D is a citizen of Alabama.
P has surgery for the implantation of a sophisticated electronic heart chamber.
The heart chamber malfunctions, injuring P severely. P files a products liability civil action in a federal district court against D, the manufacturer of the heart chamber. D files a third-party complaint for indemnity against TPD, the surgeon who implanted the chamber, alleging that the surgeon's malpractice was the primary cause of the chamber's malfunction. TPD then files a claim directly against P, seeking payment for TPD's surgical services in implanting the chamber. Finally, P files a claim directly against TPD for medical malpractice.