In Case 1, a Man Was Walking His Rottweiler Dog

In case 1, a man was walking his Rottweiler dog in the park. The dog bit a woman in an unprovoked attack. The dog had bitten someone before and the owner was aware of this. The Court of Appeal decided that that the man was liable. According to an academic commentator, the ratio of the case is: 'The owner of a dog that had bitten someone before, where the owner was aware of this, is liable in negligence for any injury caused in a public place.'
In case 2, a woman was walking her German Shepherd dog in the park. The dog bit a child in an unprovoked attack. The dog had never bitten anyone before. The Court of Appeal decides that the woman is liable and that the ratio of case 1 is, in fact, that 'the owner of a dog is liable in negligence for any injury caused in a public place regardless of whether the dog had bitten before or whether the owner was aware of this'.
Which of the facts deemed to be material by the academic commentator in case 1 have now been deemed to be immaterial by the Court of Appeal?

A) That the dog was a Rottweiler.
B) That the dog had bitten before and the owner knew it was dangerous.
C) That it was a child who was bitten.
D) That it was a dog who bit the woman.