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A defendant can only be held liable in negligence if a plaintiff proves that the defendant actually (or perhaps I should say factually) caused the plaintiff's injuries. "But-for" is the basic rule that governs this issue. We've touched on that rule before, but to see it in practice, check out the case of Kauffman v. TTC at pages 159-60 and some of the notes following in the LKF casebook. If you continue on to the next case, Athey v. Leonati at pages 161-66, you'll see that sometimes the but-for principle isn't so easily applied. That case alludes to some of the circumstances where the but-for test's deceptive simplicity makes it unworkable. For example, what if there are multiple successive injuries? What about multiple factors contributing to the same injury? What if there are multiple defendants, one of whom certainly caused an injury but it can't be proven precisely which? There are the kinds of topics we'll tackle through the materials at pages 252-274 of LKF and paras 1-5 and 13-29 of the recent SCC decision in Resurfice. On the course map I also asked you to read pages 274-80, which deal with "market share liability." You'd certainly benefit from reading those pages, but we'll only cover them in class if there's time.