In Watts v. Medicis Pharm. Corp., No. CV-15-0065 (Ariz. Jan. 21, 2016), the Arizona Supreme Court held that the learned intermediary doctrine limits the duty of drug manufacturers to provide adequate information concerning the risks of their prescription drugs to physicians and not in general to the persons who will use the drugs based on prescriptions from their physicians.  The court rejected the argument that the learned intermediary doctrine is inconsistent with the Uniform Contribution Among Tortfeasors Act (“UCATA”), which Arizona has adopted.  The court held that there is no conflict because the learned intermediary doctrine addresses only the issue of duty whereas the UCATA addresses the issue of allocating liability among defendants.  Further, the Arizona Supreme Court rejected the argument that it should adopt a direct-to-consumer advertising exception to the learned intermediary doctrine in situations where the drug manufacturer conducts mass marketing of a prescription drug.  Finally, the court concluded that the Consumer Fraud Act is applicable to prescription drugs because prescription drugs fit within the definition of “merchandise” under that Act.