Weather Underground, Incorporated v. Navigation Catalyst Systems, Incorporated et al

Filing 269

STATEMENT of Pretrial Conference Bench Book by Connexus Corporation, Firstlook, Incorporated, Navigation Catalyst Systems, Incorporated, Weather Underground, Incorporated (Attachments: # 1 Administrative Section, # 2 Exhibit Theory of the Case, # 3 Exhibit Plaintiff's Proposed Voir Dire, # 4 Exhibit Defendants' Proposed Voir Dire, # 5 Exhibit Witness List, # 6 Exhibit Exhibit List, # 7 Exhibit agreed Upon Jury Instructions, # 8 Exhibit Plaintiff's Additional Proposed Instructions, # 9 Exhibit Defendants' Additional Proposed Instructions, # 10 Exhibit Plaintiff's Proposed Verdict Form, # 11 Exhibit Defendants' Proposed Verdict Form, # 12 Exhibit Evidentiary Issues) (Delgado, William)

Plaintiff’s Proposed Verdict Form

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
THE WEATHER UNDERGROUND, INC.,
a Michigan corporation,
Plaintiff,
vs.

Case No. 2:09-CV-10756
Hon. Marianne O. Battani

NAVIGATION CATALYST SYSTEMS,
INC., a Delaware corporation;
CONNEXUS CORP., a Delaware
corporation; FIRSTLOOK, INC., a
Delaware corporation; and EPIC
MEDIA GROUP, INC., a Delaware
corporation;
Defendants.
______________________________________________________________________
Enrico Schaefer (P43506)
Brian A. Hall (P70865)
TRAVERSE LEGAL, PLC
810 Cottageview Drive, Unit G-20
Traverse City, MI 49686
231-932-0411
[e-mail]
[e-mail]
Lead Attorneys for Plaintiff
Anthony P. Patti (P43729)
HOOPER HATHAWAY, PC
126 South Main Street
Ann Arbor, MI 48104
734-662-4426
[e-mail]
Attorneys for Plaintiff

Nicholas J. Stasevich (P41896)
Benjamin K. Steffans (P69712)
Bruce L. Sendek (P28095)
BUTZEL LONG, PC
150 West Jefferson, Suite 100
Detroit, MI 48226
[phone]
[e-mail]
[e-mail]
[e-mail]
Local Counsel for Defendants
William A. Delgado
WILLENKEN WILSON LOH & LIEB LLP
707 Wilshire Boulevard, Suite 3850
Los Angeles, CA 90017
[phone]
[e-mail]
Lead Counsel for Defendants

______________________________________________________________________
PLAINTIFF’S PROPOSED SPECIAL VERDICT FORM

123473.1

We, the jury, being first duly empanelled and sworn in the above-entitled cause,
do find as follows:
1. Please put a “YES” next to each domain name on Exhibit A where you find
Defendants engaged in cybersquatting in violation of the Anticybersquatting
Consumer Protection Act.
Please put a “NO” next to each domain name on Exhibit A where you find
Defendants did not engage in cybersquatting in violation of the
Anticybersquatting Consumer Protection Act.

2. For each domain name listed on Exhibit A where you answered “YES”, award
Plaintiff no less than $1,000 and no more than $100,000 for each such
domain.
For each domain name listed on Exhibit A where you answered “NO”, do not
award any damages.
Add up the total award for all domains, if any, and enter the total amount you
award to Plaintiff below.

________________________

The presiding juror should sign and date this verdict form.

Dated this _____ day of March, 2012

__________________________________________
Presiding Juror

123473.1

Page 2 of 3

Exhibit A
Plaintiff Exhibit No:

Domain Name:

Cybersquatting
Violation:
“Yes” or “No”

Award no less than
$1,000 and no more
than $100,000 for each
domain where the
answer is “Yes.”
Do not award any
amount for any domain
where the answer is
“NO.”

3.1
3.2

123473.1

Damage Award:

Page 3 of 3