that “an expert witness may base his testimony on inadmissible information so long as such information is ‘regularly relied upon by experts in his field.’ ”) (quoting United States v. Steed, 548 F.3d 961, 975 (11th Cir.2008)); see also Tamraz v. Lincoln Elec. Co., 620 F.3d 665, 675 (6th Cir.2010); United States v. Day, 524 F.3d 1361, 1371 (D.C.Cir.2008); Eberli v. Cirrus Design Corp., 615 F.Supp.2d 1357, 1364 (S.D.Fla.2009) (“an expert’s testimony may be formulated by the use of the facts, data and conclusions of other experts”) (quoting Ohio Environmental Development Ltd. Partnership v. Envirotest Systems Corp., 478 F.Supp.2d 963, 976 (N.D.Ohio 2007)); Malletier v. Dooney & Bourke, Inc., 525 F.Supp.2d 558, 664 (S.D.N.Y.2007).

The Court applies these admissibility standards under Rules 702 and 703 to address the Daubert Motions filed in this action.

B. Motion To Exclude Testimony Relating to Metallosis

1. Metallosis Motion

Metallosis involves a build-up of metal debris in the soft tissues of the body. Plaintiff contends she suffered from metal-losis as a result of the abrasion of components of the Conserve Hip Implant System which were implanted to replace her right hip. (See Second Am. Compl. ¶¶ 1, 16, 30).

Defendants move the Court to exclude all expert testimony that “argues, contends, or concludes that metallosis was present in Plaintiff ... and that such me-tallosis caused the failure of her Wright hip implant....” (Metallosis Motion at 1). Defendants move specifically to exclude the testimony, opinions, and expert reports of Plaintiffs experts Dr. Elizabeth Laposa-ta, Dr. Brent Morgan, Dr. John Jarrell, Dr. John Waldrop, Dr. Suzanne Parisian, Dr. Joel Bach, and Dr. Reed Ayers. (Id.). Defendants argue:

In very basic terms, the theory of Plain-tiffl’s] experts is that metal particles and ions caused a reaction in the tissues and bone surrounding Plaintiffs acetabular cup, which resulted in bone fixation of the cup essentially dissolving (“resorption” or “osteolysis”), which in turn caused the cup to loosen and the device construct to fail. The problem is there is no sufficient observable evidence to support this theory.

(Id.). Defendants note:

No tissue or bone samples were taken at the time of Plaintiffs revision surgery, no microscopic evaluation of tissue cells was undertaken, and no pathology tests, histology slides, photographs, blood ion concentration levels, or other observable data exist. There is no evidence of necrosis, bony resorption or dark, stained tissue. There is no evidence of pseduo-tumors or lesions. All that Plaintiff’s] experts have to rely upon for their opinions is the operative report of Dr. Lynn Rasmussen, in which he states, in con-clusory terms, that he observed “signs” of a “metalosis [sic] reaction.” Due to a dearth of objective data, Plaintiffs experts are forced to speculate on what Dr. Rasmussen’s comments meant, and make improper assumptions about the facts (such as the presence and levels of metallosis). The experts’ opinions and conclusions based on such speculation [are] unreliable and should be excluded.

(Id. at 2). Defendants argue that, in relying on Rasmussen’s clinical observations, Plaintiffs experts failed to apply the rigorous methodology required under Daubert in reaching their conclusions. (Id.). They claim that the experts’ opinions “focus on a purported causal link between metallosis and Plaintiffs implant failure, but fail to identify or account for facts that contradict their opinion, as well as possible alternate causes and explanations of the injury.” (Id.). Plaintiffs arguments and contentions regarding metallosis, Defendants assert, are based almost entirely on speculation that metallosis was present and are not based on objective supporting evidence, and thus the opinions should be excluded. (Id. at 2-3).

Defendants do not challenge the qualifications of Plaintiffs metallosis experts and they do not contend that the expert testimony will not assist the trier of fact. Defendants also do not challenge Rasmussen’s credibility, and they do not suggest that “Dr. Rasmussen did not truly observe ‘signs’ of a metallosis ‘reaction,’ inflammation, or cloudy synovial fluid.” (Metallosis Reply at 6). Defendants contend that even if “Dr. Rasmussen’s observations are true, they do not provide sufficient foundation for Plaintiffs [other] experts to form a reliable opinion” regarding the presence of metallosis in Plaintiff and its causal relationship to the failure of her hip implant. (Id.).

The question central to the motion to exclude the testimony of Dr. Elizabeth La-posata, Dr. Brent Morgan, Dr. John Jar-rell, Dr. Reed Ayers, Dr. Joel Bach, Dr. Suzanne Parisian, and Dr. John Waldrop is whether they may rely on the clinical observations and opinions of Rasmussen that there were “signs of a metalosis [sic] reaction of her hip with an inflammatory syno-vium” and that the acetabulum was exposed and that it was “cleaned of the soft tissue debris from the metalosis [sic] reaction.” (Operative Report at 1-2). Defendants argue that the metallosis experts’ opinions all rely on Rasmussen’s observations of metallosis and, based upon it, assume that metallosis was present in stating their various opinions to support or extrapolate on Rasmussen’s metallosis findings and the relationship of metallosis to the failure of the Conserve implant. The Court first addresses whether the me-tallosis experts may rely, under Rule 703 of the Federal Rules of Evidence, on Rasmussen’s opinion, even in part, in offering their further opinions.

2. Rasmussen

In 1995, Rasmussen completed total hip replacement surgery on Plaintiffs' left hip, utilizing a ceramic femoral ball and a polyethylene liner in a metal aceta-bular shell. (Second Am. Compl. ¶ 21). Sometime prior to April 24, 2006, Rasmussen told Plaintiff that she met the criteria for a total hip replacement of her right hip, and recommended replacement with the Conserve Hip Implant System. (Id. ¶¶ 22-23). On April 24, 2006, “Dr. Rasmussen implanted the following Conserve Hip Implant System components: a Wright Conserve Plus Cup, a Wright ProFemur RAZ 'Stem, a Wright ProFemur Neck, and a Conserve Total A-Class head, into [Plaintiffs] right hip.... ” (Id. ¶ 25).

On or about October 24, 2012, Plaintiff claims she was doing yoga “when she felt and heard a crunching sound and then felt immediate, severe pain in her right hip and groin.” (Id. ¶ 27). The pain she experienced from the event prohibited her from “ambulating without assistance.” (Id.). Rasmussen saw Plaintiff on October 25, 2012, and diagnosed her as having a loose and displaced acetabular cup in her right hip replacement, requiring revision surgery, which Rasmussen performed on October 29, 2012. (Id. ¶¶ 28-29).

Rasmussen, in his operative notes from the October 29, 2012, revision operation [53.4] (“Operative Report”), stated that Plaintiff “had signs of a metalosis [sic] reaction of her hip with an inflammatory synovium.... ” (Operative Report at 1-2). Rasmussen noted that the acetabulum was exposed, and that it was “cleaned of the soft tissue debris from the metalosis [sic] reaction.” (Id. at 2).

At his February 26, 2014, deposition, Rasmussen testified that the “acetabular component was completely loose, displaced; that there was a significant inflammatory reaction in the joint and fluid that was cloudy and inflammatory fluid. It was a — you know, the inside of the hip was very consistent with what I’d seen with revisions of failed metallosis hips.” (Tr. of Feb. 26, 2014, Rasmussen Dep. [53.5] (“Rasmussen First Dep.”) at 41:14-20). When asked what “metalosis [sic] reaction” meant, Rasmussen stated:

Well, what we’ve seen with prior revisions which — and this was very similar to what we’ve seen with hips that have failed as a result of metallosis — is an inflammatory reaction of the soft tissue, granulomatous change where you have hypertrophy, built up soft tissue within the joint, oftentimes pigment stained. The fluid very cloudy. Normal fluid in a well-functioning hip replacement is just a clear yellow. This is a very cloudy fluid. And also some cystic changes within the soft tissues.

(Id. at 42:14-24); Referring to the sentence in the Operative Report about cleaning the soft tissue debris, Rasmussen explained “that there was a soft tissue reaction that appeared to be consistent with other metallosis reactions we’d seen, a buildup of inflammatory soft tissue, that we cleaned out the acetabulum, removed that tissue so that we could repair for the reaming for the new acetabular component.” (Id. at 43:10-16)

At his further deposition on December 15, 2014, Rasmussen noted that he did not preserve tissue samples or send tissue samples to pathology for histological examination. (Tr. of Dee. 15, 2014, Rasmussen Dep. [53.6] (“Rasmussen Second Dep.”) at 60:7-23). When asked whether a histological or microscopic examination would have provided important information regarding Plaintiff, Rasmussen stated that he had seen this situation numerous times before and knew the problem and the necessary treatment, and that, even without sending tissue samples for analysis, knew what Plaintiffs “problem was based upon seeing this time and time again.” (Id. at 56:7-21). Rasmussen testified that Plaintiffs tissue “look[ed] exactly like the tissue that I’ve seen before then it’s, in my mind, pretty certain, you know, what would have been found” if a pathological examination had been performed. (Id. at 56:22-57:4). Because he has seen metallosis reactions many times before in his patients, Rasmussen no longer provides a more extensive description in his operative notes and will instead only use the term “metalosis [sic]” which, in his view, refers to those more extensive descriptions he has in the past authored in cases involving metallosis. (Id. at 58:22-59:8).

Defendants claim the opinions of Plaintiffs metallosis experts, because they rely, even if only in part, on the observations and opinions of Rasmussen, render their respective expert opinions unreliable because they are founded on insufficient me-tallosis evidence, and are thus inadmissible. The Court disagrees.

Under Rule 703 of the Federal Rules of Evidence, Plaintiffs metallosis experts may rely on facts or data of which they have been made aware — here Rasmussen’s observation of metallosis in Plaintiffs right hip. See Fed.R.Evid. 703. This is true even if Rasmussen’s observations are inadmissible, so long as experts in the respective field “would reasonably rely on those kinds of facts or data in forming an opinion on the subject....” See id.

In view of Rasmussen’s considerable background and experience in hip replacement and revision surgeries, the number of instances where he has performed revision surgeries in which metallosis was present, his experience in recognizing and diagnosing it, and his credentials and qualifications as an expert in original and revision hip replacement surgeries, the Courts find Rasmussen’s observations and opinions reliable. Those of Plaintiffs metallo-sis experts who rely on Rasmussen’s observations, conclusions, and opinions, are entitled to do so. Rasmussen’s observations, conclusions, and opinions are the kind of medically reliable evidence that medical experts would consider in reaching a conclusion about medical conditions or complications. That is, medical professionals and researchers often rely on the observations of treating physicians to reach diagnostic conclusions, decide on courses of treatment and opine on the commonality of disease and injury among patients to determine if there is a common course of disease or injury. The observations of an experienced treating physician are especially reliable because they serve to record a patient’s medical history and often form the basis for a person’s treatment and health issues throughout the person’s life. In short, it is reasonable for an expert to rely on a treating physician’s observations, comparisons, conclusions, and opinions in seeking to reach a conclusion on the course of a disease, injury, health complication, or, in this case, the cause of an undisputed hip replacement device failure. The certainty and sufficiency of the treating physician’s observations and conclusions, of course, may very well impact the persuasiveness of the opinions reached by the expert relying on them.

Defendants here do not challenge Rasmussen’s credibility, or suggest that “Dr. Rasmussen did not truly observe ‘signs’ of a metallosis ‘reaction,’ inflammation, or cloudy synovial fluid.” (Metallosis Reply at 6). Defendants contend only that even if “Dr. Rasmussen’s observations are true, they do not provide sufficient foundation for Plaintiffs experts to form a reliable opinion” regarding the presence of metal-losis and its connection to the failure of her Conserve implant. (Id.). The crux of Defendants’ argument is, instead, that Plaintiffs experts’ reliance on only Rasmussen’s opinion is insufficient and thus cannot be reasonably relied upon by Plaintiffs metal-losis experts because it does not provide a sufficient factual basis. The Court disagrees.

Rasmussen has been Plaintiffs orthopedic surgeon since before 1995, and, in the course of his practice, has performed multiple metal-on-metal hip device revisions, and has seen metallosis in many of these patients. ([97.2] at 52:6-53:5). Rasmussen was engaged by Wright Medical as a consultant and device designer in 2006, and in the October 1, 2006, consulting agreement by which Rasmussen was retained, Wright Medical noted that Rasmussen is “an or-thopaedic surgeon and inventor with extensive knowledge and expertise in the field of knee and hip arthroplasty and or-thopaedic surgery .... ” ([97.1] at 1). There is little doubt that Rasmussen, based on his extensive experience, as acknowledged by Wright Medical, and who had an interest in the design of medical devices, including for Wright Medical, would accurately and objectively record his observations and conclusions in the record of patients on whom he performed device replacement and revision surgeries. It is not disputed that he was qualified to observe signs of metallosis in Plaintiff when he performed her revision surgery. It is also undisputed that Rasmussen observed metallosis when he performed revision surgery on Plaintiff on October 29, 2012. Against this qualifications and credibility backdrop it is reasonable, if not necessary, for a qualified expert who seeks to determine the cause of Plaintiffs Conserve implant failure, to consider and rely on this particular treating surgeon’s observations, conclusions and opinion reached as a result of Plaintiff’s revision surgery.

That there may have been corroborating information that Rasmussen could have sought does not impact the reliability of his observations, including where, as here, Rasmussen testified that he was familiar with, and experienced in, failure of this kind of metal-on-metal device and the revision surgery this type of failure required. (Rasmussen Second Deposition Transcript at 56:7-21). He was familiar with metallo-sis, having seen it numerous times when revising a metal-on-metal implant. (Id.). He was sufficiently practiced in this kind of surgery and the common characteristics of this kind of implant failure that ultimately he needed only to state basic observations in his case notes to record his observations, conclusions and opinions regarding the presence of metallosis rather than the more extended record entries he made in earlier surgeries. (Id.). Rasmussen had encountered metallosis many times before Plaintiffs revision procedure, and he knew when the revision surgery was performed what the problem was and the necessary treatment. (Id.). He did not need to send tissue samples for analysis. (Id.). Rasmussen stated Plaintiffs tissue looked “exactly like the tissue that I’ve seen before then it’s, in my mind, pretty certain, you know, what would have been found” if a pathological examination had been performed. (Id. at 56:22-57:4).

Defendants may, of course, at trial challenge the observations, conclusion and opinions expressed by Rasmussen and the opinions offered by other experts who rely upon them. Viterbo v. Dow Chem. Co., 826 F.2d 420, 422 (5th Cir.1987) (“[A]s a general rule, questions relating to the bases and sources of an expert’s opinion affect the weight to be assigned that opinion rather than its admissibility and should be left for the jury’s consideration.”); see also Duling v. Domino’s Pizza, LLC, No. 1:13-CV-01570-LMM, 2015 WL 3407602, at *13 (N.D.Ga. Jan. 14, 2015) (citing Viterbo). That a defendant may challenge the usefulness and persuasiveness of an expert’s opinion is different from the obligation of the Court to evaluate whether the opinion and the bases for it requires that it be precluded from being presented to the jury at all. It is commonly accepted that medical records and statements by a patient’s treating physician are materials upon which testifying medical experts may reasonably rely. See Paine ex rel. Eilman v. Johnson, No. 06 C 3173, 2010 WL 749854, at *2 (N.D.Ill. Feb. 25, 2010); see also Henderson v. Goodyear Dunlop Tires N. Am., Ltd., No. 3:11-CV-295-WKW, 2013 WL 5729377, at *5 (M.D.Ala. Oct. 22, 2013) (concluding that a physician’s reliance on other doctors’ medical records are the types of evidence contemplated under Rule 703 because they are the type of evidence that medical doctors reasonably rely upon). There is no authority to support Defendants’ contention that Rasmussen’s observation, conclusions, and opinions regarding metallosis cannot be reasonably relied upon by Plaintiffs experts.

The observations, conclusions, and opinions reached by Rasmussen are sufficient to be relied on by other experts in reaching opinions in this case to establish the cause of Plaintiffs Conserve implant failure. The Court specifically determines that Rasmussen’s observations, conclusions, and opinions were not required to be corroborated by laboratory or other corroborating testing before other experts could reasonably rely upon them.

Having found that Rasmussen’s observations, conclusions, and opinions may be relied on by other experts under Rule 703 of the Federal Rules of Evidence, the Court next addresses whether the opinions reached by the experts Plaintiff seeks to present at trial are based on sufficient facts and are sufficiently reliable to satisfy the standards set forth in Dau-bert and Rule 702 of the Federal Rules of Evidence.

3. Dr. Elizabeth A. Laposata, MD, FCAP, FASCP

a) Expert Opinion

Dr. Elizabeth A. Laposata (“Lapo-sata”) is a forensic pathologist. She was retained by Plaintiff to analyze patient records and pathology specimens to assess adverse local tissue pathology and systemic reactions to Wright Medical Conserve hip orthopedic devices removed during revision surgeries. She prepared an expert report dated July 17, 2013 [53.8] (“Laposata Report”), and a supplemental expert report dated November 21, 2014 [53.7] (“Laposata Supplemental Report”).

Laposata concluded that the “Conserve metal-on-metal hip orthopedic implant generates nanoparticles of cobalt/chromium and chromium phosphate aggregates.” (Laposata Report at 4). This metal debris, Laposata opines, can cause “adverse tissue reactions,” including: “necrosis (death) of local tissues,” “cyst formation,” “metallosis (presence of metal wear debris),” “effusions (fluid build-up),” “chronic inflammation,” and “other adverse reactions to metal debris — namely, pseudotu-mors, periprothetic soft tissue masses, aseptic lymphocytic vasculitis associated lesions.” (Id.). According to Laposata, these “adverse tissue reactions may cause clinical failure of the implant. Data from joint registries show that metal-on-metal hip orthopedic implants have a higher failure rate than metal-on-polyethylene devices.” (Id.).

Laposata explains how the body integrates a hip implant, primarily as a result of “bone repair and remodeling during the healing process called osseointegration” and notes that if osseointegration does not occur, the prosthesis will become loose. If implant integration is impacted by the os-teolysis, causing bone dissolution or destruction, “the prosthesis also will loosen. A loose hip implant can lead to clinical implant failure and may require removal (explantation) and revision.” (Id. at 5). Laposata opines that bodily movement causes wear on hip implants that produce debris:

Metal-on-metal hip implants generate wear debris that is unique in terms of size, composition and number. All of these properties cause pathophysiologic responses in the body that are unique to metal-on-metal implants. These patho-physiologic responses by the body then cause changes in cells and tissues surrounding the implant, generally known as adverse reaction to metal debris (ARMD), which is diagnosed by examining the explanted tissues with the naked eye (i.e., gross pathologic examination) and under the microscope (i.e., histologic examination). These adverse cell and tissue reactions can cause implant loosening and clinical failure of the implant.

(Id.). Laposata explains the unique reactions that occur in the body when nanopar-ticles of cobalt-chromium are shed from metal-on-metal hip replacements. (Id. at 6-9).

In the Laposata Supplemental Report, Laposata discusses Plaintiffs Conserve implant. She states that she reviewed Plaintiffs medical records and a transcript of Plaintiffs February 27, 2014, deposition, viewed photographs of the explanted head and cup, and examined the explant itself. (Laposata Supplemental Report at 2). Based on her analysis of this information and the explanted device, Laposata opines that Plaintiffs “sudden displacement of the acetabular cup indicates that any oss-eointegration initially present had been destroyed.” (Id. at 3). Laposata states that her “[v]isual examination of the aceta-bular side of the cup showed only a few minuscule islands of bone scattered between the beaded elements of the cobalt-chromium surface,” and that Plaintiffs acetabular cup was not substantially attached to the pelvic bone. (Id.). Laposata opines that this “caused loosening and failure of the implant. The cause of the lack of any initial osseointegration, as well as osteolysis[] of any existing direct bone-to-component attachments, is the inflammatory response to the cobalt-ehromium metallic wear debris and corrosion products from her hip implant components.” (Id.). After reviewing and analyzing Plaintiffs medical records, a transcript of Plaintiffs February 27, 2014, deposition, photographs of the explanted head and cup, and the explant itself, Laposata concludes that metallosis caused by the deposit of cobalt-chromium debris from the hip implant, inhibited the grown of bone into the implant and destroyed the bone already in place, resulting in the failure of the implant. (Id.).

b) Analysis

Defendants argue that Laposata’s conclusion that metallosis caused the failure of Plaintiffs implant is based solely on Rasmussen’s observation of “metalosis [sic].” (Metallosis Motion at 6). Defendants claim this reliance is a “sharp departure from the methodology she recommends in [the Laposata Report],” which Defendants contend requires not only gross visual observation but also microscopic examination. (Id. at 6-7). Defendants claim further that Laposata did not conduct any pathology analysis of the tissue, because it was unavailable, and thus relied on Rasmussen’s observation of metallosis. (Id. at 7-8).

Defendants misconstrue Laposata’s statements about methodology and the evidence she relied upon in reaching her conclusion that metallosis was present in Plaintiff. Laposata states that she “relied on the eyes of the experienced surgeon in the description of the appearance of the tissues at surgery and then I relied on my examination of the explant.” (Tr. of Dec. 29, 2014, Laposata Dep. [53.23] (“Laposata Dep.”) at 57:3-6). Laposata states that she reviewed Plaintiffs medical records and a transcript of Plaintiffs February 27, 2014, deposition, viewed photographs of the explanted head and cup, and examined the explant components. (Laposata Supplemental Report at 2). Laposata, thus, relied on more than just Rasmussen’s observations in reaching her conclusions. Laposata testified that, while you can rely on visual examination of tissues by a pathologist and the microscopic examination of the slides created from those tissues, you can also rely on medical records and testimony. (Laposata Dep. at 54:10-18).

Under Daubert, the Court must admit expert testimony if:

(1) the expert is qualified to testify competently regarding the matters he intends to address; (2) the methodology by which the expert reaches his conclusions is sufficiently reliable as determined by the sort of inquiry mandated in Daubert; and (3) the testimony assists the trier of fact, through the application of scientific, technical, or specialized expertise, to understand the evidence or to determine a fact in issue.

City of Tuscaloosa, 158 F.3d at 562-63 (11th Cir.1998) (footnote omitted) (citing Fed.R.Evid. 702; Daubert, 509 U.S. at 589, 113 S.Ct. 2786). The Court finds that Laposata’s reliance on the observations, conclusions, and opinions Rasmussen made and reached during Plaintiffs revision surgery, Plaintiffs medical records, Plaintiffs February 27, 2014, deposition, and her personal examination of photographs of the explanted head and cup, and the ex-plant itself, are sufficient under Daubert and Rule 702 of the Federal Rules of Evidence for her opinions to be admitted. See id. Defendants do not contend that Laposata is unqualified to testify competently in the field of forensic pathology, or that her testimony will not assist the trier of fact. The Court concludes that Laposa-ta is qualified in the discipline of forensic pathology, applies theories accepted in the field of forensic pathology, and that her testimony will assist the trier of fact in this case to understand the evidence and determine the issue of causation in this case. Laposata’s opinions are not required to be excluded under Daubert. See id.

4. Dr. Brent W. Morgan a) Expert Opinion

Dr. Brent W. Morgan (“Morgan”), a medical doctor Board certified in medical toxicology, was retained by Plaintiff and prepared an expert report [53.9] (“Morgan Report”). Morgan states that he is “experienced as an investigator of toxic metals such as lead and other metals on the human body” and has “evaluated several patients with metal on metal (MoM) hip implants and [has] observed the surgical removal of a Wright Medical Conserve MoM hip.” (Morgan Report at 1). Morgan reviewed Plaintiffs medical records and states that her “operation revealed the presence of metallosis reaction, an inflamed joint synovium and the accumulation of soft tissue debris from the me-tallosis. The acetabular component of her hip had failed, loosened and rotated.” (Id.). Morgan opines that Plaintiffs hip implant “had broken down and produced enough metal debris that the tissue in her body had been visibly altered.” (Id.). Morgan states:

Visual inspection of Mrs. Christiansen’s failed hip prosthesis reveals poor osteo-integration of the cup while microscopy revealed the presence of significant wear and tear that produced the metal debris in her hip joint. Metal debris released from the Wright Medical metal on metal hip prosthesis caused corrosive and direct toxic effects in the tissue surrounding Mrs. Christiansen’s hip prosthesis.

(Id.). Morgan opines that Plaintiffs Conserve implant “was continuously releasing metal debris, the immune system response produced the chronic inflammatory condition that developed in Mrs. Christiansen,” and the “chronic inflammation surrounding her bone plus the direct toxic effects of the metal debris produced bone resorption that caused degradation of Mrs. Christian-sen’s hip to the point that the prosthesis loosened and failed.” (Id. at 2).

b) Analysis

Defendants assert that Morgan’s conclusion that metallosis was present is based on Rasmussen’s references to “signs of metalosis [sic]” and “metalosis [sic] reaction.” (Metallosis Motion at 8) (citing Tr. of Jan. 14, 2015 Morgan Dep. [53.10] (“Morgan Dep.”) at 73:1-17, 78:11-13). Defendants note that Morgan states that metallosis produces “tissue that has been altered in appearance because it contains such a large amount of metal debris,” and opines that Plaintiffs hip implant “had broken down and produced enough metal debris that the tissue in her body had been visibly altered.” (Id.) (citing Morgan Report at 1). Defendants assert that Morgan assumes that the metallosis was widespread and that there was metal debris throughout the hip joint, despite that neither the Operative Report nor Rasmussen’s deposition testimony specifies the extent to which metallosis affected Plaintiffs soft tissue. (Id. at 10). Defendants assert also that Morgan assumes that metallosis existed, despite neither the Operative Report or Rasmussen’s testimony mentioning tissue color or bone resorption. (Id.).

Defendants also argue that Morgan did not “apply any discernable [ ] methodology to arrive at his opinion that metallosis caused Mrs. Christiansen’s hip to fail. Moreover, Dr. Morgan’s opinion is unique in that Dr. Morgan lacks the expertise in medical device failure to provide a meaningful opinion in this case.” (Id. at 9).

Morgan testified at his deposition:

Q. Okay. But you’re not in a position— you don’t have the background and experience to say what caused this hip to fail; right?

[Morgan]. To what exactly — I think I have the experience to talk about the toxicological issues and how, you know, chromium and cobalt that get released into a hip can cause a weakening of a joint and causing it to fail.

Q. You can say that, but you can [sic] say in Ms. Christiansen’s case what caused it to fail; right?

[Morgan], I think with the metallosis that’s here and the soft tissue debris, I think I can say more likely than not that it was, you know, the — the nano particles of this that contributed, you know, to this failure of the hip.

Q. Without knowing anything about the extent of the metallosis?

[Morgan]. Yes.

Q. Without knowing anything about that, you can say that — that metal debris caused this woman’s hip failure?

[Morgan]. I think more likely than not, yes.

Q. Without seeing any pathology material?

[Morgan]. Yes.

Q. Without seeing any X-rays?

[Morgan]. Yes.

Q. And even though you’ve said that you’re not really qualified to say what causes a hip to fail, you would need to have the surgeon’s input?

[Morgan], I would need to have the surgeon’s input, yes.

Q. Okay. All you can say is that Ms. Christiansen appeared to have some— some amount of metallosis and that could have possibly caused her hip to fail; right?

[Morgan]. I think it — yes, I think that it — I can say that, yes.

Q. Yeah. You’re not in a position to distinguish the cause of what caused her hip to fail, whether it was the metallosis versus a traumatic event?

[Morgan]. I think I would want to get input from the orthopedic surgeon on that.

(Morgan Dep. at 87:6-89:7).

A fair reading of Morgan’s deposition testimony establishes that Morgan’s opinion that Plaintiffs specific hip implant failed due to metallosis is not sufficiently reliable to present to the jury. Morgan states that it was “more likely than not” that the metallosis “contributed ... to the failure of the hip.” (Id. at 87:16-20). Morgan does not provide any specific support for this opinion, other than Rasmussen’s opinion that there was metallosis in Plaintiffs hip.

Morgan did not examine any x-rays of the dislocated implant, and he is not sure of the extent of the metallosis and what, if any, inflammation it caused in Plaintiffs soft tissues. Morgan defers to the operating surgeon for a conclusion on what caused the failure. He does not have an independent opinion, only a highly qualified view of what may here have caused the failure. Morgan’s conclusion, thus, appears to be mere ipse dixit. See Guinn v. AstraZeneca Pharm. LP, 602 F.3d 1245, 1255-56 (11th Cir.2010) (“[N]othing in either Daubert or the Federal Rules of Evidence requires a district court to admit opinion evidence which is connected to existing data only by the ipse dixit of the expert. A court may conclude that there is simply too great an analytical gap between the data and the opinion proffered.”) (citing Gen. Elec. Co. v. Joiner, 522 U.S. 136, 146, 118 S.Ct. 512, 139 L.Ed.2d 508 (1997)). The analytical gap between the “data” upon which Morgan relies and the “opinion” he offers simply is too wide to allow the opinion to be admitted.

Considering that Morgan relies almost exclusively on Rasmussen’s clinical observations and opinions, Morgan’s expert opinions in this case, besides being unreliable, are also cumulative of Rasmussen’s opinion, and other admissible expert opinions, including those of Laposata, Jarrell, and Waldrop, regarding the presence of metallosis and its impact, if any, on Plaintiff’s implant failure. Morgan’s conclusion that the failure of Plaintiff’s hip implant was caused by metallosis is not based on sufficient facts and data, is not “sufficiently rehable” and would not be helpful to the jury. It is, therefore, excluded. See City of Tuscaloosa, 158 F.3d at 562-63.

5. Dr. John D. Jarrell, PhD., PE

a) Expert Opinion

Dr. John D. Jarrell (“Jarrell”), a biomedical engineer employed by Materials Science Associations, LLC (“MSA”), was retained by Plaintiff and prepared an expert report, dated November 21, 2014 [53.19] (“Jarrell Report”). Jarrell states he is an “experienced multi-discipline engineer specializing in the analysis of complex designs and failures involving materials, mechanical and biological systems.” (Jar-rell Report at 1).

Jarrell reviewed Plaintiff’s medical records, including the Operative Report, and, on December 11, 2012 and November 19, 2014, he examined Plaintiff’s explanted Conserve implant. (Id. at 5-6). The initial examination included “visual inspection, photodocumentation, [and] microscopy wear measurements using a sensitive coordinate measuring machine (CMM).” (Id.). It was evident from Jarrell’s “inspection that metal ions and particles were released from wear and corrosion of the articular surfaces of Ms. Christiansen’s WMT Conserve® hip implant. It was also evident from her medical records that she experienced metallosis to the tissues surrounding [her] cup implant.” (Id. at 7).

Jarrell opines “there was little evidence of bony ingrowth remaining in the porous back of Ms. Christiansen’s implant after removal. There were some areas with white bone ingrowth and also areas where remaining bone was discolored.” (Id.). Jarrell noted that “the titanium alloy stem was still fixed well to the bone with good signs of integration and no sign of loosening. Titanium and titanium alloys are recognized for superior osseointegration and bony ingrowth.” (Id.). Jarrell further observed

localized corrosion, carbide pull out and scratching characteristic of third-body wear and abrasive wear, during my inspection of Ms. Christiansen’s explanted WMT Conserve® metal on metal head and cup. Corrosion was also evident in the general discoloration of the explant when compared to an unused implant (exemplar).

(Id.). Jarrell states,

It is evident from my inspection of Ms. Christiansen’s WMT implants, the results of the gross wear using CMM and her medical records indicating metallo-sis, that she was exposed to cobalt and chromium metal wear debris, metal ions and corrosion products. It is also evident that this exposure had a negative impact on the tissues surrounding her WMT CoCr acetabular cup.

(Id. at 16 — IT).

b) Analysis

Defendants argue that Jarrell relied solely on the Operative Report to conclude that Plaintiff experienced metallosis in the tissues surrounding her implant. (Metal-losis Motion at 15). This argument is unfounded. In addition to reviewing the Operative Report, Jarrell twice examined Plaintiffs hip implant. (Jarrell Report at 1). When asked what evidence existed that Plaintiff had either cobalt or chromium metal ions in her system, Jarrell states:

The evidence that we have is the medical records with the observations of metallo-sis twice and also the loss of metal, at least the visual appearance of scratching on the inside of the cup and the ball and also the corrosion inside of the taper joint. So we see evidence that metal ions and particles and wear debris was' released. Conservation of matter, if the metal ions and debris are missing from the cup and ball, they went into the adjacent areas.

(Tr. of Dec. 30, 2014 Jarrell Dep. [97.8] (“Jarrell Dep.”) at 123:10-19). Jarrell’s inspections show that “metal ions and particles were released from wear and corrosion of the articular surfaces of Ms. Chris-tiansen’s WMT Conserve® hip implant,” and Plaintiffs medical records supported that “she experienced metallosis to the tissues surrounding her, cup implant.” (Jarrell Report at 7). Jarrell states: “there was little evidence of bony ingrowth remaining in the porous back of Ms. Chris-tiansen’s implant after removal. There were some areas with white bone ingrowth and also areas where remaining bone was discolored.” (Id.).

Jarrell reached his opinions based on articulated evidence that supported Rasmussen’s conclusion that Plaintiff experienced metallosis in the tissue surrounding her hip implant. Jarrell’s expert testimony is “sufficiently reliable” and would be helpful to the jury to understand the evidence and determine the issue of causation. The opinion is not required to be excluded under Daubert. See City of Tuscaloosa, 158 F.3d at 562-63.

6. Dr. Reed Ayers, Ph.D.

a) Expert Opinion

Dr. Reed Ayers (“Ayers”), a metallurgist employed by Verkko Biomedical, also was retained by Plaintiff. Ayers prepared an expert report dated November 21, 2014 [53.14] (“Ayers Report”). Ayers states he is “an experienced multi-disci-pline engineer specializing in the synthesis and design of orthopedic materials as well as their failure in a clinical applica-tion____” (Ayers Report at 2) (internal citations omitted). His “experience includes work on the synthesis/manufacture of CoCrMoC[] alloys bone ingrowth to porous materials the corrosion of biomedical alloys and how the corrosion products of these alloys affect bone and other tissues.” (Id.) (internal citations omitted).

Ayers reviewed images of Plaintiffs ex-planted Conserve cup and ball, Plaintiffs medical records, the Jarrell Report, and the Laposata Report in forming his opinion. (Id.). Ayers does not discuss Plaintiffs hip implant specifically, but discusses general issues with Wright Medical’s Conserve cup, opining that Wright Medical’s implant could produce “localized discoloration” evidencing metallosis that could lead to the failure of the implant. (Id. at 5).

b) Analysis

Defendants argue that Ayers’ opinion is based solely on the Operative Report, and that Ayers’ opinion is that the Operative Report’s indication of “staining” in Plaintiffs tissue resulted from metallosis. (Me-tallosis Motion at 12). Defendants argue that Ayers testified that he focused on surgical observations in the Operative Report that the “tissue itself [was] discolored.” (Tr., of Jan. 8, 2015, Ayers Dep. [53.15] (“Ayers Dep.”) at 57:20). Ayers explained that tissue discoloration indicates the presence of metallosis. (Id. at 58:2-13). Defendants appear to argue that because the Operative Report did not state that Plaintiffs tissue was stained, but discolored, Ayers use of “staining” in his report renders his opinion unreliable.

While Rasmussen did not use the word “staining” in his Operative Report, metal-losis involves the release of metals into the body, often signified by tissue staining and discoloration. (See, e.g., Laposata Supplemental Report at 2 (“Metallosis is a grey/ black tissue discoloration due to the buildup of metal debris and corrosion products in the tissues of the body”); Dr. Edward F. DiCarlo’s expert report, dated December 22, 2014, [53.12] at 3 (in “some cases, it is possible to see a large amount of metal in the tissue with the naked eye. In this case, the tissue has a gray or black appearance depending on the amount of metallic debris in the tissue. Such a finding is often referred to as ‘metallosis.’ ”)). Ayers makes the same point, noting that he interpreted the Operative Report’s reference to metallosis as staining. (Ayers Dep. at 91:15-92:9).

Defendants’ sole objection to the admissibility of Ayers’ expert opinion, that he characterized the tissue discoloration as “staining” — a term not used in the Operative Report — is unpersuasive. This alone is not a credible reason to exclude Ayers’ opinion and in the absence of a reasoned basis to exclude Ayers’ opinion testimony, the Court concludes that Plaintiff satisfies the requirements of Daubert and his opinion is not required to be excluded on the basis of his characterization of the discoloring as staining. See City of Tuscaloosa, 158 F.3d at 562-63.

7. Dr. Joel Bach, Ph.D.

a) Expert Opinion

Dr. Joel M. Bach (“Bach”), a mechanical engineer employed by Thin Air Engineering, LLC, was retained by Plaintiff, and prepared an expert report dated November 21, 2014 [53.16] (“Bach Report”). In reaching the opinion he offers in this case, Bach’s review included Plaintiffs medical records, Plaintiffs February 27, 2014, deposition transcript, photographs of Plaintiffs explanted components, the Jarrell Report, and Dr. Jay M. Vincel-li’s (“Vincelli”) July 16, 2014, and November 20, 2014, reports. (Bach Report at 1-2). Bach is expected to testify regarding hip biomechanics, the history of hip replacement components, the biomechanics of total hip replacement, and the biome-chanics of metal-on-metal total hip replacement. Bach opines that Plaintiffs Conserve implant “led to corrosion, wear, and ion release, which in turn led to loss of osseointegration of the cup [of Plaintiffs hip implant device]. This directly affected the stability of the cup, which caused the cup to loosen, and ultimately fail in Mrs. Christiansen, resulting in the need for the 2012 revision.” (Id. at 8). In reaching this opinion, Bach relies on Vincelli’s examination of Plaintiffs explanted components and Vincelli’s finding of “ ‘deep and shallow scratches, gouges, and pitting’ on both the femoral head and acetabular cup.” (Id. at 7). Bach further notes that Vincelli found “this heavy surface damage is consistent with a lower gross-wearing artieu-lating couple,” and the “acetabular shell exhibited minimal bony ingrowth, which is indicative of poor osseointegration.” (Id.). Bach notes that Rasmussen observed me-tallosi