In Massachusetts, manufacturers, distributors, suppliers and retailers face the grave reality that a product liability lawsuit brought against them will almost always include a cause of action under G.L. c. 93A, §§ 2 & 9. The application of this law to personal injury lawsuits involving products stems from the Supreme Judicial Court's decision inMaillet v. ATF-Davidson Co., 407 Mass. 185, 193 (1990), which held that "[g]enerally, a breach of warranty constitutes a violation of G.L. c. 93A, § 2." Id. The addition of a G.L. c. 93A claim to a product liability case increases the stakes both for plaintiffs and for defendants (and their insurers). Under G.L. c. 93A, § 9, defendants are faced with the task of evaluating a case prior to litigation, and before discovery has been completed, based upon minimal information, in order to make a "reasonable" settlement offer within 30 days of receiving a demand letter. The consequences for failing to do so appropriately are no less than the potential doubling or trebling of damages. Worse yet, the Supreme Judicial Court held recently in Rhodes v. AIG Domestic Claims, Inc., 461 Mass. 486 (2012), that a plaintiff may recover the original tort or contract judgment and up to three times that judgment amount under chapter 93A on the unfair and deceptive practices claim (either a breach of warranty claim or a bad faith settlement claim), for a total recovery to plaintiff of up to four times the original tort/contract judgment, plus attorneys' fees. G.L. c. 93A, § 9(3); Rhodes, 461 Mass. At 505. Mishandling the matter during the pre-suit demand letter stage can have severe ramifications on the potential damages and may dictate whether the case will be ultimately settled or tried and, if it is to be settled, for how much.