The worker does not dispute that his exposure does not meet the technical definitions of acoustic trauma or acoustic
shock. He submits that testing the claim only against those two mechanisms was itself the error: both’are inner-ear
mechanisms triggered by single, high-intensity events, and neither is what-any treating specialist has identified as the
injury pathway in this case. Sections 3-6, below, set out what the specialist record actually shows.

3. Mischaracterization of the Pre-Existing Migraine Condition

‘The Opinion treats the worker's migraine history as an undifferentiated pre-existing condition, without reference to its
management status immediately before the exposure or to how it changed afterward. The worker's specialist record fills
that gap.

A uranaged baseline

Before the January 2026 exposure, the worker had implemented a structured migraine reduction program: triple
progressive glasses (obtained after a vision assessment revealed both farsightedness and nearsightedness), Coenzyme
QJ0, and cessation of both smoking and aleoho!. This program produced a documented 33% reduction in sumatriptan
use —~ an objective, medication-based measure of improving control.

Occupational disruption of that baseline

The worker's January 2026 training placement seated him directly in front of two industrial-sized servers. Within the
first week of exposure, sleep became disrupted and the migraine reduction program began losing effectiveness. Small
and nocturnal headaches increased. Approximately twe weeks in, sharp stabbing pain developed in both ears, worse on
the left.

The clinical turning point

This exposure pushed the worker's migraines to “a severity never previously experienced,” resulting in his first-ever
emergency room visit for a migraine, on January 30, 2026 — after seventeen months of a stable, well-controlled
baseline. This is not the profile of a pre-existing condition running its own independent course; it is the profile of a
managed condition destabilized by a new exposure.

Source: Dx Navjot Chaudhary, Neurology/Pain, Surrey iScope Concussion & Pain Clinics, clinical report, June 29, 2026.

.. Workers’ compensatian claim was denied by an audiologist who: auvibuted the claim t
the migraine:reduction. program or the. timeline. of: the fi rst emergency room visi
June 29,2026

ithout reviewing
No Chaudhar rv

Dr. Chaudhary, a specialist neurology and pain physician, examined the worker directly and reviewed the same medical
file available to. Ms. Pang. Her report identifies the specific gap in the Opinion: it labels the condition “pre-existing”
without ever engaging with the fact that the condition was actively and successfully managed until the exposure began.

4. Misapplication of the Mechanism-of-Injury Framework

The Opinion assesses the claim against two audiological mechanisms --- acoustic trauma (requiring peak sound
pressure of approximately 130 dB SPL) and acoustic shock (a sudden, unexpected intense sound, most often.scen in
call-centre headset injuries). Both are inner-ear mechanisms, Neither has been proposed by any treating specialist as the
injury pathway in this case, and the Opinion does not explain why those were the only two mechanisms considered.

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