McLaughlin

I. BACKGROUND

1 The Parties do not dispute the following facts. Plaintiffs Aaron McLaughlin and Tara 2 Clark, husband and wife, reside in Virginia. In 2018, they purchased a car from Tesla in Virginia. 3 Tesla is incorporated in Delaware and headquartered in Texas but designed and manufactured the 4 car in question in California. In October 2020, while Plaintiff McLaughlin was driving on the 5 highway in Virginia, he was involved in a car accident. The Parties dispute the cause of the 6 accident; Plaintiffs blame Tesla’s allegedly defective design and manufacture of the car, and Tesla 7 blames Plaintiff McLaughlin’s allegedly negligent operation of the car. 8 Two years after the accident, Plaintiffs commenced this action to recover for Plaintiff 9 McLaughlin’s injuries under theories of strict liability and negligence and to recover for Plaintiff 10 Clark’s alleged loss of consortium. See Dkt. 1-2 ¶¶ 34-84. The Parties dispute whether Virginia 11 law or California law governs these claims.

II. LEGAL STANDARD

13 Where a federal court exercises subject-matter jurisdiction on the basis of diversity 14 jurisdiction, it must apply the choice-of-law rules of the forum…