ON SEPTEMBER 12, 2011, A KUMHO ROAD VENTURE AT TIRE, SIZE LT235/85R16, DOT K2ORYD4A3508 (MANUFACTURED AT KUMHO?S BINH DUONG PLANT IN VIETNAM IN THE 35TH WEEK OF 2008) SUFFERED A CATASTROPHIC TREAD SEPARATION, RESULTING IN SEVERE INJURIES TO THE FRONT SEAT PASSENGER OF THE FORD F-250 AND THE DEATH OF HER SON, WHO WAS 32 WEEKS OLD AND STILL IN UTERO. A LAWSUIT HAS BEEN FILED AGAINST KUMHO TIRE CO., INC. AND KUMHO TIRE U.S.A., INC. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS (CASE NO. 2:13-CV-02393-JTM-TJJ). DURING THE DISCOVERY STAGE OF THE CASE, THE PASSENGER RETAINED TROY COTTLES, A RENOWNED TIRE FAILURE EXPERT. AFTER INSPECTING THE SUBJECT TIRE, MR. COTTLES FOUND THE FOLLOWING DEFECTS IN THE SUBJECT TIRE: (1) INADEQUATE BONDING BETWEEN BELTS (TRAPPED AIR/STEAM BLISTER IMPRESSIONS); (2) PREMATURE OXIDATION OF THE BELT SKIMS; (3) BELTING DEFECTS (COINCIDENTAL BELT ENDINGS, IRREGULAR BELT WIRE SPACING, GAPPED BELT SPLICES, DOG-EARED SPLICES, SNAKING, AND SPREAD CABLES); (4) CORD SHADOWS ON THE INNERLINER; (5) LOW TOP BELT WIDTH TO TREAD WIDTH RATIO; AND (6) INADEQUATE APPLICATION OF NYLON CAP PLIES. AS PART OF HIS WORK ON THE CASE, MR. COTTLES TESTED TWO EXEMPLAR KUMHO ROAD VENTURE AT TIRES OF THE SAME SIZE AS THE SUBJECT TIRE THAT WERE ALSO MANUFACTURED AT KUMHO?S VIETNAM PLANT. BOTH OF THOSE TIRES FAILED IN SIDEWALL FAILURE MODE IN APPROXIMATELY 10,000 MILES OR LESS UNDER PROPER LOADS, INFLATIONS, AND SPEEDS THAT WERE MONITORED DAILY. SEE ATT