`Case 1:17-cv-00770-JDW Document 250-28 Filed 10/25/23 Page 1 of 4 PagelD #: 25897
`
`EXHIBIT 28
`EXHIBIT 28
`
`
`
`Case 1:17-cv-00770-JDW Document 250-28 Filed 10/25/23 Page 2 of 4 PageID #: 25898
`
`3/8/2023
`
`Wirtgen America Inc. v. Caterpillar Inc.
`Highly Confidential - Outside Attorneys' Eyes Only
`
`Nathan Just
`
`Page 1
`
` UNITED STATES DISTRICT COURT FOR THE
` DISTRICT OF DELAWARE
`________________________________
`WIRTGEN AMERICA, INC., )
` )
` Plaintiff, )
` )
`v. ) No.
` ) 1:17-cv-00770-JDW-MPT
`CATERPILLAR, INC., )
` )
` Defendant. )
`________________________________)
`
` HIGHLY CONFIDENTIAL - OUTSIDE ATTORNEYS' EYES ONLY
` Video Deposition of
` NATHAN JUST
` in his personal capacity,
` and as a representative of CATERPILLAR, INC.
`
` Wednesday, March 8, 2023
` 9:01 a.m.
`
` Court Reporter:
` Staci Heichert, RDR, CRR, CRC
`______________________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
` (202) 232-0646
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2023
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 250-28 Filed 10/25/23 Page 3 of 4 PageID #: 25899
`
`3/8/2023
`
`Wirtgen America Inc. v. Caterpillar Inc.
`Highly Confidential - Outside Attorneys' Eyes Only
`
`Nathan Just
`
`Page 30
`unit, Cat unit sales forecasts by model, but our estimate of
`market shares is, we're not able to get to that level.
` Q. Okay. When did the PM600 or PM6XX series launch
`on the U.S. market?
` A. I believe we started shipping machines -- by
`"launch," if you mean shipping machines to customers, to
`dealers, I believe it was in 2016 or very end of 2015.
`2016, I believe.
` Q. When did the PM800 or PM8XX series launch?
` A. 2017, I believe.
` Q. And when did the PM300 or PM3XX series launch?
` A. I believe 2018. All of those dates, I'm sure we
`could find in gateway review, but that's from the top of my
`head.
` Q. I believe you also mentioned that part of your
`responsibilities as marketing manager is to work with
`engineering to set requirements for machines?
` A. Yes.
` Q. Is that right? Do you remember any particular
`requirements that you worked with engineering on for the
`PM600 series?
` A. So, again, most of my input, just to be clear, my
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2023
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 250-28 Filed 10/25/23 Page 4 of 4 PageID #: 25900
`
`3/8/2023
`
`Wirtgen America Inc. v. Caterpillar Inc.
`Highly Confidential - Outside Attorneys' Eyes Only
`
`Nathan Just
`
`Page 135
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`STATE OF MINNESOTA )
` )ss.
`COUNTY OF SCOTT )
` Be it known that I took the foregoing hearing on
`the 8th day of March, 2023;
` That I was then and there a notary public in and
`for the County of Scott, State of Minnesota, and that by
`virtue thereof, I was duly authorized to administer an oath;
` That the witness was by me first duly sworn to
`testify to the truth, the whole truth and nothing but the
`truth relative to said cause;
` That the foregoing transcript is a true and correct
`transcript of my stenographic notes in said matter;
` That I am not related to any of the parties hereto,
`nor interested in the outcome of the action;
` WITNESS MY HAND AND SEAL this 13th day of March,
`2023.
`
`____________________________________
`Staci A. Heichert, RDR, CRR, CRC
`My Commission Expires January 31, 2028.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2023
`
`202-232-0646
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
