(Grieco Decl. Ex. V.) In phase one, Mark Ramun’s initial title would be “Special Projects Director,” and his responsibilities would include: (1) input into the launch of and design of a new product line, and (2) direct sales to customers and distributors.
PageID #: 844 planning, financial controls, production, traffic, legal, international, human resources, marketing, etc.” (Grieco Decl. Ex. V.) Moreover, Bacon’s proposal offered, and Mark Ramun’s Employment Agreement ultimately secured, extraordinary incentives.
The party seeking summary judgment bears the initial burden of informing the district court of the basis for its motion, and identifying the evidence which it believes demonstrates “the absence of a genuine issue of material fact.” Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986); Kochins v. Linden-Alimak, Inc., 799 F.2d 1128, 1133 (6th Cir. 1986).
Damages Defendants urge the Court to dismiss Allied’s trade secret claim because it is entirely speculative and based upon a flawed assumption—i.e., that, but for the misappropriation, Allied would have captured each and every Genesis sale (of the LXP or VersiPro) through March 2008.
Co., 517 F.3d 816, 837 (6th Cir. 2007); see also Bauman v. Volkswagen Aktiengesellschaft, 621 F.2d 230, 235 (6th Cir. 1980) (“Where the evidence is sufficient to establish liability and causation, we do not believe we should remove the case from the jury because the precise extent of the injuries caused by the defendant's wrong is uncertain.