-&BRG
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`Berketey Research Group
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`JEFFERY A. STEC, Ph.D.
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`BERKELEY RESEARCH GROUP, LLC
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`70 W. Madison Suite 5000 | Chicago, IL 60602
`
`Direct: 312.429.7970
`
`istec@thinkbrg.com
`
`As a Managing Director, a leader of Berkeley Research Group‘s Intellectual Property Practice, and a
`co-Ieader of its Economics and Damages Community, Dr. Stec has worked extensively over the last 17
`years in the areas of antitrust, finance, intellectual property, and survey research, both as a consulting
`expert and as an expert witness. His engagements typically involve the application of economic,
`financial, statistical, and survey research theory and methodology to the collection and analysis of
`data to evaluate the economic impact of decisions made by consumers and firms.
`
`In the area of intellectual property, Dr. Stec has conducted economic and econometric analyses to
`determine the value of intellectual property as well as the amount of economic damages resulting from
`patent, trademark, trade secret, or copyright infringement.
`In his work, he has addressed economic
`issues such as the appropriate measurement of revenues associated with the use of the infringing IP,
`the portion of those revenues that can be attributed to the intellectual property, and whether the
`apportionment can be regarded as reasonable. He has evaluated economic and survey research
`issues in the context of Section 33? investigations conducted by the US. International Trade
`Commission. In addition, he has also evaluated the effects of anticompetitive conduct as it relates to
`the use of IP. In the context of trademarks and trade dress, he has evaluated issues of secondary
`meaning, genericness, dilution, and likelihood of confusion. Dr. Stec has also determined economic
`damages that have resulted from false advertising and counterfeit claims.
`
`In the area of survey research, Dr. Stec has both created and critically evaluated surveys in the
`context of antitrust and intellectual property engagements. He has developed complex sample
`designs, designed survey questionnaires, and collected and analyzed survey data, including the
`derivation of complex variance estimates using simulation methods. He has conducted surveys that
`have been used to determine consumers' perceptions and actions in the marketplace, including
`whether products‘ names or trade dress are distinctive, confusing, or generic. Dr. Stec has also
`examined how products are used in the marketplace and how consumers value product features. Dr.
`Stec has consulted on best survey practices for the design, collection, and analysis of survey data.
`
`In the area of antitrust, Dr. Stec has used economic and econometric analyses to investigate issues
`related to market definition, determination of market power or market dominance, and the effect of
`anticompetitive acts on competition. Some of these investigations include the effects of
`anticompetitive acts in the context of Sherman, Clayton, and Robinson-Patman Act claims dealing with
`abuse of market power as well as the use of various horizontal and vertical restraints, like price fixing,
`price discrimination, refusals to deal, exclusive dealing arrangements, and tying, on individual firms or
`members of a class.
`
`In the area offinance, Dr. Stec has used financial theory and econometrics to conduct analyses to
`determine asset values and shareholder loss in the context of securities fraud and late trading claims.
`These analyses have included the use of various loss causation and event study paradigms as well as
`trading simulation studies. Dr. Stec has examined claims of financial lending discrimination, which
`included investigations of the likelihood of discrimination and the potential damages caused by that
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`discrimination. Dr. Stec has also used financial theory to determine damages in commercial contract
`disputes and product liability litigation.
`
`Engagements Dr. Stec has worked on have dealt with the semiconductor and semiconductor design,
`computer software and hardware, consumer products, pharmaceuticals, telecommunications, handheld
`mobile devices, paper products, casino gaming, consumer appliances, automated pharmacy systems,
`consumer electronics, automobiles, heavy haul truck trailers, textile machine, precious stones, fashion
`apparel and luxury accessories, outdoor lighting, vehicle parts, medical products, hardware, product
`packaging, toys, entertainment, food, mass media, plastics, pallet, television ratings, financial securities
`and loans, alcohol, tobacco, sugar, sweetener, and tradeshow industries, among others.
`
`Prior to joining Berkeley Research Group, Dr. Stec had been engaged as a Vice President in economic
`and survey research consulting with another economic consulting firm. Prior to that, he has analyzed
`the credit card industry in detail, including co—authoring monthly state and national surveys to gauge
`consumers’ credit card and overall indebtedness. He also helped to design numerous telephone, mail,
`and internet surveys for various clients. His responsibilities included everything from sample and
`questionnaire design to data collection methods and statistical analyses of survey data. He has
`performed econometric studies and written on various economic and survey research topics such as,
`optimal forecasting methods using time- series data, the effects of unit nonresponse on survey data,
`efficient methods for conducting telephone surveys, and methods for gauging the degree of consumer
`indebtedness using original survey data.
`
`the
`Dr. Stec has presented his research at the annual meetings of the American Statistical Association,
`American Association of Public Opinion Research, the Midwest Association of Public Opinion Research,
`the Ohio Association of Economists and Political Scientists, the Midwest Macroeconomics Association,
`and the Columbus Association of Business Economists as well as in numerous presentations as a guest
`lecturer and presenter for OLE courses. He has also published his work in the American Statistical
`Association’s Proceedings of the Section on Survey Research Methods and Proceedings of the Section
`on Government Statistics and Section on Social Statistics. Dr. Stec also contributed and served as a
`
`member of the advisory board for the Encyclopedia of Survey Research Methods. He has also written the
`chapter on the use of surveys in litigation published in the Litigation Services Handbook.
`
`EDUCATION
`
`Ph.D., Economics
`
`The Ohio State University, 2000
`
`MA, Economics
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`The Ohio State University, 1995
`
`BA, Economics,
`Math Minor
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`The University of Illinois — Chicago, 1994
`
`B.A., Philosophy,
`
`Comell University, 1991
`
`Psychology
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`PROFESSIONAL EXPERIENCE
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`2004-2017
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`2000—2004
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`Vice President. Intellectual Property, Charles River Associates
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`Director, lnteliectual Property, lnteCap, Inc.
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`SELECTED EXPERIENCE
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`Intellectual Property
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`Developed economic models to determine damages due to infringement of patents held by a large
`paper products company.
`Included a determination of the damages due to the plaintiff's loss of
`distribution for its patented products due to the infringement of the defendant. Developed a lost
`distribution model to quantify the amount of distribution lost and the value of that distribution in terms
`of lost sales to the plaintiff. Additionally, it included the development of a lost profits, market share
`based model that quantified the lost profits due to lost customers' sales.
`
`Provided expert testimony in a patent infringement litigation in the plastic product manufacturing
`industry. Determined the percentage of accused products that infringed a number of patents by
`developing and conducting a multi-stage probability sample of the relevant plastic packaged products.
`Responsibilities included sample design, overseeing data collection, and data analysis using
`advanced statistical methods.
`
`Developed economic models to determine damages suffered by a manufacturer of pharmaceutical
`products as a result of infringement of a number of patents. Studied the market for the patented
`product, evaluated the substitutability of potentially competing products, and determined sales and
`profits lost by the patent holder. Constmcted and queried a large product database to determine which
`products infringed which of the many patents-in-suit. Developed analyses of a reasonable royalty
`under a hypothetical licensing agreement and the effect ofthe infringing product on the price in the
`marketplace. Evaluated an econometric market expansion theory proposed by the counterparty.
`
`Developed economic models to determine damages suffered by a manufacturer of semiconductor
`devices as a result of a competitor's infringement of numerous patents. Determined the profits the
`plaintiff lost due to price erosion and a determination of reasonable royalties on infringing sales.
`Constructed a sophisticated econometric model using a large dataset of sales, prices, and other
`variables that estimated the price elasticity of demand for the relevant product and geographic markets.
`
`Provided expert testimony in a trademark infringement litigation in the children's toy industry.
`Determined whether survey data were appropriately collected and analyzed in the evaluation of
`secondary meaning to a mark. Evaluated the survey methodology used by the counterparty to
`determine whether secondary meaning had accrued to the mark.
`
`Constmcted and queried a large proprietary database of regional oil and gas prices to determine
`differences in branded and generic prices for the purposes of determining the value of a gasoline
`trademark.
`included filtering cfthe database to examine price differences for various grades of gasoline,
`various regions of operation, and various time periods
`
`Provided expert testimony in a trademark infringement litigation in the wine industry. Determined
`whether survey data were appropriately collected and analyzed in the context of likelihood of confusion
`between two marks. Evaluated the survey methodology used by the counterparty to determine
`whether there was survey evidence of the likelihood of confusion between the marks.
`
`Developed economic models to determine damages suffered by a manufacturer of coronary medical
`devices as a result of a competitor's infringement of numerous patents. Developed lost profits and
`reasonable royalty models addressing issues such as market definition, product pricing in the absence
`of infringement, market size and competitors' market share in the absence of infringement, and
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`determination of incremental costs. Devetoped sophisticated econometric models
`issues.
`
`to address these
`
`Provided expert testimony in a theft of trade secrets in the investor relations services and technology
`industry. Determined expected client longevity in the absence of the theft of trade secrets taking into
`account client—specific characteristics using multivariate statistical models that also accounted for the
`censored nature of the underlying data. Developed damages models using the expected client
`longevity and the actual client longevity to determine the impact of the alleged theft of trade secrets.
`
`Developed economic models to determine damages suffered by a consumer goods manufacturer as
`a result of counterfeit sales being made by various retailers. Determined the profits the plaintiff
`lost
`due to price erosion in the relevant product and geographic markets. Developed econometric models
`to determine the price elasticity of demand for the impacted consumer goods.
`
`Developed economic models to determine damages suffered by inventors of children's consumer
`products as a result of infringement of a number of patents. Evaluated the product and geographic
`markets for the patented product; valued the patented technology, including the determination of the
`impact of the use of the patented technology on the infringer‘s sales and profits and the costs to
`design around the infringed technology; and determined the impact various other factors would
`h a v e on the royalty rate that might be negotiated by both parties.
`
`Developed economic models to determine damages suffered by a manufacturer of gene sequencing
`and analysis products as a result of infringement ofa number of patents. Studied the markets for the
`patented product, evaluated the substitutabiiity of potentially competing products made by various
`manufacturers, and valued the patented technology from both parties” perspectives. Constructed
`and queried a large product database to determine which products infringed which patents—in—suit
`and the revenues associated with those products.
`
`Provided expert testimony in a patent infringement matter related to antitrust counterclaims in the
`centralized hospital pharmacy automation systems market. Conducted analyses to determine the
`relevant product and geographic markets. Evaluated whether the counterparty had market power in
`the relevant markets. Examined alleged anticompetitive acts to determine the economic impact of
`these acts. Determined economic damages these anticompetitive acts had on the claimant.
`
`Provided expert testimony in a trademark infringement litigation in the low-bed, heavy haul trailer
`industry. Designed sampling approach and survey instrument used to collect data. Analyzed data
`collected from the survey in the context of whether secondary meaning could be attached to the
`trademark at issue.
`
`Provided expert testimony in a trademark infringement litigation in the clothing fashion industry.
`Evaluated the market definition methodotogy used by the opposing expert and determined the
`appropriate definition of the relevant market. Evaluated the survey methodology used by the
`counterparty to determine whether there was survey evidence of the likelihood of confusion between
`the marks. Determined whether survey data were appropriately collected and analyzed to determine
`the likelihood of confusion. Evaluated whether damages occurred to the defendant due to the
`likelihood of reverse confusion.
`
`Developed economic analyses to determine the appropriate royalty rate for a compulsory license which
`would give the infringing party the ability to continue to make and sell medical devices after a jury found
`infringement. Examined the patented technology's benefits to the infringer and the maximum itwould
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`be willing to pay for its use. Examined the benefits of the patented technology to the infringed party
`and the minimum it would be willing to accept for its use.
`
`Provided expert testimony in a trademark infringement litigation in the antibiotic ointment industry.
`Evaluated the survey methodology used by the oounterparty to determine whether there was survey
`evidence that secondary meaning had been established forthe trademark. Determined whether
`survey data were appropriately collected and analyzed to determine secondary meaning. Evaluated
`the appropriateness of using the survey data collected for the purposes of determining whether
`dilution to the trademark had occurred.
`
`Developed economic models to determine damages suffered by a manufacturer of outdoor security
`lighting products as a result of patent infringement. Defined the markets forthe patented product and
`the relevant substitutes for that product. Established the likelihood that lost sales due to the
`counterparty’s infringement of the patent. Determined the value of the patented technology to both
`parties in generating product sales.
`
`Provided expert testimony in a patent infringement litigation in the handheld mobile computing devices
`industry for the purposes of a preliminary injunction. Defined the relevant market for the alleged
`infringing products. Determined the competitive effect that the accused products would have on the
`counterparty’s sales and product prices. Evaluated the likelihood that the plaintiff would be irreparable
`harmed by the alleged patent infringement. Evaluated the counterparty’s opinions as to the effects on
`its sales and prices of the alleged infringement.
`
`Conducted survey research in a trademark infringement litigation in the student information systems
`software industry. Designed the survey questionnaire and sampling approach used to collect data.
`Analyzed data collected from the survey in the context of whether secondary meaning could be
`attached to the trademark at issue.
`
`Provided expert testimony in a patent infringement litigation in the hydraulic disc bicycle brake industry.
`Conducted analyses to determine the relevant market. Evaluated claims of lost profits, price erosion,
`and reasonable royalties. Developed analyses to determine demand for the patented feature of the
`products as well as economic damages due to patent infringement.
`
`Provided expert testimony in a patent infringement litigation in the medical products industry. Evaluated
`the product market for the patented product to determine demand for and the value of the patented
`technology. Determined the costs to design around the infringed technology and determined the
`impact various other factors would have on the royalty rate that might be negotiated by both parties.
`
`Provided expert testimony in a copyright infringement litigation in the software industry. Determined
`the relevant market in which the software was used. Developed analyses to determine the foregone
`profits due to the illegal use of the copyrighted software as well as the unjust enrichment for that use.
`
`Developed economic and survey research analyses to evaluate damages claims associated with
`alleged violations of the Lanham Act concerning false advertising in clothes dryer industry. Evaluated
`whether the alleged false advertising had an adverse impact on the sales and prices of the
`counterparty’s clothes dryers. Evaluated whether the alleged false advertising had a favorable impact
`on the accused party's clothes dryers.
`
`Provided expert testimony in a patent infringement litigation in the farm machinery industry. Oversaw
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`the sampling and collection of data from the use otthe alleged infringing machines as well as non—
`infringing altematives. Conducted advanced statistical tests to determine whether various
`configurations of the farm machinery produced statistical different measures of performance. Evaluated
`the statistical methodology used by the counterparty’s expert.
`
`Provided expert testimony in patent infringement matter in the medical products industry. Studied the
`markets for the patented product and evaluated the substitutability of potentially competing products
`made by various manufacturers to determine the relevant market. Developed economic models to
`value the patented technology from both parties’ perspectives in order to determine damages suffered
`by the plaintiff. Evaluated the opposing expert's damages opinions attributed to the counterparty‘s
`alleged infringement.
`
`Conducted industry research and developed economic models to determine the value of a portfolio of
`patents in the gene sequencing industry. Provided information on the possible ways in which the patents
`could be monetized to provide value to the client.
`
`Provided expert testimony in a patent infringement litigation in the compact digital camera industry.
`Evaluated the survey methodology used by the counterparty’s expert to determine the value of the
`patented features in the accused products. Determined whether the survey and sampling design
`were appropriately constructed. Examined whether the survey data were appropriately collected and
`analyzed to determine the value of the patented features.
`
`Conducted survey research in a copyright infringement litigation in the outdoor wind sculpture industry.
`Designed the survey questionnaire and sampling approach used to collect data. Analyzed data
`collected from the survey to evaluate whether the protected work and the accused work were
`substantially similar from the viewpoint of an ordinary observer.
`
`Provided expert testimony in a patent infringement investigation in the video analytics software
`industry. Evaluated the counterparty’s claims regarding the economic prong of the domestic industry
`requirement. Determined the amount of the bond associated with the Presidential review period.
`
`Provided expert testimony in a patent infringement investigation in the vehicle windshield wiper blade
`industry. Analyzed financial and industry information to evaluate whether a domestic industry had
`been established by the Complainant. Conducted analyses to evaluate the appropriateness of an
`exclusion order, cease—andxlesist order, and the appropriate amount of the bond associated with the
`Presidential review period. Evaluated the counterparty’s claims regarding the economic prong of the
`domestic industry requirement.
`
`Conducted survey research in a trademark infringement litigation in the retirement home industry.
`Designed the survey questionnaire and sampling approach used to collect data. Analyzed data
`collected from the survey in the context of whether there was the likelihood of confusion between the
`trademarks at issue.
`
`Developed economic analyses to determine whether there was evidence of commercial success for a
`pharmaceutical product in its relevant market. Examined the financial information for the
`pharmaceutical product as well as discounted profitability of the product relative to the investments
`undertaken to bring the product to market. Evaluated the counterparty’s claims regarding commercial
`success.
`
`Conducted survey research in a trademark infringement litigation in the coffee maker industry.
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`Designed sampling approach and survey instrument used to collect data. Analyzed data collected
`from the survey in the context of whether secondary meaning could be attached to the trademark at
`issue.
`
`Conducted industry research, evaluated economic models, and developed licensing strategy to assist
`the valuation and licensing of patented technology and trade secrets in the steel—making industry.
`Provided information on the possible ways in which the technology could be licensed and provided
`strategic advice on how to set up the licensing agreement.
`
`Developed economic analyses to determine whether there was evidence of commercial success for a
`pharmaceutical product in its relevant market. Determined the relevant market for the product.
`Examined the financial information for the pharmaceutical product as well as the market presence of
`the product. Accounted for relevant macroeconomic, industry, and company-specific factors in
`examining the pharmaceutical product’s performance.
`
`Provided expert testimony in a patent infringement litigation in the commercial bakery tray industry.
`Conducted analyses to determine the relevant market. Determined economic damages due to lost
`profits on lost sales, price erosion, and reasonable royalties.
`
`Provided expert testimony in a patent infringement investigation in the smartphone, tablet, and other
`wireless devices industries. Analyzed the relevant markets to evaluate whether harm to public interest
`was likely to occur if the Commission was to grant the Complainant an exclusion order.
`Evaluated the counterparties' claims regarding potential harm to public interest under the proposed
`exclusion order.
`
`Provided expert testimony in a trademark infringement litigation in the tool industry. Evaluated the
`survey methodology used by the counterparty to determine whether there was survey evidence of
`secondary meaning related to the trade dress of the tools. Also evaluated whether there was a
`likelihood of confusion in the marketplace between the asserted trade dress and the accused trade
`dress.
`
`Conducted survey research in a trademark and trade dress infringement litigation in the office
`supplies industry. Designed sampling approach and survey instrument used to collect data.
`Analyzed data collected from the survey in the context of whether there was a likelihood of confusion
`in the marketplace between the protected trademark and trade dress and the accused trademark and
`trade dress.
`
`Provided expert testimony in patent infringement litigations in the software industry. Designed
`sampling approach and survey instrument used to collect data. Analyzed data collected from the
`survey in the context of the usage, importance, and purchasing drivers of various software features.
`Evaluated the counterparty’s claims regarding various software features.
`
`Provided expert testimony in a trademark infringement litigation in the vegetable produce industry.
`Evaluated the survey methodology used by the counterparty to determine whether there was survey
`evidence of a likelihood of confusion between the asserted trademark and the accused trademark.
`
`Determined whether survey data were appropriately collected and analyzed to determine likelihood of
`confusion.
`
`Conducted survey research in a patent infringement litigation in the smartphone, tablet, MP3 player,
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`and computer industries. Designed sampling approach, experimental design, and survey instrument
`used to collect data. Analyzed data collected from the survey in the context of the usage, importance,
`and willingness to pay for various product features.
`
`Provided expert testimony in a patent infringement litigation in the medical products industry for the
`purposes of a preliminary injunction. Defined the relevant market for the alleged infringing products.
`Determined the competitive effect that the accused products would have on the counterparty’s sales
`and product prices. Evaluated potential damages claims and the defendant's ability to pay these
`claims. Evaluated the likelihood that the plaintiff would be irreparable harmed by the alleged patent
`infringement. Evaluated the counterparty's opinions as to the effects on its sales and prices of the
`alleged infringement.
`
`Provided expert testimony in a patent infringement litigation in the smartphone industry. Evaluated the
`survey methodology used by the counterpaity to determine the usage of, importance of, and
`willingness to pay for the alleged patented smartphone features.
`
`Conducted survey research and econometric analyses in a patent infringement litigation in the digital
`content management industry. Evaluated the counterparty‘s survey research in the context of the
`willingness to pay for various product features.
`
`Provided expert testimony in a patent infringement arbitration in the smartphone industry. Conducted
`economic analyses to determine the appropriate balancing royalty payment for a cross license to each
`party's respective patent portfolios, which included patents, divested patents, and standard essential
`patents. Evaluated the counterparty‘s opinions as to balancing royalty payment.
`
`Conducted survey research in a trade dress matter in the clothing industry. Designed sampling
`approach and survey instrument used to collect data. Analyzed data collected from the survey in the
`context of whether there was secondary meaning associated with the asserted trade dress.
`
`Conducted survey research in a trade dress matter in the baked goods industry. Designed sampling
`approach and survey instrument used to collect data. Analyzed data collected from the survey in the
`context of whether there was likelihood of confusion between the asserted trade dress and the
`
`allegedly infringing trade dress.
`
`Provided expert testimony in patent infringement matter in the automotive industry. Evaluated the
`markets for the patented product as well as licensing practices in the industry. Developed economic
`models to value the patented technology from both parties’ perspectives in order to determine
`damages suffered by the plaintiff. Evaluated the opposing expert’s damages opinions attributed to the
`counterparty‘s alleged infringement.
`
`Provided expert testimony in a patent infringement litigation in the disposable training pants industry.
`Evaluated the counterparty’s survey research in the context of the usage, importance, and willingness
`to pay for various product features. Evaluated the counterparty's damages claim as it related to the
`use of the counterparty’s survey evidence.
`
`Provided expert testimony in a Lanham Act matter concerning false advertising in the mattress industry.
`Developed financial and econometric models to determine to what extent, if any, the alleged false
`advertising had on the plaintiff's sales and profits. Incorporated these models into a determination of the
`appropriate damages due to the alleged false advertising.
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`Provided expert testimony in a trademark infringement investigation in the shoe industry. Evaluated the
`survey methodology used by the oounterparty to determine whether there was a likelihood of confusion
`in the marketplace between the asserted trade dress and the accused trade dress.
`
`Provided expert testimony in a patent infringement litigation in the server software industry. Evaluated
`the oounterparty’s survey research in the context of the usage of various product features. Evaluated
`the counterparty's damages claim as it related to the use of the counterparty's survey evidence to
`apportion the royalty base and set the royalty rate.
`
`Provided expert testimony in a patent infringement litigation in the camera industry. Designed
`sampling approach and survey instrument used to collect data. Analyzed data collected from the
`survey in the context of the usage and relative importance of various camera features. Evaluated the
`counterparty’s claims regarding various software features.
`
`Conducted survey research and developed economic analyses to evaluate claims associated with
`alleged false advertising in food industry. Evaluated whether the alleged false advertising had an
`adverse impact on the demand for the relevant food product.
`
`Provided expert testimony in a trademark infringement investigation in the digital media content
`software industry. Evaluated the survey methodology used by the counterparty to determine whether
`there was a likelihood of confusion in the marketplace between the asserted trade dress and the
`accused trade dress.
`
`Conducted survey research to evaluate claims associated with alleged false advertising in healthcare
`industry. Designed sampling approach and survey instrument used to collect data. Analyzed data
`collected from the survey to determine whether there was an impact to the false advertising.
`
`Provided expert testimony in a patent infringement litigation in the telematics devices industry.
`Designed sampling approach and survey instrument used to collect data. Analyzed data collected
`from the survey in the context of the usage and relative importance of various telematics devices
`features.
`
`Provided expert testimony in a trademark infringement litigation in the consumer lighting products
`industry. Conducted survey research to determine whether there was a likelihood of confusion in the
`marketplace between the asserted trademarks and trade dress and the accused trademarks and trade
`dress.
`
`Provided expert testimony in a false advertising litigation in the pharmaceutical industry. Conducted
`econometric analyses that were used to determine whether the plaintiff incurred damages due to the
`alleged false advertising. Evaluated the counterparty's oounterclaims regarding false advertising
`damages.
`
`Provided expert testimony in a patent infringement matter in the automobile industry. Determined the
`value that could be associated with the alleged use of the patented technology in one component of a
`multicomponent product and the damages associated with that alleged use. Evaluated the
`oounterparty‘s damages claims regarding patent infringement damages.
`
`Provided expert testimony in a trademark infringement litigation in the video and audio editing software
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