Case 1:20-cv-00393-LMB-TCB Document 1416-2 Filed 08/19/22 Page 1 of 6 PageID# 35731
`Case 1:20-cv-00393-LMB-TCB Document 1416-2 Filed 08/19/22 Page 1 of 6 PagelD# 35731
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`EXHIBIT B
`EXHIBIT B
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`Case 1:20-cv-00393-LMB-TCB Document 1416-2 Filed 08/19/22 Page 2 of 6 PageID# 35732
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`Case Clip(s) Detailed Report
`Tuesday, June 07, 2022, 11:20:36 PM
`
`PMI v. RJR EDVa Trial
`
`Calderon, Kara (Vol. 01) - 11/12/2020
`1 CLIP (RUNNING 00:09:11.169)
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`Calderon,K_111220_ALL_TRIMMED2
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`28 SEGMENTS (RUNNING 00:09:11.169)
`KC-ALL-FINAL
`1. PAGE 9:05 TO 9:08 (RUNNING 00:00:13.794)
` 05 Q. Good morning, Ms. Calderon. Would you
` 06 please spell your full name for the record?
` 07 A. Kara, K-a-r-a. Calderon,
` 08 C-a-l-d-e-r-o-n.
`2. PAGE 9:13 TO 9:21 (RUNNING 00:00:23.559)
` 13 Q. Who's your current employer?
` 14 A. R.J. Reynolds Vapor Company.
` 15 Q. And what do you do at R.J. Reynolds
` 16 Vapor Company?
` 17 A. I am the senior director of our fit for
` 18 future for vapor and THP.
` 19 Q. What does "fit for future" mean?
` 20 A. I am in charge of strategy and pipeline
` 21 development.
`3. PAGE 14:13 TO 14:17 (RUNNING 00:00:13.646)
` 13 Q. My question is, Ms. Calderon, you
` 14 understand that you're testifying today both in
` 15 your personal capacity and as a corporate
` 16 representative on behalf of RJRV, right?
` 17 A. Yes, sir.
`4. PAGE 54:03 TO 54:06 (RUNNING 00:00:09.796)
` 03 Q. Okay. And based on your experience, we
` 04 discussed earlier, you're knowledgeable about how
` 05 RJRV markets the Vuse products; is that fair?
` 06 A. Yes, sir.
`5. PAGE 83:07 TO 83:10 (RUNNING 00:00:10.337)
` 07 Q. And so based on your experience,
` 08 consumers find it important to have a vaping
` 09 product that feels like the cigarettes that they
` 10 used to smoke before transitioning; is that right?
`6. PAGE 83:12 TO 83:19 (RUNNING 00:00:29.287)
` 12 A. Some consumers, right? Again, broad --
` 13 broad consumer base, what is good for you is
` 14 different for me, which is different from Mr. Vitt
` 15 is -- so for some consumers, a familiar experience
` 16 is an important factor for them. For other
` 17 consumers, they do not want a familiar experience.
` 18 They want something completely different. So it
` 19 really comes down to individual choice.
`7. PAGE 83:20 TO 84:05 (RUNNING 00:00:23.341)
` 20 Q. But at least for some consumers, a
` 21 familiar experience, in terms of the vaping device
` 22 feeling like a traditional combustible cigarette,
` 00084:01 is important to them; is that fair?
` 02 A. Based off of the research that -- that
` 03 I've gone through, for some consumers, a familiar
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`Case 1:20-cv-00393-LMB-TCB Document 1416-2 Filed 08/19/22 Page 3 of 6 PageID# 35733
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`Case Clip(s) Detailed Report
`Tuesday, June 07, 2022, 11:20:36 PM
`
`PMI v. RJR EDVa Trial
`
` 04 experience, a cigalike experience is -- is
` 05 something that they look for.
`8. PAGE 119:21 TO 120:09 (RUNNING 00:00:35.228)
` 21 clarification. Are you familiar with the concept
` 22 of -- of the e-liquid leaking from the cartridge
` 00120:01 at any time, whether it's during use or in your
` 02 purse?
` 03 A. Yeah. So, yeah, so there have been, you
` 04 know -- you know, throw my device in my -- in my
` 05 purse, and liquid comes out, right? Consumers
` 06 don't want that. I don't want that, right? So,
` 07 yeah, so leakage, in terms of it coming out, yeah,
` 08 that is -- that is something that we have heard
` 09 and we have seen with products.
`9. PAGE 166:06 TO 166:13 (RUNNING 00:00:26.035)
` 06 Q. Sure. When RJRV sells, for example, a
` 07 Solo power unit by itself, it expects to makes
` 08 additional sales of the cartridges for -- that are
` 09 used with that Solo power unit, right?
` 10 A. So to use the product, yes, you need
` 11 the -- you need the power unit and the cartridge.
` 12 So you need to buy both to -- to make the product
` 13 work in its intended form.
`10. PAGE 166:16 TO 167:06 (RUNNING 00:00:41.253)
` 16 Okay. And when RJRV sells a Solo power
` 17 unit, for example, the cartridge -- it expects the
` 18 consumer to purchase additional Solo cartridges
` 19 after the initial cartridge runs out, right?
` 20 A. Well, that would be -- that would be the
` 21 model, right? Is that you -- you buy your power
` 22 unit, and then what you need to continue using the
` 00167:01 power unit are the cartridges.
` 02 Q. Right. Have you heard -- that is the
` 03 model. Have you heard of that model referred to
` 04 as a razor/razor blade model?
` 05 A. Yup. Razor/razor blades. Yup. Power
` 06 units cartridges.
`11. PAGE 167:14 TO 167:18 (RUNNING 00:00:13.980)
` 14 So the RJRV, with respect to the sales
` 15 of the cartridges and power units, follows the
` 16 razor/razor blade model; is that fair?
` 17 A. That would be a fair representation of a
` 18 model.
`12. PAGE 193:21 TO 194:03 (RUNNING 00:00:09.871)
` 21 Q. So for the Solo, for at least part of
` 22 the time it's been on the market since 2013, you
` 00194:01 consider that product to have been a market
` 02 leader; is that right?
` 03 A. Yes.
`13. PAGE 200:08 TO 200:12 (RUNNING 00:00:12.778)
` 08 Q. Okay. And since it was released in the
` 09 market in August 2018, the Alto has been a
` 10 successful product for RJRV, right?
` 11 A. It -- we put a lot of emphasis on the
` 12 Alto product, yes.
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`Case 1:20-cv-00393-LMB-TCB Document 1416-2 Filed 08/19/22 Page 4 of 6 PageID# 35734
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`Case Clip(s) Detailed Report
`Tuesday, June 07, 2022, 11:20:36 PM
`
`PMI v. RJR EDVa Trial
`
`14. PAGE 200:20 TO 201:01 (RUNNING 00:00:09.029)
` 20 Q. And you said earlier, "We put a lot of
` 21 emphasis on the Alto product." Were you speaking
` 22 from a marketing perspective in that answer?
` 00201:01 A. Yes.
`15. PAGE 201:04 TO 201:10 (RUNNING 00:00:21.707)
` 04 Is the majority of the investment, from
` 05 a marketing perspective, put into the Alto as
` 06 compared to the other Vuse products at this time?
` 07 A. We would need to get those exact numbers
` 08 from -- from finance, but, yes, Alto is our -- our
` 09 premier product, and -- and that's what we
` 10 emphasize.
`16. PAGE 202:16 TO 202:22 (RUNNING 00:00:18.278)
` 16 Does RJR have any plans, that you're aware of, to
` 17 stop selling each of the Vuse products, meaning
` 18 the Ciro, Solo, Vibe, and Alto, in the United
` 19 States?
` 20 A. To stop selling them?
` 21 Q. Yes.
` 22 A. Not that I'm aware of.
`17. PAGE 259:16 TO 259:22 (RUNNING 00:00:20.902)
` 16 Q. And so Exhibit 11 is a printout of the
` 17 vapor overview from RJR Vapor's website, right?
` 18 A. It appears to be, yes, sir.
` 19 Q. Okay. And on the second page, it's --
` 20 RJRV is describing the Alto, Vibe, Ciro and Solo,
` 21 correct?
` 22 A. Yes, sir.
`18. PAGE 260:02 TO 260:13 (RUNNING 00:00:29.188)
` 02 sorry. For the Alto, RJRV is describing the Alto
` 03 as having an innovative ceramic wick and alloy
` 04 heating element.
` 05 Do you see that?
` 06 A. Yes, sir.
` 07 Q. Okay. So does that refresh your
` 08 recollection as to RJRV has, in fact, promoted the
` 09 innovative ceramic wick and alloy heating element
` 10 in the Alto, correct?
` 11 A. In terms of here, the innovative ceramic
` 12 wick and alloy heating element are being called
` 13 out for a Vuse Alto.
`19. PAGE 266:12 TO 266:18 (RUNNING 00:00:16.751)
` 12 Q. Okay. And you've seen Exhibit 13
` 13 before?
` 14 A. Yes, sir.
` 15 Q. What is Exhibit 13?
` 16 A. Exhibit 13 is a general market
` 17 assessment of a variety of different vapor
` 18 products.
`20. PAGE 268:08 TO 268:12 (RUNNING 00:00:10.790)
` 08 Q. So looking at the page ending in Bates
` 09 610, you see a reference TF16. What product is
` 10 that?
` 11 A. Yes. That is the product that is
` 12 currently known as Vuse Alto.
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`Case 1:20-cv-00393-LMB-TCB Document 1416-2 Filed 08/19/22 Page 5 of 6 PageID# 35735
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`Case Clip(s) Detailed Report
`Tuesday, June 07, 2022, 11:20:36 PM
`
`PMI v. RJR EDVa Trial
`
`21. PAGE 269:18 TO 270:01 (RUNNING 00:00:19.142)
` 18 Q. Okay. And one of the areas which this
` 19 study identified the Alto as outperforming other
` 20 products is that it has a quiet draw, right?
` 21 A. Quiet draw, no mess, no leaking,
` 22 mouth -- mouthpiece -- that should be feel -- and
` 00270:01 ease of use.
`22. PAGE 270:02 TO 270:07 (RUNNING 00:00:14.518)
` 02 Q. Right. And -- and the -- the second
` 03 area in which this study identified the Alto as
` 04 outperforming other products is that it has no
` 05 leaking, correct?
` 06 A. That is one of the areas that Alto
` 07 outperforms is leaking -- no leaking.
`23. PAGE 273:07 TO 273:10 (RUNNING 00:00:11.133)
` 07 Q. Okay. So the ability of the Alto to
` 08 prevent leaking was significantly higher than the
` 09 other competitive products in this study. Is that
` 10 what column is saying?
`24. PAGE 273:12 TO 273:12 (RUNNING 00:00:00.562)
` 12 A. That is.
`25. PAGE 277:17 TO 278:12 (RUNNING 00:01:03.034)
` 17 Q. Right. And below the box we were just
` 18 looking at, the fact that the battery was easy to
` 19 charge and stayed charged for a long time was a
` 20 feature in the Alto that was identified as what
` 21 users liked most about the Alto, correct?
` 22 A. Yes. Battery easy to charge and stay
` 00278:01 charged for a long time.
` 02 Q. And then in the box above that to the
` 03 right, another feature identified as what users
` 04 like about the Alto, at least in this study, is
` 05 the "Small size and oval shape made it easy and
` 06 comfortable to fit in my pocket"; is that right?
` 07 A. Yes, sir. That's what it says.
` 08 Q. And are all three of those benefits,
` 09 based on your experience, of the Alto to users?
` 10 A. Those are three of the benefits to Alto,
` 11 not leaking, battery life, and consistency, shape,
` 12 size, comfortable, easy to use.
`26. PAGE 279:03 TO 279:07 (RUNNING 00:00:21.474)
` 03 Q. What -- what is Exhibit 14?
` 04 A. Exhibit 14 looks like a working document
` 05 of some evaluation of when Alto was coming into
` 06 market and reassessing the brand and the marketing
` 07 around Vuse Alto.
`27. PAGE 279:08 TO 279:11 (RUNNING 00:00:08.017)
` 08 Q. Okay. And you say it's a working
` 09 document. Are you indicating that this is a draft
` 10 and not a final version?
` 11 A. Yes.
`28. PAGE 290:08 TO 290:14 (RUNNING 00:00:23.739)
` 08 Q. In the first bullet point here on RJRV
` 09 is identifying -- is saying that they want to
` 10 elevate the importance of the FEELM heater
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`Case 1:20-cv-00393-LMB-TCB Document 1416-2 Filed 08/19/22 Page 6 of 6 PageID# 35736
`
`Case Clip(s) Detailed Report
`Tuesday, June 07, 2022, 11:20:36 PM
`
`PMI v. RJR EDVa Trial
`
` 11 technology as critical reason to believe for the
` 12 Alto as being the highest performance vape yet,
` 13 correct?
` 14 A. That's what this document says.
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