In a multi-district litigation (MDL) case decided in 2012, In re Chantix (Varenicline) Products Liability Litigation, the court stated that "Rule 702, Federal Rules of Evidence, as construed by the Supreme Court in Daubert v. Merrell Dow Pharmaceuticals, Inc., requires expert scientific evidence to be both reliable and relevant pursuant to Rule 702, such that it appropriately assists the trier of fact." (139) Of course, the 2012 version of Rule 702 could not have been construed in Daubert, given that Daubert was decided more than seven years before that Rule came into existence.
Supreme Court in Daubert v. Merrell Dow Pharmaceuticals. (2) In Daubert, the Court said that Federal Rule of Evidence 702 requires trial judges to determine whether expert testimony is both reliable--supported by scientifically valid reasoning or methodology--and relevant--applicable to the specific issue the court must resolve.
Since Daubert v. Merrell Dow Pharmaceuticals was decided in 1993, there have been two primary Issues in applying Daubert to expert testimony in valuation situations: qualification of an expert witness and the use of methodology.