`
`UNITED STATES DISTRICT COURT
`DISTRICT OF MINNESOTA
`
`
`
`National Presto Industries, Inc.,
`
`
`Plaintiff,
`
`
`Case No. 18-cv-03321 (SRN/BRT)
`
`
`JOINT PROPOSED
`INTRODUCTION TO THE CASE
`
`
`U.S. Merchants Financial Group, Inc.,
`d/b/a Greenmade,
`
`
`v.
`
`Defendant.
`
`
`
`
`
`
`
`Pursuant to the Court’s Final Pretrial Order (Dkt. 354), the parties submit the
`
`following joint introduction to the case, to be read to prospective jurors during voir dire:
`
`This case involves two parties: Plaintiff National Presto Industries, Inc., and
`
`Defendant U.S. Merchants Financial Group, Inc., d/b/a Greenmade. The parties each sell
`
`parabolic electric heaters at Costco. Plaintiff alleges that it holds valid copyrights in two
`
`separate instruction manuals for Plaintiff’s parabolic electric heaters—works that are
`
`titled HEATDISH Plus Tilt Parabolic Electric Heater Instructions and HEATDISH
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`Parabolic Electric Heater Instructions. Plaintiff further alleges that Defendant’s
`
`instruction manual, which was included within the package for Defendant’s parabolic
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`electric heater sold at Costco from Fall 2018 through Spring 2019, infringes Plaintiff’s
`
`copyrights. Defendant denies Plaintiff’s claims.
`
`This introduction is also incorporated in the parties’ Joint Proposed Jury
`
`Instructions (Dkt. 389) in the “Before Voir Dire” proposed instruction.
`
`
`
`1
`
`
`
`CASE 0:18-cv-03321-SRN-LIB Doc. 390 Filed 12/15/21 Page 2 of 3
`
`Dated: December 15, 2021
`
`
`
`Dated: December 15, 2021
`
`
`Respectfully submitted,
`
`
`
`s/ Franklin M. Smith (with permission)
`Jeffer Ali (#0247947)
`ali@ptslaw.com
`PATTERSON THUENTE PEDERSEN, P.A.
`4800 IDS Center
`80 South Eighth Street
`Minneapolis, MN 55402
`Telephone: (612) 349-5740
`Facsimile: (612) 349-9266
`
`John S. Artz, admitted pro hac vice
`jsartz@dickinsonwright.com
`Yafeez S. Fatabhoy, admitted pro hac vice
`yfatabhoy@dickinsonwright.com
`DICKINSON WRIGHT PLLC
`350 S. Main Street, Suite 300
`Ann Arbor, MI 48104
`Telephone: (248) 433-7262
`Facsimile: (844) 670-6009
`
`Andrea L. Arndt, admitted pro hac vice
`aarndt@dickinsonwright.com
`Franklin M. Smith, admitted pro hac vice
`fsmith@dickinsonwright.com
`DICKINSON WRIGHT PLLC
`2600 West Big Beaver Road, Suite 300
`Troy, MI 48084
`Telephone: (248) 433-7200
`Facsimile: (844) 670-6009
`
`Attorneys for Plaintiff
`
`Respectfully submitted,
`
`
`
`
`s/ Christopher K. Larus
`Christopher K. Larus (#0226828)
`CLarus@robinskaplan.com
`William E. Manske (#0392348)
`WManske@robinskaplan.com
`Emily J. Tremblay (#0395003)
`ETremblay@robinskaplan.com
`
`2
`
`
`
`CASE 0:18-cv-03321-SRN-LIB Doc. 390 Filed 12/15/21 Page 3 of 3
`
`Jessica L. Gutierrez (#0396359)
`JGutierrez@robinskaplan.com
`Ellen K. Levish (#0400878)
`ELevish@robinskaplan.com
`ROBINS KAPLAN LLP
`800 LaSalle Ave., Suite 2800
`Minneapolis, MN 55402
`Telephone: (612) 349-8500
`Facsimile: (612) 339-4181
`
`Attorneys for Defendant
`
`3
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`
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