The record
A California Court of Appeal affirmed summary judgment for J&J's consumer arm where the plaintiffs relied on internal documents without an opposing expert declaration, and criticised the plaintiffs' characterisations of two internal documents as unsupported by the documents themselves.
Claim scope
MANDATORY COUNTERWEIGHT with a VERIFIED reporter citation (44 Cal.App.5th 475, cross-cited in both Strobel and McNeal). A published appellate court examined specific internal talc exhibits and found the plaintiffs' summaries of them overstated: the October 1, 1976 memorandum's entire comment on the Langer paper was “This paper will appear in the November ‘76 issue of the Journal of Toxicology and Environmental Health. Appropriate responses are being organized.” The court characterised the plaintiffs' framing as showing “lack of specificity and descriptive hyperbole.”
What this source does not establish
It does not hold that talc was asbestos-free, and it turned substantially on a procedural failure (no opposing expert declaration at summary judgment). It concerned Vermont-sourced Hammondsville and Argonaut talc in a 1980-2000 use period.
Limitations
This record exists to discipline the page's own drafting. The specific document AsbestosAtlas would be most tempted to characterise as 'J&J prepared refutations of Langer' is the exact characterisation a published court rejected. Also note the court quotes a 1973 outside-consultant TEM report on Vermont talc No. 32-71S finding NO chrysotile or tremolite, only antigorite — a dated NEGATIVE result that belongs in an honest timeline.
Source
Case Citation — LAOSD Asbestos Cases, 44 Cal.App.5th 475 (Cal. Ct. App. 2d Dist. Div. 4, 2020)