What factors will plaintiffs have to prove at trial to recover medical monitoring damages?

In reviewing the factors that plaintiffs will have to prove at trial to recover medical monitoring damages, there is substantial evidence to support the trial court's conclusion that common issues predominate. Part II of the lead opinion recognizes that it is undisputed that several key issues at trial will be proven by evidence that is common to all class members. (Lead opn., ante, 131 Cal.Rptr.2d at pp. 8-10, 63 P.3d at pp. 919-920.) As the lead opinion states, because plaintiffs' claims sound generally in negligence, plaintiffs will have to prove duty, breach of duty, proximate cause, and damages. (Artiglio v. Corning Inc. (1998) 18 Cal.4th 604, 614, 76 Cal.Rptr.2d 479, 957 P.2d 1313.) The lead opinion acknowledges that the issue of whether defendants owed a duty of care to the proposed class members is susceptible to common proof. (Lead opn., ante, at pp. 8-9, 63 P.3d at pp. 919-920.) In addition, the lead opinion states that the issue of defendants' breach of this duty of care is also one that will be proven by evidence common to all class members. (Lead opn., ante, at pp. 8-9, 63 P.3d at p. 919.)