Proximate cause is when an event is involved enough as the cause of an injury that it can be recognized in court as such. To say that a certain action was proximate cause is, in essence, to say that it was the primary cause of injury. Proximate cause is established by several tests — the but for test is the most common. According to the but for test, if an injury would not have taken place but for the action in question, then that action is indeed the proximate cause. For example, the test about a high speed collision could say: but for the speed at which the driver was driving, the pedestrian would not have been hit. In addition to the but for test, courts have also held that other aspects must be considered for an action to be proximate cause, particularly foreseeability and direct causation.