Eileen Ford of MOODK’s Delaware office obtained dismissal on summary judgment for two boiler manufacturer clients in two separate (consolidated) asbestos cases. The Plaintiffs (two brothers) alleged asbestos exposure to exterior insulation on boilers when they owned and operated a conglomerate of laundry businesses in Florida from the late-1960s into the mid-1980s. Motions for summary judgment were filed on behalf of both clients on the basis that Plaintiff’s failed to provide sufficient evidence that the exterior insulation was a product manufactured by the clients as required pursuant to Florida’s Asbestos and Silica Act and/or the application of the bare-metal defense which the clients argued was the substantive law in Florida. Alternatively, it was argued that because Plaintiffs could not place a particular boiler at any of their conglomerate locations (i.e. name recognition only), that they could not meet the “substantial factor exposure” requirement under Florida law. Ultimately, the Court granted summary judgment on the grounds that it was Plaintiffs’ conglomerate that actually purchased the alleged asbestos-containing asbestos, and since they did not know the manufacturer of that insulation, could not quantify how often they present when insulation was removed or installed, summary judgment was granted. The Court determined it did not need to reach the issue of predicting how Florida Supreme Court would rule on the bare-metal defense argument.