San Francisco Superior Court granted summary judgment for Burning Man event promoter Black Rock City, LLC, in a case filed by Anthony Beninati, who attended the Burning Man festival in 2005. (Beninati v. Black Rock City, San Francisco Superior Court case no. CGC-06-455768.) Mr. Beninati walked into the Burning Man bonfire, tripped and fell, and incurred severe burn injuries. Under California primary assumption of the risk doctrine, the court found that Black Rock City owed no duty of care to the plaintiff, finding that if he had simply chosen to stay away from the fire, he never would have burned himself. William S. Kronenberg and Steven A. Kronenberg defended Black Rock City, LLC.