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" ... Where there is little evidence of negligence (e.g., where a factory created social separation and sanitized equipment after the pandemic was announced), summary judgement should be granted to defendants. Even if there is negligence in a given case, causation may be difficult to prove: maybe the gas pump should have been santized more often, but how can Mr. Smith prove that he probably contracted coronavirus at that pump? Conversely, causation may be easy to prove (for example, prisoners with coronavirus clearly contracted the disease inside prisons), but there may be no negligence (if, for example, it was simply not feasible to operate the prison in any other way). ... "