In Casey v. Overhead Door Corp. (1999) 74 Cal. App. 4th 112, 118, 87 Cal. Rptr. 2d 603, the court held that while courts have extended the concept of strict products liability to allow purchasers to sue developers of mass-produced homes (citing Kriegler v. Eichler Homes, Inc. (1969) 269 Cal. App. 2d 224, 74 Cal. Rptr. 749), "they have refused to extend the principle beyond the developer to the subcontractors or suppliers. (La Jolla Village Homeowners' Assn. v. Superior Court (1989) 212 Cal. App. 3d 1131, 1144-1146, 261 Cal. Rptr. 146.) 'A subcontractor who does not have any ownership or control over the project or over its portion of the project being built should not be held strictly liable for defective or dangerous conditions of the mass-produced homes.' (Id. at p. 1145.) This applies to 'all subcontractors in the typical real estate construction project regardless of whether they provided "services" or a "product."' (Id. at p. 1146.)" (Casey, at p. 119.) The plaintiffs in Casey unsuccessfully argued that La Jolla Village Homeowners' Assn. v. Superior Court, supra, 212 Cal. App. 3d 1131, did not apply and Overhead was not shielded from strict liability because it manufactured a defective product: windows, window frames, and window components. The Casey court said: "La Jolla is not limited as plaintiffs suggest. The distinction is not between material or 'service' suppliers (i.e. subcontractors), on the one hand and materials manufacturers on the other. Instead, the distinction is between the developer, which 'manufactures' the homes, and the rest of the participants, regardless of whether they provide a service, supply a component or manufacture a component part. The principle of risk distribution, fundamental to the doctrine of strict liability, is effected by holding the developer strictly liable for all defects in mass-produced homes." (Casey v. Overhead Door Corp., supra, 74 Cal. App. 4th at pp. 119-120.) In short, the trial court was found to have erred in refusing to allow plaintiffs to pursue a cross-complaint for indemnity which had been assigned to them by another defendant who had settled. The trial court's ruling, however, was apparently based on its determination "that plaintiffs had not amended their complaint to include the assigned indemnity cause of action, which was therefore not before the court. The court failed to consider the independent nature of a cross-complaint, and that trial can proceed under more than one operative pleading. " (Id. at p. 121, fn. 5.)