Medical technology is advancing at a rapid pace, including advances with medical devices. For example, doctors are now performing surgeries with state-of-the-art robotic surgical systems. As medical devices become more sophisticated, there is an increase in demand for training to accompany these products. In response, many manufacturers now offer training and other educational programs on their most complex medical devices.

With this training and education come new theories of liability. Some products liability claims have shifted from focusing on the quality of the product to examining the quality of the training.  A recent aviation case from the Pennsylvania Superior Court sheds light on the viability of such training claims in Pennsylvania.