Because plaintiffs can present plausible claims based on the standard elements of negligence, drug manufacturers must argue for the creation of a special rule that would trump the normal application of those elements. Their basic argument is that a drug manufacturer should be liable only for harm suffered by those who actually used its products.238 They contend that a manufacturer should not be responsible for injuries that did not directly result from the use of its products, even if those injuries were actual and foreseeable results of the manufacturer’s negligence. In short, they believe manufacturers can only be liable qua manufacturers.The drug makers contend that this limitation on their liability is a long and well-established principle. “It is hornbook law,” argued the brand-name manufacturer in the Conte case, “that a product manufacturer owes no duty to a plaintiff who does not use its product.”239 Likewise, observers denouncing the Conte decision claimed that it has been clear “since the dawn of product liability” that “[y]ou can only sue the manufacturer of the product that injured you.”240