Does the term "proximate cause" need to be used in the prosecution argument or the jury's instructions?

Here, in contrast, the term "proximate cause" did not appear in the prosecutor's argument or the jury's instructions, and the evidence did not support a conclusion that appellant caused Eveningred's injuries in any way other than personally and directly. The jury was instructed that the prosecution was required to prove appellant personally inflicted great bodily injury. Further instruction on the meaning of this requirement was not required. " ' "A word or phrase having a technical, legal meaning requiring clarification by the court is one that has a definition that differs from its nonlegal meaning." [Citations.]' (People v. Hudson (2006) 38 Cal.4th 1002, 1012.) Here, the

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