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A homeowner sues a space-heater manufacturer after a heater ignited curtains in her bedroom. She claims the heater's tip-over switch failed when the heater fell on thick carpet. The manufacturer denies defect and argues that the homeowner placed curtains too close to the heater.
The homeowner offers 18 consumer complaints. Six involve the same heater model tipping over on thick carpet and continuing to run. Five involve different models by the same manufacturer overheating while upright on tile floors. Seven involve the same model but only after owners modified the power cord. The homeowner offers the complaints to prove defect, causation, and notice. The manufacturer objects under Rules 401 and 403, arguing that the complaints are dissimilar and would require a trial about 18 separate incidents.
Analyze which complaints, if any, should be admitted and whether the court should use limits, redactions, or a representative subset.