In Bockrath v. Aldrich Chemical Co. (1999) 21 Cal. 4th 71, the plaintiff contracted multiple myeloma while working at Hughes Aircraft Company from January 1973 to March 1994. His suit named approximately 55 defendants, including the manufacturers of such common items as WD-40 and rubber cement. The court was primarily concerned with "overbroad litigation." ( Id. at p. 81.) According to the court: "The law cannot tolerate lawsuits by prospecting plaintiffs who sue multiple defendants on speculation that their products may have caused harm over time through exposure to toxins in them, and who thereafter try to learn through discovery whether their speculation was well-founded." (Ibid.) "It is sharp practice to implead defendants in a products liability suit alleging long-term exposure to multiple toxins unless, after a reasonable inquiry, the plaintiff actually believes that evidence has been or is likely to be found raising a reasonable medical probability that each defendant's product was a substantial factor in causing the harm . . . ." ( Id. at p. 82.) "A cancer-afflicted plaintiff suing every manufacturer of an airborne substance found in the Los Angeles basin probably would be exposed to sanctions for the suit, even if certain defendants eventually were found to have made a product that was a substantial factor in the onset of the plaintiff's cancer." ( Id. at p. 83.) The plaintiff's complaint, which was "poorly drafted" and "internally inconsistent," appeared to be "attempting to allege" that "defendants' products cause cancer, he was exposed to them, and they migrated to his internal organs and caused his multiple myeloma." ( Bockrath v. Aldrich Chemical Co., supra, 21 Cal. 4th at p. 79.) The court concluded the allegations were "insufficient" because they did not allege "that each defendant's product was a substantial factor . . . in causing his multiple myeloma." (Id. at pp. 7980.) Due to the multitude of defendants named and products identified, the pleaded facts did not show plainly the connection between cause and effect or give rise to an inference of causation that was more than theoretical. The court remanded in order to give the plaintiff the opportunity to assert the following specific allegations: "(1) Plaintiff must allege that he was exposed to each of the toxic materials claimed to have caused a specific illness. An allegation that he was exposed to 'most and perhaps all' of the substances listed is inadequate. (2) He must identify each product that allegedly caused the injury. It is insufficient to allege that the toxins in defendants' products caused it. (3) He must allege that as a result of the exposure, the toxins entered his body. (4) He must allege that he suffers from a specific illness, and that each toxin that entered his body was a substantial factor in bringing about, prolonging, or aggravating that illness. (5) Finally, . . . he must allege that each toxin he absorbed was manufactured or supplied by a named defendant." (Id. at p. 80.)