Timebase Pty Ltd v. Thomson Corporation, The

Filing 200

LR7.1 WORD COUNT COMPLIANCE CERTIFICATE by Thomson Corporation, The, West Publishing Corporation, West Services re 198 Memorandum in Opposition to Motion. (Wagner, Kevin)

Timebase Pty Ltd v. Thomson Corporation, The

Doc. 200

ZASTROW EXHIBIT 12

ZASTROW EXHIBIT 12

Dockets.Justia.com

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UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA --------------------------------------------------------L e M O N D CYCLING, INC., Plaintiff, vs. T R E K BICYCLE CORPORATION, Defendant/Third-Party Plaintiff, vs. G R E G LeMOND, Third-Party Defendant. --------------------------------------------------------Case No. 08-1010

Video Deposition of DEAN GORE Thursday, May 14th, 2009 12:24 p.m. at GASS WEBER MULLINS LLC 309 North Water Street Milwaukee, Wisconsin

Reported by Kealoha A. Schupp, RPR

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Q A Q A Q A Q dealers that owned the concept stores, and then they had the opportunity to make the decision whether they would integrate it or not. Since we don't own them, I can't speak to whether it was -- what percent had done it. For

the two Trek stores that -- the two concept stores that we did own, yes, LeMond area was integrated into those two locations. What about Item 5, "Utilize Greg as spokesperson for new platforms," was that successfully accomplished? That's a large question. Did we have -- did -- did Yes.

we utilize Greg when we launched the product? He did attend when we launched in the Tour de Georgia.

He also attended when we launched the next

year at the Tour of California, and he did attend when we had all the dealers flown in for when we introduced the new carbon bikes for 2006. Okay. events? Oh, sure, yes. I think I've seen some. Okay. All right. There were photographs taken of some of these

But -- was -- was Greg readily available for outside of that? Okay. Move to strike. MS. RAHNE: But I No. It was a challenge.

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marketplace. A A Q B Y MR. WEBER: Q A Q A Q Counsel had shown you some pages in the PowerPoint. Mm-hmm. And -- and -Yes. -- let me just go back to a few of these. If you'd EXAMINATION

turn several pages from the end, there's a reference there to "Early 2006. Trek revamps the LeMond

product line -- Great Product." Okay. Do you see that? All right. Tell us what happened

in 2006 with respect to the LeMond product line, flying dealers to Waterloo, the marketing campaign, Tour de Georgia, etc. 2006 was -- I think it was a milestone year for LeMond because we -- we, saying because I was -- I was living the LeMond brand. That's -- that's what I

did every day was come in and work on LeMond and Fischer. And it was -- LeMond had -- was introducing better product than Trek had in the It had an industry-leading carbon

product that when we launched to our dealers, they were very, very excited about it. We flew in 100

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great press. rented it out. of California. A 2007. 2007 we -- we introduced the next evolution of the new carbon product that we had. It was 100,

150 grams lighter than what we launched the season prior. It put LeMond into a whole new price point They were very

because these bikes were 6-, $7,000. expensive.

We did a similar press tour where we flew the domestic and some UK editors into the Tour Again, wined -- wined and dined in

the Santa Rosa area, and let them ride the bikes, and got them the opportunity to watch the race. And we even went to the extent we had a LeMond night at a big theater in California. We hired Phil Liggett, who's the We

preeminent voice of cycling in the English speaking world. He came, and he and Greg put on a

play-by-play, stage-by-stage narration of the 1991 Tour de France, and we did the promotion. out the theater. We sold

Gave all the proceeds to the I

charity that supported the Tour of California.

paid for Phil Liggett, I paid for all the editors' flights. Things were going great. We -- we had We

The dealers were very interested.

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Q A A A Q A Q Q had great product. cylinders. There's been some discussion about the August 2007 Trek World Show several months after this California event. Mm-hmm. At Trek World, from time to time does Trek make bikes available for dealers to ride during the show? Yes. And in August of 2007 do you recall whether bikes were made available for dealers to ride? Yes. And LeMonds were part of that, and not only LeMond was really hitting on all

were they part of that, in 2006 we flew all our dealers in to introduce them LeMond road bikes. 2007 we had a new Trek product that we introduced, so we flew the dealers in again. Introduced them to the new Trek road product. But

when we did that, we also showed them the new LeMond product that we had introduced in February. So the

dealers had the choice of riding a LeMond or riding the Trek at that June introduction in 2007. Okay. And then that fleet of bikes just rolled right into our big Trekfest event where all Trek and LeMond dealers were invited, and that was in August.

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