See plaintiff's Memorandum in Support of Motion to Require Nissan to Make Good Cause Showing, n.5 at 5. Because airbags are now required in all new cars, the public has a strong interest in knowing about the features and safety benefits that differ among airbag system designs. Other plaintiffs and the public should have access to information regarding the variances in airbag design and deployment characteristics. Plaintiffs need this information in order to determine the speed, force, trajectory, and excursion distance of the airbag during its deployment. Plaintiffs will then be able to determine whether the mode of the bag's deployment is safe or whether it exposes the occupant to unnecessary risks not found in better designed airbag systems.
Consumers have a similar interest in obtaining airbag system crash test videos and reports.
Consumers need to know which airbag systems are safe, and which, due to their flawed designs, have dangerous propensities. Such disclosure is particularly necessary in view of advertising that fails to reveal the variances in airbag system designs and erroneously suggests that all airbag systems have features that are present only in the better-designed airbag systems. See OSI Ex. These allegations warrant public disclosure of Nissan's crash test videos and reports so that the airbag system can be carefully scrutinized for safety. The defendant has no need to keep the specified crash test videos and reports secret because they reveal no trade secrets.