A Checklist of practical issues that defense counsel should consider when responding to a product liability complaint for personal injury in New York state supreme court. Specifically, this Checklist identifies the defendant's initial response options, outlines important issues to discuss with the client when formulating a defense strategy, and highlights the key procedural and substantive responses that a defendant typically may raise in a product liability action. This Checklist does not address defenses that apply to specific products, such as prescription drugs, or to claims for punitive damages.