The Plaintiff's Counts: 1. Abnormally Dangerous Activity. 2. Private Nuisance 3. Negligence ( I am not sure, but couldn't professional malpractice be added?)
A: A cause of action (i.e., a "count") must be proved by pleading ultimate facts which if proved at trial would satisfy the elements of the cause of action. Abnormally Dangerous Activity
"In determining whether an activity is abnormally dangerous, the following factors are to be considered: (a) Whether the activity involves a high degree of risk of some harm to the person, land or chattels of others; (b) Whether the gravity of the harm which may result from it is likely to be great; (c) Whether the risk cannot be eliminated by the exercise of reasonable care; (d) Whether the activity is not a matter of common usage; (e) Whether the activity is inappropriate to the place where it is carried on; and (f) The value of the activity to the community.'" Yommer v. McKenzie, 255 Md. 220 224 (1969)
Ignoring, for the purposes of a dismissal motion, the technology that caused the injuries, you must show that the above-quoted elements are satisfied by the facts as part of your complaint, or the court must dismiss the complaint (or grant leave to amend, if you believe you can perfect the pleading by adding the missing facts).
The same analysis applies to each cause of action/count.Private Nuisance
Section 821D of the Restatement (Second) of Torts (1965) defines a private nuisance as "a  nontrespassory invasion of  another's interest in the private use and enjoyment of land." In this regard, we have held that "where a trade or business as carried on interferes with the reasonable and comfortable enjoyment by another of his property, a wrong is done to a neighboring
owner for which an action lies...." [numbers added] Meadowbrook Swimming Club v. Albert, 173 Md. 641, 645, 197 A. 146 (1938)
The basic elements necessary for a cause of action in negligence "are a duty or obligation which the defendant is under to protect plaintiff from injury, a failure to discharge that duty, and actual loss or injury to the plaintiff proximately resulting from that failure." Peroti v. Williams, 258 Md. 663, 669, 267 A.2d 114 (1970)
The Defendants position is 1. Fails to state a claim upon which relief may be granted 2. Plaintiff Assumed the risk 3. Contributory negligence.
A: Assumption of Risk and Contributory Negligence are affirmative defenses. They are inapplicable to a motion to dismiss. Failure to state a claim means that the plaintiff has not adequately pleaded the necessary facts to the required elements. Which leads us back to my first answer.
BotXXXXX XXXXXne, the defense to a motion to dismiss is that the case is adequately pleaded on the face of the complaint. If not, then the plaintiff must amend the complaint to provide facts sufficient satisfy the required elements.
Hope this helps.