A Checklist of practical issues that defense counsel should consider when responding to a product liability complaint for personal injury in Florida circuit 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.