LeMond Cycling, Inc. v. Trek Bicycle Corporation

Filing 138

Attachment 2
AFFIDAVIT of Dan Titus in OPPOSITION TO 114 MOTION for Summary Judgment filed by Trek Bicycle Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Rolf, Benjamin)

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LeMond Cycling, Inc. v. Trek Bicycle Corporation Doc. 138 Att. 2 Case 0:08-cv-01010-RHK-JSM Document 138-3 Filed 08/05/09 Page 1 of 3 TITUS EXHIBIT C TITUS EXHIBIT C Dockets.Justia.com Case 0:08-cv-01010-RHK-JSM Document 138-3 Filed 08/05/09 Page 2 of 3 CONFIDENTIAL Message----Kevin Ishaug (mailto:Kevin@FreewheelBike.com] Sent: Thursday, March 20, 2008 10:48 AM From: -----Original Titus, To: Subject: Dan RE: Lemond Dave Ebel and Jim Kudorer (sp?). One of the guys mothers brought us to build, included was the packing and cost (nice what your margin is on a Victoire!) and ship-to address (Greg's). mother knows Kathy Lemond somehow, that is as much as I know. in for list the bikes to know The Again, I i~ raises Regards, Kevin hate wasting your time and mine my blood pressure a few points. on this issue, but you can imagine Sent: Wednesday, March 19, 2008 2:48 To: Kevin Ishaug -----Original Message----From: Titus, Dan [mailto:Dan Titus@trekbikes.com] PM Subject: Kevin, Can you DT RE: Lemond provide first and last names of these kids? Thanks. To: Titus, Dan SUbject: Lemond Dan, I Kevin Ishaug [mailto:Kevin@FreewheelBike.comJ Sent: Wednesday, March 19, 2008 11:10 AM From: -----Original Message----- my wanted to bring to your attention Lemond. a matter that recently occurred in I worked with two young that were interested in buying road bikes for the upcoming season. After making the presentation and getting our selection narrowed down, the customers selected Lemond Zurich's based on my recommendation of men 1 market regarding Greg Two weeks ago, fit, .. .. z EXHIBIT ,; E 11 ~ ăi c.. TREK011479 Case 0:08-cv-01010-RHK-JSM Document 138-3 CONFIDENTIAL Filed 08/05/09 Page 3 of 3 value (we had men complete the sale last weekend. and performance. We did not have the exact young men were looking for, we ordered bikes specifications that the and were expecting two to After ordering bikes to fill the customers order young the last years bikes and they wanted this years models), one of the returned this past weekend to inform me that they were able to get bikes. The from Greg Lemond himself, and since they were saving over 50%, they ordered Victoire's instead. And, to make matters even worse, they ordered an extra bike to sell online to cover that cost of the first two "hook-up" results of Greg's actions: *Undermining the dealer relationship *Devaluing the process and services we provide *Taking profit SS directly out of my pocket *Straining the relationship between Freewheel and Lemond/Trek we Why would to support a vendor that is As an deliberately using back-channels immediate resolution to this the only fair and practical thing that I can see is to bill Mr. Lemond's account for the lost profit $$ that we have foregone as a result action. Furthermore, going forward, I would like an apology and of his his word problem, sell products in our market? that he Regards, will not sell around his dealers going forward. Kevin Ishaug Freewheel Bike Minneapolis, MN 55454 Owner, 612-339-2223 2 TREK011480

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