Full opinion text
MEMORANDUM OPINION AND ORDER (Daubert Motions) JOSEPH R. GOODWIN, District Judge. Pending before the court are the defendants’ (1) Motion to Limit the Testimony of Bruce Rosenzweig, M.D. [Docket 149]; (2) Motion to Limit the Testimony of Prof. Dr. Med. Bernd Klosterhalfen [Docket 152]; (3) Motion to Exclude Opinion Testimony of John F. Steege, M.D. [Docket 155]; (4) Motion to Exclude Certain Opinions of Jerry G. Blaivas, M.D. [Docket 157]; (5) Motion to Exclude the Opinions and Testimony of Dr, Scott Guelcher, Ph.D. [Docket 181]; (6) Motion to Exclude the Opinions and Testimony of Dr. Russell Dunn, Ph.D., P.E. [Docket 183]; and (7) Motion to Exclude the Opinions and Testimony of Dr. Abhay Pandit, Ph.D. [Docket 185]; and the plaintiffs’ (1) Motion to Exclude the Opinions and Testimony of Michael Greenberg, M.D., M.P.H. [Docket 165]; (2) Motion to Exclude Certain Opinions and Testimony of Christina Pramudji, M.D. [Docket 167]; (3) Motion to Exclude the Opinions and Testimony of Harry Johnson, Jr., M.D. [Docket 169]; (4) Motion to Exclude the Opinions and Testimony of Daniel J. Sexton, M.D. [Docket 171]; and (5) Motion to Exclude the Opinions and Testimony of Wenxin Zheng, M.D. [Docket 175], For the reasons explained below, the defendants’ motions with respect to Dr. Rosenzweig [Docket 149], Dr. Dunn [Docket 183], Dr.' Steege [Docket 155], and Dr. Pandit [Docket 185] are GRANTED in part and DENIED in part. The defendants’ motion with respect to Dr. Kloster-halfen [Docket 152] is DENIED in part and RESERVED in part. The defendants’ motion with respect to Dr. Blaivas [Docket 157] is GRANTED in part and DENIED in part and RESERVED in part. The defendants’ motion with respect to Dr. Guelcher [Docket 181] is DENIED. The plaintiffs’ motion with respect to Dr. Greenberg [Docket 165] is GRANTED. The plaintiffs’ motions with respect to Dr. Pramudji [Docket 167] and Dr. Zheng [Docket 175] are GRANTED in part and DENIED in part. The plaintiffs’ motions with respect to Dr. Sexton [Docket 171] and Dr. Johnson [Docket 169] are DENIED. I. Background This case is one of more than 60,000 in seven MDLs that have been assigned to me by the Judicial Panel on Multidistrict Litigation. This case involves surgical mesh products manufactured and sold by the defendants, Ethicon, Inc. and Johnson & Johnson, Inc. (collectively, “Ethicon”), to treat female stress urinary incontinence. The device at issue is Ethicon’s Gynecare TVT Obturator (“TVT-O”), which was implanted in the plaintiff, Ms. Huskey. The TVT-0 is a medical device that includes a mechanism used to place a mesh tape, or sling, under the urethra to provide support to the urethra. The parties have brought several Daubert challenges to proposed experts. II. Legal Standards Under Federal Rule of Evidence 702, expert testimony is admissible if it will “help the trier of fact to understand the evidence or to determine a fact in issue” and (1) is “based upon sufficient facts or data” and (2) is “the product of reliable principles and methods” which (3) has been reliably applied “to the facts of the case.” Fed.R.Evid. 702. A two-part test governs the admissibility of expert testimony. The evidence is admitted if it “rests on a reliable foundation and is relevant.” Daubert v. Merrell Dow Pharm., 509 U.S. 579, 597, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993). The proponent of expert testimony does not have the burden to “prove” anything. He must, however, “come forward with evidence from which the court can determine that the proffered testimony is properly admissible.” Md. Cas. Co. v. Therm-O-Disc, Inc., 137 F.3d 780, 783 (4th Cir.1998). The district court is the gatekeeper. It is an important role: “[E]xpert witnesses have the potential to be both powerful and quite misleading[;]” the court must “ensure that any and all scientific testimony ... is not only relevant, but reliable.” Cooper v. Smith & Nephew, Inc., 259 F.3d 194, 199 (4th Cir.2001) (citing Westberry v. Gislaved Gummi AB, 178 F.3d 257, 261 (4th Cir.1999) and Daubert, 509 U.S. at 588, 595, 113 S.Ct. 2786). I “need not determine that the. proffered expert testimony is irrefutable or certainly correct”&emdash;“[a]s with all other admissible evidence, expert testimony is subject to testing by ‘vigorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof.’” United States v. Moreland, 437 F.3d 424, 431 (4th Cir.2006) (quoting Daubert, 509 U.S. at 596, 113 S.Ct. 2786); see also Md. Cas. Co., 137 F.3d at 783 (noting that “[a]ll Daubert demands is that the trial judge make a ‘preliminary assessment’ of whether the proffered testimony is both reliable ... and helpful”). Daubert mentions specific factors to guide the overall relevance and reliability determinations that apply to all expert evidence. They include (1) whether the particular scientific theory “can be (and has been) tested”; (2) whether the theory “has been subjected to peer review and publication”; (3) the “known or potential rate of error”; (4) the “existence and maintenance of standards controlling the technique’s operation”; and (5) whether the technique has achieved “general acceptance” in the relevant scientific or expert community. United States v. Crisp, 324 F.3d 261, 266 (4th Cir.2003) (quoting Daubert, 509 U.S. at 593-94, 113 S.Ct. 2786). Despite these factors, “[t]he inquiry to be undertaken by the district court is ‘a flexible one’ focusing on the ‘principles and methodology’ employed by the expert, not on the conclusions reached.” Westberry, 178 F.3d at 261 (quoting Daubert, 509 U.S. at 594-95, 113 S.Ct. 2786); see also Kumho Tire Co. v. Carmichael, 526 U.S. 137, 150, 119 S.Ct. 1167, 143 L.Ed.2d 238 (1999) (“We agree with the Solicitor General that ‘[t]he factors identified in Dau-bert may or may not be pertinent in assessing reliability, depending on the nature of the issue, the expert’s particular expertise, and the subject of his testimony.’ ”) (citation omitted); see also Crisp, 324 F.3d at 266 (noting “that testing of reliability should be flexible and that Daubert’s five factors neither necessarily nor exclusively apply to every expert”). With respect to relevancy, Daubert also explains: Expert testimony which does not relate to any issue in the case is not relevant and, ergo, non-helpful. The consideration has been aptly described by Judge Becker as one of fit. Fit is not always obvious, and scientific validity for one purpose is not necessarily scientific validity for other, unrelated purposes.... Rule 702’s helpfulness standard requires a valid scientific connection to the pertinent inquiry as a precondition to admissibility. Daubert, 509 U.S. at 591-92, 113 S.Ct. 2786 (internal citations and quotation marks omitted). Finally, in several of the instant Daubert motions, a specific scientific methodology comes into play, dealing with differential diagnoses or etiologies. “Differential diagnosis, or differential etiology, is a standard scientific technique of identifying the cause of a medical problem by eliminating the likely causes until the most probable one is isolated.” Westberry, 178 F.3d at 262. The Fourth Circuit has stat-. ed that: A reliable differential diagnosis typically, though not invariably, is performed after “physical examinations, the taking of medical histories, and the review of clinical tests, including laboratory tests,” and generally is accomplished by determining the possible causes for the patient’s symptoms and then eliminating each of these potential causes until reaching one that cannot be ruled out or determining which" of those that cannot be excluded is the most likely. Id. A reliable differential diagnosis passes scrutiny under Daubert. An unreliable differential diagnosis is another matter: A differential diagnosis that fails to take serious account of other potential causes may be so lacking that it cannot provide a reliable basis for an opinion on causation. However, “[a] medical expert’s causation conclusion should not be excluded because he or she has failed to rule out every possible alternative cause of a plaintiffs illness.” The alternative causes suggested by a defendant “affect the weight that the jury should give the expert’s testimony and not the admissibility of that testimony,” unless the expert can offer “no explanation for why she has concluded [an alternative cause offered by the opposing party] was not the sole cause.” Id. at 265-66 (internal citations omitted). III. Ethicon’s Daubert Motions Ethicon seeks to limit or exclude the testimony of Dr. Bruce Rosenzweig, Dr. Bernd Klosterhalfen, Dr. Scott Guelcher, Dr. Russell Dunn, Dr. Abhay Pahdit, Dr. John F. Steege, and Dr. Jerry G. Blaivas. I will address each proposed expert in turn. Before I begin, I will address two arguments that apply to many of Ethicon’s Daubert motions. First, as I have repeated throughout these MDLs, I will not permit the parties to use experts to usurp the jury’s fact-finding function to determine Ethicon’s state of mind, or whether Ethicon acted reasonably. See, e.g., In re C.R. Bard, Inc., 948 F.Supp.2d 589, 611, 629 (S.D.W.Va.2013); In re Ethicon, Inc., Pelvic Repair Sys. Prods. Liab. Litig., 2:12-MD-02327, 2014 WL 186872, at *6, *21 (S.D.W.Va. Jan. 15, 2014). While an expert may testify as to a review of internal corporate documents solely for the purpose of explaining the basis for his or her opinions — assuming the opinions are otherwise admissible — Ethicon’s knowledge, state of mind, or other matters related to corporate conduct and ethics are not appropriate subjects of expert testimony because opinions on these matters will not assist the jury. Similarly, “opinion testimony that states a legal standard or draws a legal conclusion by applying law to the facts is generally inadmissible.” United States v. McIver, 470 F.3d 550, 562 (4th Cir.2006). I will not repeatedly parse the expert reports and depositions of each expert in relation to this same objection. I trust that able counsel in this matter will tailor expert testimony at trial accordingly. Second, Ethicon repeatedly argues that expert opinions relating to polypropylene do not apply to the Prolene mesh used in the TVT-O. Ethicon states that experts testifying about polypropylene fail “to account for the important chemical differences between generic polypropylene and PROLENE, which is an isotactic form of polypropylene that has been treated with two proprietary antioxidants.” (See Defs.’ Mem. of Law in Supp. of Mot. to Exclude the Test, and Ops. of Dr. Scott Guelcher, Ph.D. [Docket 182], at 4). This appears to be an argument wholly conceived by lawyers, unfounded in science. The experts in this case, including Ethi-con’s experts, testify as to “polypropylene” and its propensities. This is a strong indication that Ethicon’s argument is disingenuous. For example, Dr. Michael Greenberg, an Ethicon expert, writes in his report that “polypropylene is a safe biomaterial with an extensive history of use inside the human body.” (Greenberg Report [Docket 211-4], at 14). Another Ethicon expert, Dr. Harry Johnson writes that “[polypropylene is the most used material for pelvic floor repair.” (Johnson Report [Docket 212-2], at 24). Further, Dr. Christina Pramudji writes in support of Ethicon that “[pjolypropylene material is safe and effective as a surgical implant.” (Pramudji Report [Docket 209-5], at 25). It is clear that the experts in this case do not consider Prolene to be different from polypropylene for the purposes of their opinions in this case. Therefore, to the extent that Ethicon contends that an expert’s opinions are unreliable or unhelpful because they do not account for the “important chemical differences” between polypropylene and Prolene, this argument is rejected. A. Dr. Bruce Rosenzweig Dr. Rosenzweig is a urogyneeologist and professor of obstetrics and gynecology. He offers several different opinions, each of which Ethicon contends is improper: (1) opinions regarding the sufficiency of warnings set out in the TVT-0 Instructions for Use (“IFU”) and other promotional materials, (2) opinions that Ethicon failed to provide adequate training, (3) opinions that the TVT-0 causes an increased risk of infection, (4) opinions that the TVT-0 degrades in vivo and is subject to fraying and particle loss, and (5) opinions regarding mesh shrinkage or contracture. I will address each opinion in turn. 1. Opinions Related to Sufficiency of Warnings on the IFU and Promotional Materials Dr. Rosenzweig opines that the TVT-O’s IFU was inadequate, that Ethi-con failed to inform patients and physicians about particular risks of the TVT-O, and that the TVT-O’s marketing materials were inaccurate or incomplete. (See Rosenzweig Report [Docket 201-1], at 3). Ethicon first argues generally that Dr. Rosenzweig is not qualified to testify about product warnings because he has not drafted an IFU. While it is true that Dr. Rosenzweig has not personally drafted an IFU, Dr. Rosenzweig’s testimony reveals that he has consulted on product warnings in the past: Q. Have you ever prepared IFUs? A. Well, I did work with Gish Biomedical to get the information that they needed to put in the amnioinfusion catheter IFU. Q. Did you actually draft the IFU? A. No, I did not. I worked as a consultant on that. Q. Have you ever drafted an IFU? A. No, I have not. Q. Have you ever drafted a patient brochure? A. I worked on the amnioinfusion catheter brochures, yes. (Rosenzweig Dep. [Docket 149-3], at 53:17-54:4). Dr. Rosenzweig also testified that he served on another company’s scientific advisory committee that worked on similar documents. (See id. at 54:10-12). In his expert report, Dr. Rosenzweig states that he has reviewed “numerous” IFUs for a “variety of products including mesh products in order to understand the proper way to use the device and to gain knowledge about the complications and adverse events associated with the device.” (Rosenzweig Report [Docket 201-1], at 55). Further, as a urogynecologist, Dr. Rosenzweig is qualified to opine about the risks of the TVT-0 and pelvic mesh surgery and whether those risks were adequately expressed on the TVT-O’s IFU. I therefore FIND that Dr. Rosenzweig is qualified "to testify generally on the adequacy of the TVT-O’s product warnings and marketing materials. . Finding Dr. Rosenzweig qualified to opine generally about the TVT-O’s warnings and marketing materials, I now turn to Ethicon’s specific objections in relation to particular product warning opinions, a. Cancer The plaintiffs state that Dr. Rosenzweig will not testify about cancer. (See Pis.’ Resp. to Defs.’ Mot. to Limit the Test, of Bruce Rosenzweig, M.D. (“Pis.’ Resp.”) [Docket 200], at 6). Accordingly, Ethicon’s motion on this subject is DENIED as moot. b. Cytotoxicity Dr. Rosenzweig states in his expert report that an internal Ethicon document suggested that polypropylene mesh was cytotoxic. (See Rosenzweig Report [Docket 201-1], at 105). Cytotoxicity refers to a material’s potential to cause cell death. Dr. Rosenzweig writes that Ethi-con failed to undertake testing “to determine whether the marked cytotoxicity found in the TVT mesh had long term consequences for permanent human use.” (Id. .at 105-06). He then opines that Ethi-con failed to act as a “reasonably prudent medical device manufacturer” because it “failed to inform physicians and their patients about the. risk of its mesh being cytotoxic[ ].” (Id. at 106). According to Ethicon, cytotoxicity testing “does not represent in vivo testing, and toxicological experience is required to extrapolate the results to humans.” (Mem. in Supp. of Mot. to Limit the Test, of Bruce Rosenzweig, M.D. (“Defs.’ Mem.”) [Docket 150], at 6). Ethicon therefore argues that this testimony exceeds Dr. Rosenzweig’s qualifications because he does not have toxicological experience, and he admits that he has never conducted toxicity or cytotoxicity testing of mesh. (See Rosenzweig Dep. [Docket 149-3], at 222:4-6). Ethicon also argues that this testimony is unreliable because the internal Ethi-con study cited by Dr. Rosenzweig states that “this clinical data provides important evidence that the cytotoxicity of the [polypropylene] mesh observed in vitro does not translate into any clinical significance or adverse patient outcomes.” (Cytotoxicity Risk Assessment for the TVT (Ulmsten) Device [Docket 149-8], at 2). I FIND that Dr. Rosenzweig is qualified to offer the opinion that Ethicon failed to inform physicians about the risk that the TVT-0 is cytotoxic. Although Dr. Rosenzweig is not a toxicologist, he stated that he regularly encounters cytotoxicity in his practice, including in women who have polypropylene mesh implants. (See Rosenzweig Aff. [Docket 201-4] ¶ 4). He also stated that he has removed mesh implants, including the TVT, as a result of cytotoxicity. (See id.). I further FIND that this opinion is sufficiently reliable. Dr. Rosenzweig relies on an internal Ethicon finding that the mesh used in the TVT-0 was cytotoxic. Further, Dr. Rosenzweig states that the potential for cytotoxicity is important information that physicians need to know. (See Rosenzweig Report [Docket 201-1], at 106). To the extent that Ethicon believes cytotoxicity is not clinically significant, it may cross examine Dr. Rosenzweig on that issue. Therefore, Ethicon’s motion with respect to Dr. Rosenzweig’s opinions about the failure to warn about cytotoxicity is DENIED. However, I FIND that Dr. Rosenzweig is not qualified to opine that Ethicon’s testing was insufficient. There is no indication that Dr. Rosenzweig has any experience or knowledge on the appropriate testing a medical device manufacturer should undertake. Therefore, Dr. Rosenzweig’s testimony that Ethicon failed to appropriately test for cytotoxicity is EXCLUDED. c. TVT-0 Appropriateness for Certain Populations Dr. Rosenzweig will also testify that “Ethicon promoted the TVT-0 as a ‘reproducible’ technique that was appropriate for all patients,” when in fact it was less efficacious for certain types of women, including obese women, older women, active women, diabetics, smokers, Asian women, and African-American women. (Rosenzweig Report [Docket 201-1], at 77-80). He claims that Ethicon should have warned physicians of risks to these different populations. In support, he simply reviews deposition testimony and internal documents of Ethicon employees expressing concerns about the TVT-O’s adaptability to different populations. For instance, Dr. Rosenzweig quotes deposition testimony of Ethicon’s Medical Director to show that “obese patients do not fare well with these devices.” (Id. at 77). He also reviews a document wherein the inventor of the TVT-0 stated that the TVT-0 was inappropriate for treatment in younger, active women. (See id. at 78). As the plaintiffs concede, much of this opinion is not relevant to Ms. Huskey’s case and should be excluded. (See Pis.’ Resp. [Docket 200], at 8-9). The only part that is relevant is the TVT-O’s appropriateness for younger, active women, a category into which Ms. Huskey falls. But it is not helpful to the jury to have Dr. Rosenzweig read a document explaining what the inventor of the TVT-0 thought about this. The jury is capable of reading that document itself. See In re Prempro Prods. Liab. Litig., 554 F.Supp.2d 871, 887 (E.D.Ark.2008); Fed.R.Evid. 702 (“the expert’s scientific, technical, or other specialized knowledge” must “help the trier of fact to understand the evidence”). Therefore, Dr. Rosenzweig’s opinion that Ethi-con should have warned that the TVT-0 could be more dangerous for certain populations is EXCLUDED. d. Adverse Event Reporting Dr. Rosenzweig opines that “Ethicon’s collection and reporting of adverse events and complications to physicians and patients was incomplete, inaccurate, and misleading.” (Rosenzweig Report [Docket 201-1], at 98). Ethicon argues that Dr. Rosenzweig is unqualified to offer this opinion, and it is unreliable. The plaintiffs concede that Dr. Rosenzweig will not offer this opinion at trial. (Pis.’ Resp. [Docket 200], at 9-10). Therefore, this aspect of Ethicon’s motion is DENIED as moot. 2.Failure to Provide Adequate Training Dr. Rosenzweig opines that Ethicon “failed to provide adequate training” to physicians regarding the use of the TVT-O. (Rosenzweig Report [Docket 201-1], at 3). However, instead of commenting on the quality of training, Dr. Rosenzweig reviews corporate documents showing that Ethicon cut funding for professional trainings which Dr. Rosenzweig says “contrasted” with Ethicon’s corporate credo. (See Rosenzweig Report [Docket 201-1], at 74-77). Not only is this opinion simply a narrative review of corporate documents, which is not helpful to the jury, but it is unreliable because Dr. Rosenzweig fails to describe the basis for his opinion that Ethicon’s training was inadequate. Therefore, this opinion is EXCLUDED. 3.Infections Dr. Rosenzweig opines that the TVT-0 mesh and implantation procedure carry an increased risk of infection. (See id. at 26). Ethicon argues that this opinion is not helpful to the jury because Ms. Huskey has not suffered from a mesh-related infection. However, the plaintiffs clearly indicated on their Plaintiff Fact Sheet that Ms. Huskey suffered from an infection. (See PI. Fact Sheet [Docket 161-2], at 6). Further, Dr. Siddique, who partially ex-planted Ms.-Huskey’s mesh, testified that Ms. Huskey’s eroded mesh caused an infection. (See Siddique Dep. [Docket 227-2], at 41:2-14). He also testified that Ms. Huskey suffered from chronic inflammation caused by a chronic infection of the eroded mesh. (See Siddique Dep. [Docket 201], at 63:8-11). Therefore, contrary to Ethicon’s arguments, infections are a fact in issue in this case, and Ethicon’s motion, as presented on this issue, is DENIED. 4.Degradation and Fraying Dr. Rosenzweig will testify that the TVT-0 is defective because its mesh degrades in vivo and is subject to fraying and particle loss. (See Rosenzweig Report [Docket 201-1], 11-20, 34-46). Further, Dr. Rosenzweig will testify that Ms. Hus-key’s mesh degraded, frayed, and lost particles. Ethicon first argues that Dr. Rosenzweig is unqualified to offer these opinions because he does not have a background in polymer chemistry, has never studied biomaterials, and has never done any bench or lab research regarding polypropylene. I disagree. As I stated in relation to Lewis v. Johnson & Johnson, Simply becáuse Dr. Rosenzweig has not personally performed pathology research on polypropylene explants does not necessarily render him unqualified under Rule 702 to offer opinions regarding the suitability of the TVT device for implantation. An expert may be qualified by “knowledge, skill, experience, training, or education.” Fed.R.Evid. 702. “One knowledgeable about a particular subject need not be precisely informed about all details of the issues raised in order to offer an expert opinion.” Thomas J. Kline, Inc. v. Lorillard, Inc., 878 F.2d 791, 799 (4th Cir.1989). Dr. Rosenzweig has performed over a thousand pelvic floor surgical procedures, and over 200 surgeries dealing with complications related to synthetic mesh, including the removal of numerous TVT devices. Dr. Rosenzweig testified that as early as 2004 or 2005, he determined, as a result of explanting mesh products, that polypropylene degrades in the human body. Further, he cites dozens of studies and academic papers in his expert report to support his opinion that vaginally implanted polypropylene mesh degrades. I therefore FIND that Dr. Rosenzweig is qualified to offer the opinion that the TVT is not suitable for permanent implantation to treat stress urinary incontinence. In re Ethicon, Inc., Pelvic Repair Sys. Prods. Liab. Litig., 2:12-MD-02327, 2014 WL 186872, at *20 (S.D.W.Va. Jan. 15, 2014) (internal citations and quotation marks omitted). I ADOPT that holding here. With respect to Dr. Rosenzweig’s general causation opinions that the mesh used in the TVT-0 degrades, frays, and loses particles, Ethicon contends that these opinions are not helpful to the jury. According to Ethicon, “neither Dr. Rosenzweig nor any of Plaintiffs’ other experts can reliably testify (1) that the mesh in Ms. Huskey’s TVT-0 device actually degraded, frayed, or lost particles, or (2) that any such degradation, fraying, or particle loss proximately caused Ms. Huskey’s injuries.” (Defs.’ Mem. [Docket 150], at 13). Ethicon is incorrect that Dr. Rosenzweig’s general causation testimony — that the TVT-0 mesh can degrade, fray, or lose particles— should be excluded under Rule 702 simply because the plaintiffs might fail to carry their burden as to specific causation — that Ms. Huskey was injured by the TVT-0 mesh. If Ethicon believes the plaintiffs ultimately fail to carry their burden, they are free to make that argument at trial. With respect to Dr. Rosenzweig’s specific causation opinions, Ethicon contends that they are unreliable because none of the plaintiffs’ experts tested Ms. Huskey’s explanted mesh. The parties agree that Ms. Huskey’s mesh was discarded by the hospital before the parties had an opportunity to test it. Therefore, Ethicon argues that there is no way to test any of Dr. Rosenzweig’s opinions about Ms. Huskey’s mesh. See Daubert, 509 U.S. 579, 593, 113 S.Ct. 2786 (1993) (“[A] key question to be answered in determining whether a theory or technique is scientific knowledge that will assist the trier of fact will be whether it can be (and has been) tested.”). I FIND that Dr. Rosenzweig’s specific causation testimony on degradation, fraying, and particle loss is not sufficiently reliable under Rule 702. Although he has not examined Ms. Huskey’s mesh, he formed his opinion by conducting an examination of Ms. Huskey and determining that the tissues surrounding the remaining mesh were tender. (See Rosenzweig Dep. [Docket 149-2], at 281:25-282:5; 283:16-22). He stated that “[w]hen I examine her, I feel a very tender band along the left side of the vagina. That could represent mesh that’s frayed, pieces of mesh that are still there, or a scar plate that formed when — before it was excised.” (Rosenzweig Dep. [Docket 201-9], at 255:7-11). He agreed that tenderness during an examination can result from “numerous things,” including degradation. (Rosenzweig Dep. [Docket 149-2], at 282:7-9). He then stated that of his more than 200 explant surgeries, it is “not [] infrequent” that he sees actual degradation on the explanted mesh. (Rosenzweig Dep. [Docket 201-9], at 275:15-276:14). Based on that experience, and his “work in seeing mesh degradation,” he opined that Ms. Huskey’s remaining mesh is “more likely than not undergoing degradation.” (Id. at 276:16-277:3). Finally, when counsel suggested that he was essentially guessing whether Ms. Huskey’s mesh had degraded, he stated that “I’m using my experience, my medical knowledge, to make an opinion with a reasonable degree of medical certainty.” (Rosenzweig Dep. [Docket 149-2], at 283:12-14). That is not enough to indicate that his opinions are reliable. In addition to the fact that Dr. Rosenzweig has not seen or tested Ms. Huskey’s mesh, he does not explain how tenderness indicates that Ms. Huskey’s mesh has degraded. Nor does he attempt to rule out the other potential causes for tenderness that he identified, even though he admits there could be “numerous” others. (Rosenzweig Dep. [Docket 149-2], at 282:7); Cooper v. Smith & Nephew, Inc., 259 F.3d 194, 202 (4th Cir.2001) (“[I]f an expert utterly fails to consider alternative causes or fails to offer an explanation for why the proffered alternative cause was not the sole cause, a district court is justified in excluding the expert’s testimony.”). Quite simply, Dr. Rosenzweig is using other explants to draw an inference about Ms. Huskey’s explant. But he does not say precisely how often he finds degradation on explants. He simply states that such a finding is “not [ ] infrequent.” (Rosenzweig Dep. [Docket 201-9], at 275-76). Without proper indicia of reliability, Dr. Rosenzweig’s specific causation theories regarding degradation, fraying, and particle loss are EXCLUDED. This result does not, as the plaintiffs suggest, unfairly punish them for a missing piece of evidence over which they had no control. Rule 702 and Daubert are clear that an expert’s testimony must be based on “reliable principles and methods.” Fed. R.Evid. 702. That is not present here. B. Dr. Bernd Klosterhalfen Dr. Klosterhalfen offers general causation opinions related to infection, degradation, particle loss, shrinkage, and effective porosity of the TVT-0 mesh. This is not the first time I have reviewed Daubert challenges to Dr. Klosterhalfen’s opinions on these topics. See In re C.R. Bard, Inc., 948 F.Supp.2d 589, 617-22 (S.D.W.Va.2013); In re Ethicon, Inc., Pelvic Repair Sys. Prods. Liab. Litig., 2:12-MD-02327, 2014, WL 186872, at *10-11 (S.D.W.Va. Jan. 15, 2014). Wisely wanting to avoid rehashing old arguments, most of Ethi-con’s motion argues that Dr. Klosterhal-fen’s opinions are not helpful to the jury in this case because (1) Ms. Huskey did not develop an infection in this case, and (2) the plaintiffs cannot link degradation, particle loss, shrinkage, or effective porosity to Ms. Huskey’s injuries. (See Mem. in Supp. of Mot. to Limit Test, of Prof. Dr. Med. Bernd Klosterhalfen [Docket 154], at 3, 5, 11-12). First, as I have already explained, there is evidence that Ms. Hus-key developed an infection in connection with her TVT-0 implant. Second, simply because Dr. Klosterhalfen’s opinions are limited to general causation does not mean they are not helpful to the jury. If Ethi-con believes the plaintiffs cannot establish that the TVT-0 caused Ms. Huskey’s injuries, it can address this issue at trial. Ethicon also challenges the reliability of two of Dr. Klosterhalfen’s opinions: those based on degradation and those based on effective porosity. Ethicon argues that Dr. Klosterhalfen’s testimony about surface degradation should be excluded because Dr. Klosterhalfen “cannot reliably testify that degradation has any clinical significance.” (Id. at 9). The plaintiffs failed to respond to this argument. Without a full expert report, I am unable to determine the full scope of Dr. Klosterhal-fen’s opinions and their foundation. Therefore, I RESERVE for trial my ruling on Dr. Klosterhalfen’s degradation opinions. Ethicon also argues that Dr. Klosterhal-fen’s testimony about effective porosity is unreliable because in his deposition, “Plaintiffs failed to elicit any testimony that Dr. Klosterhalfen was familiar with the details of’ the studies on which those opinions are based. (Id. at 12). But an expert witness is not required to be familiar with the particular details of the studies on which he bases his opinion, as long as an expert in that particular field reasonably relies on the opinions contained in those studies. See Fed.R.Evid. 703; Ferrara & DiMercurio v. St. Paul Mercury Ins. Co., 240 F.3d 1, 9 (1st Cir.2001) (“[W]hen an expert relies on the opinion of another, such reliance goes to the weight, not to the admissibility of the expert’s opinion.”). Ethicon also argues that Dr. Klosterhalfen’s opinions are not reliable-because they have not been “validated.” The plaintiffs fail to respond to this argument, and without an expert report, I again cannot determine the precise bases for these opinions. I therefore also RESERVE this ruling for trial. Accordingly, Ethicon’s motion to exclude Dr. Klosterhalfen is DENIED in part with the caveat that I RESERVE RULING on the admissibility of Dr. Klosterhalfen’s degradation and effective porosity opinions. C. Dr. Scott Guelcher Dr. Guelcher holds a Ph.D. in chemical engineering and a post-doctoral degree in biomedical engineering. He is currently a professor of chemical and biomolecular engineering. He offers the following opinions in this case: (1) the human body “does not stop responding” to mesh until it is removed entirely, (2) the “dynamic environment where these meshes are implanted coupled with the chronic response of the body leads to polymer instability, embrittlement, structural degradation and other changes,” (3) it is not possible to guarantee that the TVT-0 will perform its intended function after implantation, and (4) the TVT-0 mesh is not inert and can change after implantation, which may lead to adverse events for the patient. (Guelcher Report [Docket 203-1], at 3). Ethicon first argues that Dr. Guelcher’s general causation testimony is not helpful to the jury because the plaintiffs cannot •prove specific causation and because no expert can say that degradation is clinically significant. As I have already explained, general causation opinions are helpful to the jury and fit the facts of this ease regardless of whether the plaintiffs may ultimately fail to carry their burden to show that Ms. Huskey was harmed by her TVT-0 implant. Second, Ethicon argues that Dr. Guelcher’s opinions are unreliable and unhelpful because they relate only to generic polypropylene, not Prolene mesh. This argument, too, has already been rejected. Therefore, Ethicon’s motion to exclude Dr. Guelcher is DENIED. D. Dr. Russell Dunn Dr. Dunn holds a Ph.D. in chémical engineering and consults on chemical and polymer process and product design issues. (See Dunn Report [Docket 202-1], at 1). He will opine that Ethicon’s risk assessment process for the TVT-0 was inadequate and that the TVT-0 is defective. (See id. at 4). Dr. Dunn also filed a rebuttal report challenging the opinions of several of Ethicon’s experts. Ethicon challenges Dr. Dunn’s risk assessment opinion, his opinion at his deposition that polyvinylidene fluoride, or PVDF, is a safer alternative design, and his rebuttal of Ethicon’s experts. 1.Risk Assessment Opinions Dr. Dunn offers opinions regarding Ethicon’s risk assessment process — which he calls “Failure Mode & Effects Analysis” — during the design of the TVT-O. He opines that Ethicon’s “design documents did not contemplate several [Failure Mode & Effects Analysis] issues and that Ethi-con did not have an adequate quality system in place” with respect to Prolene. (Dunn Report [Docket 202-1], at 15). He contends that Ethicon’s risk assessment processes failed to account for “polypropylene’s inherent tendency to oxidize.” (Id.). Ethicon argues that this opinion is not helpful to the jury because Dr. Dunn fails to articulate any effect a different quality control process would have had on the TVT-O’s design. (See Mem. in Supp. of Defs.’ Mot. to Exclude the Test, and Ops. of Dr. Russell Dunn, Ph.D., P.E. (“Defs.’ Mem.”) [Docket 184], at 14). Ethicon frames the issue incorrectly. An expert’s testimony must help the jury to “understand the evidence or to determine a fact in issue.” Fed.R.Evid. 702. This testimony assists the jury in determining whether Ethicon was negligent in designing the TVT-O. Therefore, Ethicon’s motion to exclude Dr. Dunn’s risk assessment opinions is DENIED. 2.Safer Alternative Designs Although his expert report does not contain any opinions about safer alternative designs, Dr. Dunn testified in his deposition that mesh using PVDF would be a safer alternative design for the TVT-O. (See Dunn Dep. [Docket 183-3], at 123:8-20). Ethicon argues that any opinions related to safer alternative designs should be excluded because Dr. Dunn did not disclose them in his expert report pursuant to Federal Rule of Civil Procedure 26(a)(2)(B), and because they are unreliable. The plaintiffs did not respond to this argument. Accordingly, Dr. Dunn’s opinions regarding safer alternative designs are EXCLUDED. 3.Rebuttal Report Dr. Dunn rebuts the opinions of Ethicon’s experts, Dr. Kevin Ong, Dr. Shelby Thames, and Timothy Ulatowski. Specifically, he criticizes the conclusions that these experts draw about the Ethicon canine study and Prolene’s vulnerability to oxidation. (See Dunn Rebuttal Report [Docket 202-2], at 1-2). Ethicon contends that this rebuttal report is unreliable because it is not supported by scientific literature. (See Defs.’ Mem. [Docket 184], at 17). Despite Ethicon’s objection, I FIND that Dr. Dunn’s rebuttal report has sufficient indicia of reliability. His rebuttal report simply criticizes the methods Ethi-con’s experts used to come to their conclusions. Dr. Dunn writes that the Ethicon canine study failed “to recount its materials and methods of reproducibility” and used “a control group that does not comport with the implanted Prolene samples.” (Dunn Rebuttal Report [Docket 202-2], at 1). He contends that Ethicon’s experts ignored polypropylene’s propensity to degrade, despite the use of antioxidants. (See id,.). He cites several scientific studies for his opinions and states that the sources relied on by Ethicon’s experts “favor specific data while ignoring others[.]” (Id.). Therefore, Ethicon’s motion on this issue is DENIED. E. Dr. Abhay Pandit Dr. Pandit is a biomedical engineer. He plans to testify that the TVT-0 was defectively designed and that Ethicon failed to adequately test the TVT-O. Ethicon moves to preclude Dr. Pandit’s testimony in its entirety. 1. Leaching Chemicals Dr. Pandit opines that the TVT-0 is defective because, among other things, when polypropylene degrades in vivo, “chemicals are produced that leach into the surrounding tissues.” (Pandit Report [Docket 207-1], at 6). He states that Ethi-con failed to perform appropriate tests for “these chemicals and their effects.” (Id.). Ethicon argues that these opinions are unreliable. Dr. Pandit cites no scientific support for these opinions, and he was unable to name which particular chemicals are produced: Q. Do you have an opinion, to a reasonable degree of scientific certainty, that when oxidation occurs breaking the chemical bonds, that chemicals are produced that leach into the surrounding tissues? A. Yeah. Q. What chemicals? A. I’m not so sure which ones they are. (Pandit Dep. [Docket 185-3], at 162:15-22). It is clear from this exchange that Dr. Pandit’s opinions on chemical leaching and Ethicon’s failure to test for such leaching are not reliable. Therefore, these opinions are EXCLUDED. 2. Failure to Test Dr. Pandit claims that Ethicon failed to adequately test the TVT-O. For instance, he states that pre-clinical testing was inadequate; Prolene mesh was not tested for shrinkage, degradation, or stiffening; the “inside-out approach” for surgical implantation was not tested appropriately; and the trocar design was not tested appropriately. (Pandit Report [Docket 207-1], at 1-2). Ethicon contends that Dr. Pandit is not qualified to offer these opinions because he failed to identify any specific experience, training, or education in designing or testing implantable devices. In his expert report, Dr. Pandit simply states, without elaboration, that he “has extensive experience .in the design and testing of implantable medical devices, including surgical mesh.” (Id. at 1). The plaintiffs failed to attach Dr. Pandit’s curriculum vitae to his expert report, so I am unable to verify this statement. When asked about this statement at his deposition, Dr. Pandit’s response was vague: •Q. What experience do you have in the design and testing of surgical mesh used for the treatment of stress urinary incontinence specifically? A. So my experience in testing of im-plantables is a very fundamental approach of looking at host responses in the body. So I’m an expert in host responses. I design material for host response to understand what the host response is. And the approach I take is, you know, is looking at the principles involved in how one does the studies for the intended applications. So in the context of surgical meshes, I would have had implanted surgical meshes in quite a few projects before, and looking at what the host response is. (See Pandit Dep. [Docket 185-2], at 24:14-25:5). He also stated that he has “used polypropylene several times” in the last 22 years in “multiple situations in the body.” (Id. at 25:16-17, 24-25). In light of Dr. Pandit’s vague explanations and plaintiffs’ counsels’ failure to attach Dr. Pandit’s curriculum vitae, I am unable to determine what precise qualifications he has to opine about designing or testing implantable medical devices. Therefore, the plaintiffs failed to carry their burden to demonstrate that Dr. Pan-dit should be permitted to testify on this issue, and Dr. Pandit’s opinions regarding testing are EXCLUDED. See Md. Cas. Co. v. Therm-O-Disc, Inc., 137 F.3d 780, 783 (4th Cir.1998) (“As in all questions of admissibility, the proffering party must come forward with evidence from which the court can determine that the proffered testimony is properly admissible.”). 3. Safer Alternative Designs Although he did not discuss safer alternative designs in his expert report, Dr. Pandit testified in his deposition that Ethicon should have used materials other than Prolene in the TVT-O. Ethicon contends that these opinions should be excluded because they were not contained in his expert report and because they are unreliable. Whether or not these opinions should be excluded for failing to appear in Dr. Pan-dit’s expert report, they are unreliable. Dr. Pandit refused to say which particular materials would be suitable as an alternative design: Q. Can you tell me today what modified synthetic materials that you have described that may have these additives or changes that may be appropriate for the use in the treatment of stress urinary incontinence? A. Yes. One other ideas could be, I don’t want to give Ethicon ideas on what they should be doing. Q. Sorry, you’re going to have to. A. I mean I’m giving our IP to them, telling them what they should be doing in terms of constructs. (Pandit Dep. [Docket 185-2], at 38:8-19). The plaintiffs state .that “Dr. Pandit identified PVDF and relied upon Ethicon documents which compare the mechanical properties and in vivo reactivity of polypropylene and PVDF.” (Pis.’ Resp. to Defs.’ Mot. to Exclude the Test, and Ops. of Dr. Abhay Pandit, Ph.D. [Docket 207], at 19). But the plaintiffs do not cite to any portion of Dr. Pandit’s expert report or deposition for this statement. Without an explanation from Dr. Pandit about which particular materials would be suitable alternative designs, these opinions are unreliable and are EXCLUDED. 4. Laser Cutting Mesh In his deposition, Dr. Pandit stated that the TVT-0 was defective because it uses laser-cut mesh. (See Pandit Dep. [Docket 185-2], at 69:16-22; 99:3-101:17). He also claimed that Ethicon failed to test the effects of laser cutting. (See id. at 99:10-12). He opines that “laser treatment does damage [to] polymer structures” and that antioxidants are lost as a result of laser cutting. (Id. at 99:20-21; 100:4-10). However, Dr. Pandit admitted that he could “absolutely not” testify to a reasonable degree of medical certainty that laser-cut mesh is safer than mechanically cut mesh. (Id. at 100:21). Therefore, this opinion is unreliable and is EXCLUDED. 5. Cancer The plaintiffs state that Dr. Pandit will not opine about the TVT-O’s potential to cause cancer. (See Pis.’ Resp. [Docket 207], at 17). Ethicon’s motion on this issue is accordingly DENIED as moot. F. Dr. John F. Steege Dr. Steege is an obstetrician and gynecologist. He teaches and studies the etiology or “causes” of chronic pelvic pain, vaginal pain, and sexual pain. (See Steege Report [Docket 210-3], at 1). In his expert report, Dr. Steege discusses the etiology of problems associated with using mesh in gynecologic surgery. (See id. at 2-11). In addition, Dr. Steege opines that the TVT-O IFU failed to reflect potential mesh-related complications. (See id. at 11-12). Finally, Dr. Steege provides an assessment of Ms. Huskey’s current medical condition. (See id. at 12-18). Ethicon moves to exclude Dr. Steege’s opinions entirely. Ethicon argues that Dr. Steege’s general opinions regarding mesh complications exceed the scope of his qualifications and do not fit this case because he cannot connect his general criticisms of the TVT-0 to Ms. Huskey’s alleged injuries. In addition, Ethicon argues that Dr. Steege’s specific causation opinions are unreliable because: (1) Ms. Huskey did not disclose her prior history of chronic pelvic pain to Dr. Steege, and (2) Dr. Steege did not conduct a proper differential diagnosis to rule out alternative causes of Ms. Hus-key’s chronic pelvic pain. Finally, Ethicon claims that Dr. Steege’s opinions regarding the TVT-0 IFU are unreliable because he did not review the IFU before completing his written expert report. 1. General Causation Opinions In his report, Dr. Steege provides several opinions regarding alleged problems associated with surgically implanted mesh, including “[c]hronie inflammation of native tissue surrounding the mesh”; “[s]hrinkage and deformation of mesh”; i‘[d]irect trauma to nerves, incurred during the mesh implantation or explanation process”; “[n]erve irritation, distortion, and. entrapment in the mesh and the surrounding fibrosis”; “[m]esh-related neuropathy”; and “[alteration of the function of surrounding organs due to any or all of’ the above-described mechanisms. (Steege Report [Docket 210-3], at 2). Ethicon contends that Dr. Steege is unqualified to offer these general causation opinions because he has never performed a TVT, TVT-O, or mesh-related procedure to treat SUI (see Steege Dep. [Docket 210-2], at 113:14-114:2); he has not taught any courses or conducted any studies regarding the TVT-0 implantation procedure (see id. at 136:17-137:16); and he has not handled explanted mesh, examined the biomechanical properties of mesh, or performed degradation testing of mesh (see id. at 156:16-19, 242:17-21). After reviewing Dr. Steege’s report and curriculum vitae, I FIND that Dr. Steege is qualified to opine on the etiology of problems associated with the implantation of mesh products in gynecologic surgery. An expert may be qualified by “knowledge, skill, experience, training, or edueation[.]” Fed.R.Evid. 702. “One knowledgeable about a particular subject need not be precisely informed about all details of the issues raised in order to offer an [expert] opinion.” Thomas J. Kline, Inc. v. Loril lard, Inc., 878 F.2d 791, 799 (4th Cir.1989). Dr. Steege is a renowned teacher and' physician who specializes in the etiology of chronic pelvic pain, vaginal pain, and sexual pain. He is the Director of the Division of Laparoscopy and Pelvic Pain at the University of North Carolina at Chapel Hill and a professor of obstetrics and gynecology. (See Steege Report [Docket 210-3], at 1). He has published a textbook and several book chapters and scientific papers on chronic pelvic pain. (See Steege CV [Docket 210-1], at 3-13). In 2009, as part of the American College of Obstetrics and Gynecology’s “Clinical Expert Series,” Dr. Steege discussed the relationship between mesh and the occurrence of new dyspareunia. (Evaluation and Treatment of Dyspareunia, 113 Obstetrics & Gynecology: Clinical Expert Series 1124, 1133 (2009) [Docket 210-3]). He concluded that: [m]ultiple studies of mesh placement in pelvic support surgeries demonstrate that new dyspareunia after surgery is substantially more common with these techniques compared with those that do not use mesh material. It would seem, therefore, that complications after mesh placement deserve much more detailed study and that the use of mesh should be a last resort, rather than the first procedure done. (Id.). In addition, Dr. Steege has treated 15-20 patients who complained of pain after being implanted with a mesh product. (See Steege Dep. [Docket 210-2], at 153— 56). Ethicon also argues that Dr. Steege’s general causation opinions do not fit the facts of this case and are therefore unhelpful. Ethicon contends that because Dr. Steege has not examined Ms. Huskey’s explanted mesh, he cannot connect his general causation opinions to Ms. Huskey’s injuries. I have already rejected this argument and thus FIND that Dr. Steege’s general causation opinions are helpful. 2. Specific Causation Opinions Dr. Steege provides a case-specific assessment of Ms. Huskey. After reviewing Ms. Huskey’s medical history and conducting a physical, abdominal, and gynecological examination, Dr. Steege concludes that “more likely than not her current dyspa-reunia and daily pain is in response to the initial mesh placement and multiple mesh excisional procedures required in an attempt to treat and manage her symptoms.” (Steege Report [Docket 210-3], at 17). He also testified to a “reasonable degree of medical certainty” that “Mrs. Huskey’s pelvic and vaginal pain are caused by the Ethicon TVT-0 polypropylene sling[.]” (Steege Dep. [Docket 210-2], at 318:13-18). Ethicon contends that these specific causation opinions are unreliable because Ms. Huskey did not disclose to Dr. Steege her prior history of chronic pelvic pain, and because Dr. Steege did not conduct a proper differential diagnosis. For the reasons that follow, I reject Ethicon’s arguments, a. Ms. Huskey’s Prior Medical History Ethicon claims that Dr. Steege did not have sufficient facts to formulate a reliable opinion because Ms. Huskey did not inform Dr. Steege that she had chronic pelvic pain prior to her TVT-0 implantation. “It is generally held that relevant testimony from a qualified expert may be received if and only if he is in possession of such facts as would enable him to express a reasonably accurate conclusion as distinguished from mere conjecture.” Horton v. W.T. Grant Co., 537 F.2d 1215, 1218 (4th Cir.1976). According to Ethicon, this prior history of chronic pain suggests that the TVT-0 is not the primary cause of Ms. Huskey’s current pain symptoms. Ethicon references Ms. Huskey’s December 2010 emergency room visit as evidence of her prior history of chronic pelvic pain. On December 13, 2010, Ms. Huskey visited the Decatur Memorial Hospital Emergency Room due to abdominal pain. (See Emergency Triage Notes [Docket 230-1]). According to the emergency room triage notes, Ms. Huskey complained of an “acute worsening of chronic left lower quadrant pain[.]” (Id. at 2). A subsequent colonoscopy suggested that diverticulitis was a possible source of Ms. Hüskey’s December 2010 pain. (See Steege Report [Docket 210-3], at 12). Ethicon claims that Ms. Huskey did not inform Dr. Steege that she had chronic pelvic pain prior to her TVT-O implantation. Contrary to Ethicon’s assertions, Dr. Steege does reference the December 2010 incident in his expert report. (See id.). In addition, Dr. Steege- testified that he was aware of this incident but did not consider it to be related to Ms. Huskey’s current symptoms: Q: Did Ms. Huskey have pelvic pain at any point before her TVT-O? A. According to her history with us, she did — she did not really. She had that episode of left quadrant pain that was really rather separate from subsequent events. Q. Did Mrs. Huskey report to you that she had chronic abdominal pain at any point prior to her TO implantation? A. We discussed the episode of the left lower quadrant pain that she had. She did not describe it as chronic. Q. Did. Mrs. Huskey report to you that she had any type of history of pelvic pain before her TVT-O? A. I think we covered that. Q. Oh, I did? A. Yeah. Q. She didn’t report that to you? A. No. (Steege Dep. [Docket 210-2], at 253:2-17, 258:1-8 (emphasis added)). Because Dr. Steege was aware of Ms. Huskey’s prior pelvic pain, I FIND that he had the facts necessary to render a sufficiently reliable opinion regarding the cause of Ms. Hus-key’s current symptoms. b. Differential Diagnosis Ethicon also maintains that Dr. Steege failed to perform a proper differential diagnosis to rule out other possible causes of Ms. Huskey’s chronic pelvic pain. In particular, Ethicon contends that Dr. Steege did not conduct a sufficient examination to rule out endometriosis as an alternative cause of Ms. Huskey’s condition. Ethicon also claims that Dr. Steege did not explain the methodology he used to form his specific causation opinion. In his report, Dr. Steege acknowledges several alternative causes of Ms. Huskey’s pain. (See Steege Report [Docket 210-3], at 16-17). He also reviewed Ms. Huskey’s medical history and conducted a musculo-skeletal, abdominal, and gynecological examination. (Id. at 16). He described the examination procedures and their results. (Id.). He then concluded as follows: There is likely a neuropathic component to [Ms. Huskey’s] pain, although we could not document a single nerve injury. The clinical diagnosis of a direct nerve injury is made when there are signs of motor weakness and/or sensory loss, however the diagnosis of nerve entrapment from progressive scarring in the pelvis is more challenging. This is because it is the nature for cutaneous sensory dermatomes to overlap and, as many of the nerves in the pelvis do not have motor innervation, it is difficult to differentiate between them. Also, some nerves with both sensory and motor function can be damaged even if there is no loss in motor function. Despite some mild hyperalgesia, she also had a normal neurosensory exam. Regardless, more likely than not her current dyspareunia and daily pain is in response to the initial mesh placement and multiple mesh excisional procedures required in an attempt to treat and manage her symptoms. These conclusions are based on my knowledge of pelvic neuroanato-my, the inflammatory response of tissue to foreign bodies, and my professional opinion. These opinions are supported by well-established scientific principles accepted by the medical community and published in the scientific literature. In reaching these conclusions, I was able to rule out other causes of her pelvic pain and sexual pain, including, but not limited to, her back condition, her history of back surgery, her sacro-iliac dysfunction, her history of pelvic surgery, and diverticulitis. (I'd. at 17). Although Dr. Steege did not provide a detailed explanation as to why he ruled out these alternative causes, he bases his conclusions on accepted scientific principles and research. In addition, he reviewed Ms. Huskey’s medical history and conducted three diagnostic examinations to determine the cause of Ms. Huskey’s pain. Although he did not clearly connect these scientific studies and examinations to his opinion, it cannot be said that he provided “no explanation” as to why he ruled out alternative causes. See, e.g., Heller v. Shaw Indus., 167 F.8d 146, 156 (3d Cir.1999) (“Dr. Papano did not offer detailed explanations for why he concluded that these were not the causes of plaintiffs illness, but his responses [during cross-examination], grounded in the alleged temporal relationship, the results of Todd’s testing showing a reduction in VOCs when the carpet was removed, and Heller’s medical history and physical examination, certainly are more than ‘no explanation.’ ”). Accordingly, I FIND that Dr. Steege used a sufficiently reliable methodology to as-, certain the cause of Ms. Huskey’s chronic pelvic pain. Ethicon also argues that Dr. Steege failed to conduct a sufficient examination to exclude endometriosis as a source of Ms. Huskey’s chronic pelvic pain. In his deposition, Dr. Steege testified that “I would [ ] comment that neither patient we’re dealing with [including Ms. Huskey] had endometriosis for the record.” (Steege Dep. [Docket 210-2], at 161:20-21). Dr. Steege testified that endometriosis is a common health problem for women. (See id. at 161:10-19). He also conceded that endometriosis can cause chronic pelvic and lower back pain. (See id. at 161-62:15-8). Dr. Steege testified that endometriosis can be diagnosed with a physical examination, but that the condition is often diagnosed by reviewing the patient’s history and conducting a diagnostic laparoscopy: Q. And how is endometriosis usually diagnosed? A. Sometimes by physical examination, more often by history combined with usually a diagnostic laparoscopy. Q. Say again. A laparoscopic? A. Diagnostic laparoscopy. Q. This is an area I’m not versed in too well, so can you tell me what is a diagnostic laparoscopy. A. That’S' — -I’m also puzzled as to why it’s germane to this because it kind of isn’t. Q. How do you determine whether or not a patient has endometriosis? A. By taking a history and physical exam in detail and those where it’s clinically relevant a high index of suspicion and do a laparoscopy. Typically the person who comes to see me, though, has already had the diagnosis made because they’ve had four lapar-oscopies, some of which they didn’t need. So I don’t need another one. Q. So would you say then a majority of your patients who have — who come to you, they’ve already had a laparosco-py? A. Majority being over half, I would say that’s probably true. Q. Has Mrs. Huskey ever had a prior laparotomy? A. I don’t believe she had, but then to save you some breath, I’ve seen very few 54-year-olds with endometriosis, okay? We can cut to the quick a little bit. (Id. at 9-10:16-1,170-71:13-4). Dr. Steege further testified that “I would say that the decision to do a laparos-copy is based on the totality of the history and physical exam to see if there’s enough evidence to support the possibility. You certainly do not laparoscope every patient with pelvic pain.” (Id. at 164:1-6). In addition, during his deposition, Dr. Steege referred to a study indicating that physicians relying on a patient’s history and physical examination correctly diagnosed endometriosis eighty percent of the time. (See id. at 164-65:9-21). In Ms. Huskey’s case, although he conducted a physical examination of Ms. Huskey, Dr. Steege did not conduct a diagnostic laparoscopy to determine whether she had endometriosis. (See id. at 10:16-18; see also Steege Report [Docket 210-3], at 16). However, he noted that it was unlikely that a fifty-four year old with a hysterectomy could have endometriosis. (See Steege Dep. [Docket 210-2], at 187:18-23, 322:14-19). “[A] 'physician need not conduct every possible test to rule out all possible causes of a patient’s illness, ‘so long as he or she employed sufficient diagnostic techniques to have good grounds for his or her conclusion.’ ” Heller v. Shaw Indus., Inc., 167 F.3d 146, 156 (3d Cir.1999) (quoting In re Paoli R.R. Yard PCB Litig., 35 F.3d 717, 761 (3d Cir.1994)). Here, although Dr. Steege did not conduct a laparoscopy, he did conduct a physical examination and reviewed Ms. Huskey’s history, which Dr. Steege demonstrated is a reliable means of diagnosing endometriosis. Accordingly, I FIND that Dr. Steege used a reliable methodology to exclude endometriosis as a possible source of Ms. Huskey’s chronic pelvic pain. 3. IFU Opinions Dr. Steege opines that the TVT-0 IFU did not accurately reflect the potential complications of implanting the TVT-O, such as chronic pelvic pain, vaginal pain, dyspareunia, persistent leg and groin pain, partner pain, vaginal scarring, shrinkage, degradation, chronic foreign body response, and removal difficulty. (See Steege Report [Docket 210-3], at 11-12). Ethicon claims that these opinions are unreliable because he did not review the IFU before completing his expert report. During his deposition, Dr. Steege testified that he did not review the TVT-0 IFU until after he had completed his expert report: Q. When did you review that TVT-IFU, before or after you issued your report? A. After. Q. And so the IFU for TVT-0 did not have a role in the formulation of your opinions that you issued in your report in this case, correct? ' A. They have a role in my general testimony about the case but not in the report. I didn’t have them for the report. Q. The opinions that you formed in this case you formed those before reviewing the TVT-0 IFU, correct? A. The report opinions, yes, correct. Q. And those opinions were not only formed but reduced to writing even before you reviewed the TVT-0 IFU