In Dover v. R.J. Reynolds Tobacco Co., No. 09-cv-11531 (M.D. Fla. Sept. 22, 2014), the district court addressed a motion in limine filed by plaintiff seeking to bar defendants from introducing evidence to show that plaintiff had smoked a non-party’s cigarettes for an extended period of time. Defendants planned to introduce this evidence to rebut plaintiff’s causation evidence and to refute plaintiff’s claim that the specific design of defendant’s cigarettes stopped plaintiff from quitting smoking. The court held that defendants could adduce evidence of plaintiff’s use of another company’s cigarettes for these purposes.