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A decade ago, James, et.al. published a detailed study of the available NASS data on severe rear impacts, with findings that “… stiffened or rigid seat backs will not substantially mitigate severe and fatal injuries in rear impacts.” No field accident study has since been advanced which refutes this finding. Advocates of rigidized seat backs often point to specific cases of severe rear impacts in which MAIS 4+ injuries are associated with seat back deformation, coupled with arguments supporting stiffer seatback designs. These arguments are generally based upon laboratory experiments with dummies in normal seating positions. Recent field accident data shows that generally, in collisions where the majority of societal harm is created, yielding seats continue to provide benefits, including those associated with whiplash associated disorders (WAD).