GERMANY improved the legal situation of pharmaceutical products liability plaintiffs by enacting two laws: 1) the second Pharmaceutical Act of August 24, 1976 ("Pharmaceutical Act")1 and 2) the Product Liability Act of December 15, 1989 ("Product Liability Act").2 Prior to the enactment of these laws, individuals who had suffered injuries from pharmaceutical products were protected by tort law only,3 but under tort law, a valid claim existed only if a defective product caused an injury, and there was negligent pharmaceutical company behavior.4 Often it was impossible for a plaintiff to meet the standard of proof; however, in the past, compensation for plaintiffs in mass pharmaceutical …