Is cause in fact considered to be a proximate cause?

⁴ The reason for this conflation of the two concepts probably lies in the fact that cause in fact has been referred to as "[o]ne of the concepts included in the term proximate cause." ( Mitchell v. Gonzales (1991) 54 Cal.3d 1041, 1049, 1 Cal.Rptr.2d 913, 819 P.2d 872.) Thus, a defendant who argues his conduct was not the proximate cause of the complaining party's injuries may be understood to argue, depending on the facts of the case, that he should not be held liable either because his conduct was not a cause in fact of the injuries or because, even though his conduct was a cause in fact of the injuries, his conduct should not be considered a proximate cause of the injuries under the various principles that go into determining proximate causation.