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We can assume that if a defect in a product causes harm, there would be potential liability. But if it fails to do harm?
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Think of a seat belt that doesn't restrain the passenger or an airbag that doesn't deploy. There's potential liability there. I would think the same might be the case for a smart gun that doesn't shoot. I'm not a products liability attorney but, depending upon how unreliable the technology is, then perhaps there's liability for negligent design. No machine is perfect so the rate of defective performance would be important. If the failure rate is not much different than "dumb" guns, then I can't see liability for that.