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http://gizmodo.com/5312623/teenager-falls-into-open-manhole-while-texting
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Even if you're arguing that a texting person will not notice walking through caution tape and knocking aside cones, those things are also brightly colored and easily noticed specifically to counteract the fact that a manhole is not easily noticed.
If those things were there, and this girl didn't notice them, knocked them aside, and then fell in a manhole, then the workers would not be at fault, and she and her family could, at most, complain that cones and tape are not adequate warnings of an open manhole.
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