the plaintiff suffered actual quantifiable injury (damages). As demonstrated in cases such as Winterbottom v. Wright, the scope of the duty of care was limited to those with whom one was in privity. Later cases like MacPherson v. Buick Motor Co. broadened the duty of care to all who could be foreseeably injured by one's conduct. Over time, negligence concepts have arisen to deal with certain specific situations, including negligence per se (using a manufacturer's violation of a law or regulation, in place of proof of a duty and a breach) and res ipsa loquitur (an inference of negligence under certain conditions). Strict liability Rather than focus on the behavior of the manufacturer (as in negligence), strict liability claims focus on the product itself. Under strict liability, the manufacturer is liable if the product is defective, even if the manufacturer was not negligent in making that product defective. Under a strict liability theory, the plaintiff merely needs to prove: the defendant manufactured, distributed, or supplied a product; the product was defective; the defect caused injury to the plaintiff; and as a result, the plaintiff sustained damages. Consumer protection In addition to common law remedies, many states have enacted consumer protection statutes that provide specific remedies for certain specific types of product defects. One reason for the appearance of such statutes is that under the "economic loss rule", strict liability in tort is unavailable for products that cause damage only to themselves. In other words, strict liability is unavailable for defects that merely render the product unusable (or less useful), and hence cause only economic injury, but do not cause personal injury or damage to other property. Breach of warranty actions governed by Article 2 of the Uniform Commercial Code also often fail to provide adequate remedies in such situations. The best-known examples of consumer protection statutes for product defects are lemon laws, which provide protection to purchasers of defective new vehicles and, in a small number of states, used vehicles. In the United States, "cars are typically the second most valuable asset most people own, outranked only by their home." Europe Although European observers followed Greenman and Section 402A "with great interest", European countries did not initially adopt such a doctrine. For example, after the landmark case of Donoghue v Stevenson [1932] (which followed MacPherson), UK product liability law did not change any further for many decades, despite "trenchant academic