ESTTA Tracking number: ESTTA1112734 02/06/2021

Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov

ESTTA Tracking number: ESTTA1112734

Filing date: 02/06/2021

IN THE UNITED STATES PATENT AND TRADEMARK OFFICEBEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

Proceeding 91236453

Party DefendantWalgreen Co.

CorrespondenceAddress

TAMARA A MILLERLEYDIG VOIT & MAYER LTDTWO PRUDENTIAL PLAZA SUITE 4900, 180 N STETSON AVECHICAGO, IL 60601-6731UNITED STATESPrimary Email: [email protected] Email(s): [email protected], [email protected], [email protected], [email protected]

Submission Testimony For Defendant

Filer's Name Tamara A. Miller

Filer's email [email protected], [email protected]

Signature /Tamara A. Miller/

Date 02/06/2021

Attachments Notice of Filing Testimony - Crystal Fouchard - PUBLIC redacted.pdf(1420165bytes )CrystalFouchard Exhibits PUBLIC.pdf(4282707 bytes )

http://estta.uspto.gov

1

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

SPECIALTY PHARMACY MANAGEMENT, LLC, )

)

Opposer, ) Opposition No.: 91236453

) Serial No. 87/353,224

v. )

)

WALGREEN CO., )

)

Applicant. )

APPLICANT’S NOTICE OF FILING TESTIMONY

OF CRYSTAL FOUCHARD (REDACTED)

In accordance with TBMP § 703.01 and 37 CFR § 2.125(a), Applicant Walgreen Co.

(“Walgreens”) hereby notes its filing of the testimony deposition of Crystal Fouchard with

corresponding exhibits. Pursuant to the Protective Order in place and 37 CFR § 2.126(c),

portions of the testimony transcript and some exhibits are deemed Confidential, Highly

Confidential, or Trade Secret / Commercially Sensitive. Thus, they have been redacted and shall

be submitted under separate cover and identified as “CONFIDENTIAL” via the ESTTA system.

Respectfully submitted,

Date: February 6, 2021 /Tamara A. Miller/

Tamara A. Miller

Laura M. Schaefer

LEYDIG, VOIT & MAYER, LTD.

Two Prudential Plaza, Suite 4900

180 N. Stetson Ave.

Chicago, Illinois 60601-6731

(312) 616-5600

[email protected]

[email protected]

Attorneys for Applicant

2

CERTIFICATE OF SERVICE

I hereby certify that on February 6, 2021 a copy of this APPLICANT’S NOTICE OF

FILING TESTIMONY OF CRYSTAL FOUCHARD (REDACTED), the testimony deposition

transcript, the signature page and errata sheet, and accompanying exhibits were served on

counsel for Opposer via email, by agreement, to:

Ellen S. Simpson

Simpson & Simpson PLLC

5555 Main Street

Williamsville, NY 14221

United States

[email protected]

[email protected]

/Laura M. Schaefer/

Applicant notes that the testimony transcript of Crystal Fouchard and corresponding

exhibits were previously served on Opposer’s counsel pursuant to TBMP § 703.01(m) on

February 6, 2020. Further, pursuant to the Protective Order, the signature page, errata sheet, and

confidentiality designations were served on Opposer’s counsel on March 9, 2020.

CRYSTAL FOUCHARD

1 THE UNITED STATES PATENT AND TRADEMARK OFFICE

2 BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

3 SPECIALTY PHARMACY

4 MANAGEMENT, Opposition No

5 Opposer, 91236453

6 vs. Serial No.

7 WALGREEN CO., 87/353,224

8 Applicant

9 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

10

11

12 TESTIMONY OF

13 CRYSTAL FOUCHARD

14

15

16 January 10, 2020

17 9:38 a.m.

18

19 180 North Stetson Avenue, Suite 4900

20 Chicago, Illinois

21

22 Stenographically Reported By:

23 Deanna Amore - CRR, RPR, CSR - 084-003999

24

25

Page 1

Veritext Legal Solutionswww.veritext.com 888-391-3376

CRYSTAL FOUCHARD

1 APPEARANCES OF COUNSEL

2

On Behalf of the Opposer, SPECIALTY PHARMACY

3 MANAGEMENT:

4 SIMPSON & SIMPSON

MS. ELLEN SWARTZ SIMPSON

5 5555 Main Street

Williamsville, New York 14221-5430

6 (716) 626-1564

[email protected]

7 - and -

LAW OFFICES OF LARRY KERMAN

8 MR. LARRY KERMAN

2645 Sheridan Drive

9 Tonawanda, New York 14150

(716) 834-9445

10 [email protected]

11 On Behalf of the Applicant, WALGREEN CO.:

12 LEYDIG, VOIT & MAYER, LTD.

MS. TAMARA A. MILLER

13 MS. LAURA M. SCHAEFER

Two Prudential Plaza

14 180 North Stetson Avenue

Suite 4900

15 Chicago, Illinois 60601-6731

(312) 616-5600

16 [email protected]

[email protected]

17

18

19 * * * * *

20

21

22

23

24

25

Page 2


CRYSTAL FOUCHARD

1 I N D E X

2 WITNESS EXAMINATION

3 CRYSTAL FOUCHARD

4 EXAMINATION BY MS. MILLER 6

5 CROSS-EXAMINATION BY MR. KERMAN 85

6 REDIRECT EXAMINATION BY MS. MILLER 185

7 RECROSS-EXAMINATION BY MR. KERMAN 186

8 RE-REDIRECT BY MS. MILLER 189

9 EXHIBITS

10 Applicant's Notice of Deposition 15

11 Trial Testimony for Crystal

12 Exhibit 66 Fouchard

13 Applicant's Walgreens FY18 Provider 16

14 Trial Media Plan; W000927-938

15 Exhibit 67

16 Applicant's Corsearch Search Report 31

17 Trial Alliance Rx; W001828-2214

18 Exhibit 68

19 Applicant's Marketing Channel 36

20 Trial Financial Spend

21 Exhibit 69 FY14-FY18; W003012

22 Applicant's A snapshot of the print 60

23 Trial roto program; W003064

24 Exhibit 70

25

Page 3


CRYSTAL FOUCHARD

1 EXHIBITS

2 NUMBER DESCRIPTION PAGE

3 Applicant's 7-8-2018-7-14-2018 64

4 Trial Walgreens Circular;

5 Exhibit 71 W002307

6 Applicant's LinkedIn Walgreens 66

7 Trial Printout

8 Exhibit 72

9 Applicant's YouTube Walgreens 67

10 Trial Printout

11 Exhibit 73

12 Applicant's Walgreens Pinterest Page 68

13 Trial

14 Exhibit 74

15 Applicant's Walgreens Instagram 0

16 Trial

17 Exhibit 75

18 Applicant's Walgreens Facebook Page 71

19 Trial Exhibit

20 76

21 Applicant's walgreens.com Printout 72

22 Trial

23 Exhibit 77

24

25

Page 4


CRYSTAL FOUCHARD

1 EXHIBITS

2 NUMBER DESCRIPTION PAGE

3 Applicant's 5.16.2018 Email Re: 75

4 Trial Awareness Numbers;

5 Exhibit 78 W002762

6 Applicant's 6.15.2018 Walgreens FY17 77

7 Trial Brand Tracking Q're

8 Exhibit 79 Outline; W003277-3299

9 EXHIBITS PREVIOUSLY MARKED PAGE FIRST REFERRED TO

10 Applicant's Trial Exhibit 20 117

11 Applicant's Trial Exhibit 21 27

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 5


CRYSTAL FOUCHARD

1 (Whereupon, the witness was

2 duly sworn.)

3 MS. MILLER: Tamara Miller, on behalf of the

4 Applicant, Walgreen Co.

5 MS. SCHAEFER: Laura Schaefer, on behalf of the

6 Applicant, Walgreen Co.

7 MR. KERMAN: Larry Kerman, on behalf of

8 Opposer, Specialty Pharmacy Management, LLC.

9 MS. SIMPSON: Ellen Simpson, am on behalf of

10 Opposer, Specialty Pharmacy Management, doing

11 business as Reliance Rx.

12 CRYSTAL FOUCHARD,

13 called as a witness herein, having been first duly

14 sworn, was examined and testified as follows:

15 EXAMINATION

16 BY MS. MILLER:

17 Q. Good morning, Ms. Fouchard. Thank you for

18 being with us today. Let's start with some

19 questions about your education.

20 Did you go to college?

21 A. I did.

22 Q. Where did you go?

23 A. I went to undergrad at the University of

24 Michigan.

25 Q. Did you receive a degree?

Page 6


CRYSTAL FOUCHARD

1 A. I did.

2 Q. What was the degree?

3 A. Got my bachelor of business

4 administration.

5 Q. What year did you receive that degree?

6 A. 1991.

7 Q. And past your bachelor's degree, did you

8 seek any more education?

9 A. I did.

10 Q. What was that?

11 A. I got my MBA from Duke University, the

12 Fuqua School of Business.

13 Q. When was that?

14 A. 1999.

15 Q. And after college or your MBA, did you

16 have any -- what was your first job?

17 A. After undergrad, my first job was with

18 Kraft.

19 Q. What did you do for Kraft?

20 A. I was in marketing research.

21 Q. And what were your duties in that role?

22 A. I was focused on the natural cheese

23 business and was working with the brand marketing

24 team on consumer research related to either custom

25 research needs or syndicated research.

Page 7


CRYSTAL FOUCHARD

1 Q. And when did you get that job?

2 A. 1991.

3 Q. And how long did you have that job?

4 A. Until 1993.

5 Q. After leaving Kraft, did you have any

6 other jobs that were marketing related?

7 A. Yes. After my MBA I went to work at

8 McNeil Consumer Products, which is part of

9 Johnson & Johnson.

10 Q. And what was your title there?

11 A. I began as an associate marketing manager.

12 Q. And approximately what year was that?

13 A. 1999.

14 Q. And you said associate marketing manager?

15 A. Yes.

16 Q. And in that role, what were your

17 responsibilities?

18 A. In that role I was working on the Tylenol

19 brand, was working with, actually, retail partners,

20 including Walgreens, on how the brand would show up

21 in store, things like displays and signage.

22 Q. And how long did you have that position?

23 A. That particular position was probably two

24 years.

25 Q. And what did you do after that?

Page 8


CRYSTAL FOUCHARD

1 A. I became a marketing manager and,

2 ultimately, a group product director.

3 Q. Okay. So you started there in 1999?

4 A. Yes.

5 Q. So approximately what year did you become

6 a marketing manager?

7 A. I would say approximately 2001.


9 A. I worked on various brands. I worked on

10 the Pepcid brand and then also began working on the

11 Children's Tylenol and Children's Motrin brands,

12 various responsibilities, depending on the brand

13 and the business need at the time, developing

14 advertising, different types of print or TV

15 advertising, new product development, working with

16 the R&D folks on different types of new products,

17 Children's Tylenol Meltaways, as an example.

18 Q. How long were you a marketing manager?

19 2001 until when approximately?

20 A. 2005 maybe.

21 Q. And what did you do next?

22 A. Then I became a group product director.

23 Again, different responsibilities. Working on some

24 enterprise initiatives like SKU rationalization,

25 trying to maximize our assortment to generate the

Page 9


CRYSTAL FOUCHARD

1 greatest number of sales at the most efficient

2 SKUs -- with the most efficient number of SKUs.

3 Worked on an acquisition of Pfizer consumer

4 products where we acquired brands like Zyrtec.

5 Q. And did you have any marketing-related

6 responsibilities as the group products director?

7 A. Yeah. All of those were within the scope

8 of marketing as it was defined within McNeil.

9 Q. And how long were you a group products

10 director?

11 A. Until 2008.

12 Q. And then what did you do?

13 A. Then I took a place and was not working

14 for a couple of years until I began with Walgreens.

15 Q. When did you start with Walgreens?

16 A. December 28, 2010.

17 Q. And when you started with Walgreens, what

18 was your title?

19 A. Marketing director.


21 A. In that role I was focused on supporting

22 our retail health and wellness business, which are

23 categories like pain, cough/cold, vitamins. Again,

24 various marketing-related initiatives, anything in

25 terms of consumer communication, which runs the

Page 10


break

CRYSTAL FOUCHARD

1 gamut from in-store signage to print ads to radio

2 ads, TV ads.

3 Q. And are you still a marketing director at

4 Walgreens?

5 A. I am not. I'm a senior director.

6 Q. Okay. So after you became a marketing

7 director, did you become a senior director next?

8 A. Yes.

9 Q. And when was that?

10 A. It was about two and a half years ago, I'd

11 say.

12 Q. And what are you the senior director of?

13 A. Right now my focus is on our pharmacy and

14 health businesses. So that includes immunizations;

15 chronic conditions, including specialty pharmacy

16 conditions that we support direct to consumer; HIV;

17 and oncology; also pain; diabetes; our adherence

18 efforts to try and help our patients stay adherent

19 to their medication; and most recently, it includes

20 responsibility for Med D and market access consumer

21 marketing.

22 Q. You mentioned specialty pharmacy that's

23 offered direct to consumers. Can you explain what

24 you mean by that?

25 A. Sure.

Page 11


CRYSTAL FOUCHARD

1 My portion of the marketing organization

2 is focused on direct-to-consumer marketing, and

3 there are certain businesses and conditions that we

4 talk about as specialty pharmacy that we support

5 direct to consumers. So we would -- and those

6 include, specifically for my team, oncology and

7 HIV. So we develop marketing campaigns and tactics

8 to support those businesses on HIV. For example,

9 we have National HIV Testing Day and a partnership

10 with Kaiser Family Foundation where we offer free

11 HIV testing in our stores. That's just one

12 example. We also do print advertising and other

13 types of marketing.

14 For oncology, we have a myriad of efforts.

15 We launched a new program called "Feel More Like

16 You," which is a service offered in our stores

17 where pharmacists and consultants have been

18 specially trained to help cancer patients with the

19 side effects of their treatment. So we help

20 consumers become aware of that service and

21 encourage them to take advantage of it.

22 Those are just examples.

23 Q. And specialty pharmaceuticals that you

24 offer direct to consumer, how would a consumer go

25 about obtaining those drugs?

Page 12


CRYSTAL FOUCHARD

1 A. Sure.

2 There are multiple ways.

3 So we have specialty at retail, so where

4 those pharmaceuticals, in some case, are available

5 in our retail stores.

6 We also have what we call our local

7 community pharmacies, which may be a stand-alone

8 pharmacy, or it may be a pharmacy on-site at a

9 hospital or a health system where they offer

10 specialized services specifically for specialty

11 pharmacy patients.

12 Those prescriptions could also be

13 available via mail.

Page 13


CRYSTAL FOUCHARD

8 Q. Have you heard of AllianceRx

9 Walgreens Prime?

10 A. I have.

11 Q. What is that?

12 A. AllianceRx Walgreens Prime is a joint

13 venture between Walgreens and Prime -- it's now a

14 new company -- to support specialty pharmacy.

15 Q. And how, if you know, is AllianceRx

16 Walgreens Prime different than the specialty

17 pharmacy that you offer direct to consumers?

Page 14


CRYSTAL FOUCHARD

23 (Whereupon, Applicant's Trial

24 Exhibit 66 was marked for

25 identification.)

Page 15


CRYSTAL FOUCHARD

1 BY MS. MILLER:

2 Q. The court reporter has handed you what's

3 been marked Applicant's Trial Exhibit 66.

4 Do you have an understanding of what this

5 document is?

6 A. I see it's a notice of testimony

7 deposition.

8 Q. And do you understand you are here today

9 to testify on behalf of Walgreen Co. in the matter

10 shown at the top?

11 A. Yes.



14 identification.)

15 BY MS. MILLER:


17 been marked Applicant's Trial Exhibit 67, entitled

18 "FY18 Provider Media Plan."

19 Do you see that?

20 A. I do.

21 Q. There is a name under the title, Rick

22 Serlin. Do you know who Rick Serlin is?

23 A. I do.

24 He's part of our provider marketing team.

25 Q. When you say "our," do you mean Walgreens?

Page 16


CRYSTAL FOUCHARD

1 A. Walgreens, yes.

2 Q. And do you know whether Rick helped

3 support the AllianceRx Walgreens Prime brand?

4 A. Yes, he does.

5 Q. And are you familiar with this type of

6 document?

7 A. I am familiar with this type of document,

8 yes.

9 Q. And what is this type of document in your

10 business?

11 A. So we put together a marketing plan. So

12 this type of document would be representative of

13 any key inputs that would be relevant for

14 developing a plan and then give examples of

15 different types of channels that are going to be

16 used and the marketing support of the initiative.

17 Q. And does the marketing team at Walgreens

18 regularly put together these types of media plans?

19 A. Yes. We do that in partnership with our

20 media agency, but this is a type of document that

21 we would do in conjunction with our agency partners

22 generally.

Page 17


CRYSTAL FOUCHARD

Page 18


CRYSTAL FOUCHARD

Page 19


CRYSTAL FOUCHARD

Page 20


CRYSTAL FOUCHARD

Page 21


CRYSTAL FOUCHARD

Page 22


CRYSTAL FOUCHARD

Page 23


CRYSTAL FOUCHARD

Page 24


CRYSTAL FOUCHARD

Page 25


CRYSTAL FOUCHARD

24 Q. Ms. Fouchard, were you involved in the

25 selection of AllianceRx Walgreens Prime as the

Page 26


CRYSTAL FOUCHARD

1 trademark?

2 A. Yes.

3 Q. And what was your involvement?

4 A. I was asked to help kind of facilitate

5 internally within Walgreens and also working with

6 Prime on the review and recommendation of the

7 trademark.

8 Q. Do you recall about when in time you

9 became involved?

10 A. I became involved towards the end of

11 October.

12 Q. Of what year?

13 A. Oh, 2016.

14 Q. Okay. Can you -- you have two stacks of

15 exhibits in front of you. The one on the left is

16 the applicant's exhibits. Can you find Exhibit 21

17 in that stack?

18 MR. KERMAN: Give me a chance to find it too,

19 please. Thanks.

20 Okay. Thank you for waiting.

21 BY MS. MILLER:

22 Q. Have you seen this document before?

23 A. I have.

24 Q. What is this document?

25 A. It's an email.

Page 27


CRYSTAL FOUCHARD

1 Q. And looking at the top, were you a

2 recipient of the email at the top here?

3 A. I was.

4 Q. And what was this email about?

5 A. This was about the naming for the

6 Walgreens Prime joint venture.

7 Q. And who sent you the email?

8 A. David Barber.

9 Q. Who is David Barber?

10 A. He was my manager at the time.

11 Q. Did he also work in marketing?

12 A. He did.

13 Q. Why did David send you this email string

14 below?

15 MR. KERMAN: Object to the form.

16 THE WITNESS: James, Jim -- I call him

17 Jim -- Oconor forwarded the or sent this email to

18 David and others looking for a resource to help

19 lead the effort to gain resolution on the name for

20 Walgreens Prime joint venture. David sent it to me

21 at that time without any context, but subsequently,

22 based on our conversation, that person to help lead

23 and facilitate was me.

24 Q. And who are the people -- well, did you

25 work with -- you said "facilitate." Did you

Page 28


CRYSTAL FOUCHARD

1 facilitate a process or other people?


3 THE WITNESS: Yes. As I said, I worked

4 internally within Walgreens and then also with

5 Cameron Olig on the Prime side to consider

6 different name options and put forth a

7 recommendation.

8 BY MS. MILLER:

9 Q. And do you know, when you became involved

10 with the selection of the mark "AllianceRx

11 Walgreens Prime" whether at that point -- do you

12 have an understanding of where in the selection

13 process people were before you became involved?

14 A. I had visibility to other names that had

15 been considered. There was a document from one of

16 Prime's agencies, Martin Williams, that reflected

17 different names within that document.

18 When I became involved, there was momentum

19 towards AllianceRx and Walgreens.

Page 29


CRYSTAL FOUCHARD

Page 30


CRYSTAL FOUCHARD



7 identification.)

8 BY MS. MILLER:

Page 31


CRYSTAL FOUCHARD

Page 32


CRYSTAL FOUCHARD

10 BY MS. MILLER:

11 Q. And at some point after the legal review

12 happened, was a final decision made as to what mark

13 to go with?

14 A. Yes.

15 Q. What was that?

16 A. Initially, it was "AllianceRx Walgreens +

17 Prime."

18 Q. You said "initially." Why did you start

19 your answer with initially?

20 A. We subsequently modified to remove the

21 plus sign and the mark was AllianceRx

22 Walgreens Prime.

23 Q. Do you know why the plus sign was removed?

24 A. We were still doing different

25 considerations and reviews internally and with

Page 33


CRYSTAL FOUCHARD

1 Prime during the course of the trademark search and

2 subsequent to that. So it was a call made to -- to

3 remove the plus sign for simplicity.

4 Q. Do you know why AllianceRx Walgreens Prime

5 was ultimately selected as the mark?

6 A. There were a number of factors.

7 So wanting to include both Walgreens and

8 Prime, given the equity that both of those marks

9 and brands bring to the different stakeholders that

10 are involved in this new company.

11 AllianceRx was related to -- one

12 consideration was that we -- Walgreens' parent

13 company is Walgreens Boots Alliance. So having the

14 word "Alliance" as part of our parent company

15 connects to that.

16 Also, the reference of Alliance -- or

17 Walgreens with Alliance, strategic partnerships are

18 very important. Alliance represents that idea of

19 partnership and also represents the idea of the

20 partnership with Walgreens and Prime.

21 Q. Do you know how long the mark "Walgreens"

22 has been in use?

23 A. Since 1901.

24 Q. And what has the mark "Walgreens" been

25 used for since 1901?

Page 34


CRYSTAL FOUCHARD

1 A. It's on our physical store assets. So

2 it's on the exterior of our stores, on other

3 exterior assets we have, reader boards, what we

4 call monument signs. It's on the interior of our

5 stores and different assets like signage, our

6 circular, our savings book. It's on walgreens.com.

7 It's within our mobile app.

8 It's used on our marketing materials,

9 direct-to-consumer marketing, provider marketing,

10 payor marketing. So that could be examples all the

11 way from print ads to digital to TV, radio,

12 et cetera.

13 Q. And, generally speaking, what goods or

14 services does Walgreens offer under the Walgreens

15 mark?

16 A. We have our pharmacy services, including

17 prescriptions, information, advice. We have all of

18 our retail products in health and wellness

19 categories. As I mentioned, like pain, cough,

20 cold, vitamins; within beauty, personal care, so

21 cosmetics, shampoo; within consumables, nuts,

22 candy.

23 The mark itself is on our health and

24 wellness products. So we have products within the

25 store and sold online that are Walgreens-branded

Page 35


CRYSTAL FOUCHARD

1 products.

2 We have photo services. They are also

3 under Walgreens.

4 Q. What would be included in health and

5 wellness products?

6 A. It's a big range. So I mentioned, like,

7 pain, cough, cold, vitamins. We have like GI,

8 gastrointestinal, things like heartburn relief. We

9 have testing supplies. We have things like blood

10 pressure monitors, glucose monitors. We have

11 within -- some types of oral clear. We have all

12 sorts of categories there.



15 identification.)

16 BY MS. MILLER:

Page 36


CRYSTAL FOUCHARD

Page 37


CRYSTAL FOUCHARD

Page 38


CRYSTAL FOUCHARD

4 Q. Looking at the top row, under "Marketing

5 Channel," the first item is "Roto/IVC." Can you

6 tell us what that means, if you know?

7 A. Roto, or we sometimes also say our

8 circular, is the weekly printed and also online

9 version of all of the offers that we have within

10 our stores. Actually, not all of the offers but

11 the highlight of the offers that we have within our

12 stores. IVC, I don't know what the initials stand

13 for. We also refer to that as our savings book.

14 That's what it says on the cover. So that's also

15 available in our store. It's a printed book that

16 has coupons. That's usually a monthly document.

17 Q. What are the ways in which someone could

18 obtain a roto?

19 A. A roto, our weekly circular, is available

20 in newspapers. It's also available in our stores.

21 You can access it on walgreens.com. You can also

22 access it on our Walgreens app.

23 Q. And do you know how many stores the roto

24 is sent to each week?

25 A. The roto shows up in almost all of our

Page 39


CRYSTAL FOUCHARD

1 stores each week.

2 Q. And how many is that?

3 A. Almost 9,000.

4 Q. And the next item, "Online Display

5 (Digital & Programming)," can you tell us what that

6 is?

7 A. Online displays are -- those are generally

8 banner ads.

9 Programming, that's a particular type of

10 activation within digital displays, but they are

11 basically banner ads.

12 Q. And then skipping down to "Agency Fees,"

13 what is meant by that?

14 A. "Agency Fees," so those are fees that we

15 pay to third parties -- for example, I mentioned

16 WPP earlier -- to help us with the, for example,

17 development of creative or putting the circular

18 together, those types of things.

19 Q. And the next one, "Paid Search," what does

20 that mean?

21 A. "Paid Search." So that is if you are on

22 Google or Bing or other search engines and are

23 searching for something, we put dollars behind

24 making sure that Walgreens shows up in relevant

25 searches. So that would be an example of "Paid

Page 40


Programmatic

CRYSTAL FOUCHARD

1 Search."

2 Q. And "Signage," what would be meant by

3 that?

4 A. "Signage," we usually use that to refer to

5 in-store signage. So that could be front door

6 poster. We have posters in our pharmacy waiting

7 room. Sometimes we have counter mats on the front

8 of store pharmacy counter, so those types of

9 signage.

10 Q. And would the signage bear the mark

11 "Walgreens"?

12 A. Yes.

13 Q. "Online Video," what would that mean?

14 A. "Online Video," basically what it's

15 representing. So a video that shows up on

16 something like YouTube. So, for example, if you

17 are looking for a video on YouTube, oftentimes you

18 have to watch a six-second ad before that video.

19 That would be an example of an online video where

20 we pay to have our marketing message included.

21 Q. Would the mark "Walgreens" be included?

22 A. Yes.

23 Q. Okay. And going back to the roto and IVCs

24 at the top, is the mark "Walgreens" on those

25 materials?

Page 41


CRYSTAL FOUCHARD

1 A. It is.

2 Q. And the online displays that you

3 mentioned, would the mark "Walgreens" appear in

4 those?

5 A. Yes, it would generally appear in those.

6 Q. And would the mark "Walgreens" appear in

7 any TV or radio that you do?

8 A. Yes.

9 Q. And after online videos, the next one is

10 "Production." What would that include?

11 A. "Production" is the cost to develop a TV

12 spot or a print ad or a digital ad, you know, to

13 develop the marketing materials for these channels.

14 Q. And "Ad Tags," what are those?

15 A. "Ad Tags" are what you see at shelf

16 associated with a specific product, so generally

17 used to highlight that that product is on sale. So

18 you'll see the ad tag kind of being applied right

19 below the product at the shelf.

20 Q. Is the mark "Walgreens" on ad tags?

21 A. I am not sure.

22 Q. And direct mail, what would be included?

23 A. Direct mail is when we send out -- it

24 could be a letter. It could be a postcard.

25 Basically, something that goes through the mail

Page 42


CRYSTAL FOUCHARD

1 direct to a customer or a patient with a message

2 from Walgreens.

3 Q. And would the name "Walgreens" be on it?

4 A. Yes.

5 Q. And what is "Paid Social"?

6 A. "Paid Social" is representing different

7 types of social channels, like Facebook, Instagram,

8 Twitter, Pinterest. So different types of social

9 channels where we would pay to have a placement, so

10 to show up in a relevant audience's news or feed on

11 Facebook, for example.

12 Q. And would the mark "Walgreens" be included

13 in such ads?

14 A. Yes.

15 Q. And "Magazine," I think we all know what

16 magazines are.

17 Would Walgreens include the mark

18 "Walgreens" in any magazine ad it might do?

19 A. Yes.

20 Q. And what does "Affiliates" mean?

21 A. "Affiliates" are third parties, like

22 RetailMeNot. Like they are different third parties

23 who are like accumulators of -- maybe it's coupons

24 or in some cases they offer, like, points to people

25 who use them. But, basically, it's having

Page 43


CRYSTAL FOUCHARD

1 Walgreens show up in those third-party accumulator

2 searches. Like if somebody is using RetailMeNot,

3 having Walgreens show up as part of an option

4 within that.

5 Q. Does Walgreens use the name "Walgreens" on

6 its coupons?

7 A. On its coupons, like, within that example?

8 Q. Yes.

9 A. Yes.

10 Q. "Mobile Display"?

11 A. "Mobile Display" is having a marketing

12 communication, advertisement, show up on your

13 mobile phone.

14 Q. And would the mark "Walgreens" be used in

15 such mobile displays?

16 A. Generally, sometimes we use the corner W

17 because mobile ads are really, really tiny but...

18 Q. And what is "One Times Square"?

19 A. One Times Square is a billboard that we

20 have in Times Square in New York.

21 Q. Is the mark "Walgreens" on it, if you

22 know?

23 A. We place advertisements on it. Like, for

24 example, a video and the mark "Walgreens" would be

25 on -- would be on those advertisements. We also

Page 44


CRYSTAL FOUCHARD

1 have a store in that building.

2 Q. In Times Square?

3 A. Yes.

4 Q. And what is "Partnerships/Cause

5 Marketing"?

6 A. That is a bucket that includes things like

7 our Red Nose Day partnership, which is a

8 partnership with the charity that Walgreens is a

9 part of. So Red Nose Day, ME to WE. We also have

10 partnerships with non-profit organizations, Home

11 and Family Foundation, as I mentioned earlier;

12 Kaiser Family Foundation; Susan G. Komen. So these

13 are different partnerships that we are working with

14 a third party to market together.

15 Q. What is Red Nose Day?

16 A. Red Nose Day is an event in partnership

17 with Comic Relief and also NBC. So there is a

18 one-day event that's a fundraiser event, but then

19 there is, you know, weeks' long efforts through

20 NBC.

21 There will be different integrations on

22 different NBC properties like Kelly Clarkson. Then

23 we also carry red noses in store. It's a

24 fundraiser. So if you buy a red nose, then a

25 donation is made to the charity partner.

Page 45


Kaiser

CRYSTAL FOUCHARD

1 And then we also have our vendor -- our

2 supplier partners participate in donations to

3 Red Nose Day, and as a result of that, they get

4 display space in store. So you'll see

5 Red Nose Day, for example, in the center aisle or

6 on display.

7 Q. What is meant by "Email"?

8 A. "Email" is sending an email to either a

9 broad audience or a targeted audience with a

10 relevant message.

11 Q. And would the mark "Walgreens" be used in

12 email?

13 A. Yes.

14 Q. And what would "Marketing Materials"

15 include?

16 A. That's a pretty general bucket. So that

17 may include something like a brochure that we

18 print, so collateral that's used either in store or

19 out of store.

20 Q. Would the mark "Walgreens" appear on

21 brochures?

22 A. Yes.

23 Q. What is "Streaming Audio"?

24 A. "Streaming Audio" are channels like

25 Pandora. So rather than listening to terrestrial

Page 46


CRYSTAL FOUCHARD

1 radio, you can listen to streaming audio, and we

2 would place a name within those streaming audio

3 channels.

4 Q. An audio ad?

5 A. An audio ad, yes.

6 Q. Would you include the mark "Walgreens" in

7 such ads?


9 THE WITNESS: You would verbally hear the name

10 Walgreens. Some of the partners also have a

11 digital component associated with them, and so you

12 might also see a visual ad, like, on your mobile

13 phone, for example, which would also have the

14 Walgreens mark.

15 Q. Can you explain "Mobile App Downloads"?

16 A. "Mobile App Downloads." So we have a

17 Walgreens mobile app, and in some cases, we pay

18 third parties to incentivize the download of the

19 mobile app.

20 Q. How do third parties go about

21 incentivizing the download of the app?

22 A. It could be we are advertising on, like, a

23 different site to give people visibility that we

24 have the Walgreens mobile app.

25 Q. And what is "Run of Press

Page 47


CRYSTAL FOUCHARD

1 (ROP)/PFP/Parade"? What does that mean?

2 A. So "Parade" is an insert that's in some

3 Sunday papers. So if we placed an ad within

4 Parade, that's what that would represent.

5 "PFP," I don't know what the acronym

6 means. In addition, to the section of the

7 newspaper where it's got a focus on coupons, you

8 can put a freestanding insert, almost like a --

9 your own separate page highlighting Walgreens'

10 messaging, so that's a PFP.

11 "ROP" stands for run of press.

12 Q. What does "run of press" mean?

13 A. Sometimes we use that to reference

14 newspaper ads.

15 Q. And what would "Research" include?

16 A. "Research" could include a lot of

17 different types of research. So customer research

18 for my area of focus, research for consumers. It

19 could be focus groups. It could be an online

20 survey.

21 Q. Going back to the "Run of

22 Press/PFP/Parade," in those types of

23 advertisements, would the mark "Walgreens" be

24 included?

25 A. Yes.

Page 48


CRYSTAL FOUCHARD

1 Q. Do you know what "Content" is?

2 A. "Content" is another general term, but we

3 do partner with third parties to develop content.

4 So, for example, WebMD might develop specific

5 articles related to a category or a consumer need

6 that Walgreens is sponsoring.

7 We could have a third parties develop,

8 like, an infographic, a graphical representation of

9 content bringing a study or other materials to life

10 in a way that consumers are going to understand and

11 respond to it.

12 Q. Okay. And would the mark "Walgreens" be

13 included in such content?

14 A. Yeah. Like I said, in some cases we would

15 be a sponsor of the content, and it would say

16 "Sponsored By Walgreens."

17 Q. And what is "Out of Home"?

18 A. "Out of Home" is usually referring to

19 billboards. So it might be a sign on a bus station

20 or it could be a billboard that you see on the

21 highway.

22 Q. And would the mark "Walgreens" be included

23 in such -- out of home -- advertisements?

24 A. Yes.

25 Q. What is "SEO"?

Page 49


CRYSTAL FOUCHARD

1 A. "SEO" stands for search engine

2 optimization.

3 So within search, you have two different

4 dynamics: One being if somebody is searching

5 something that you want your brand to show up high

6 on that search. Another is to incentivize clicks.

7 So getting people to click on the search ad to take

8 you to, for example, our website to purchase a

9 product or to get more information. So search

10 engine optimization helps with, like, the

11 algorithms of optimizing Walgreens' exposure and

12 subsequent, then, action by the consumer.

13 Q. "In-Store Print"?

14 A. "In-Store Print," I'm not exactly sure.

15 I don't use that term. I know our stores have the

16 ability to print some things in store themselves.

17 That usually shows up on the store expenses as

18 opposed to being represented within this type of

19 document. So I'm not exactly sure what that

20 represents.

21 Q. And what about "Remarketing"? What does

22 that mean?

23 A. "Remarketing" is relatively new for us

24 from a technology standpoint. So having the

25 ability to understand if somebody has seen a

Page 50


CRYSTAL FOUCHARD

1 digital ad and then serve them up with a subsequent

2 marketing messaging, perhaps, in another channel,

3 like sending them an email.

4 Q. Would the Walgreens mark "Walgreens" be

5 included?

6 A. Generally, yes.

7 Q. And "AARP Royalties," can you explain what

8 that is, and why it is in this report?

9 A. Sure.

10 We have a partnership with AARP.

11 Walgreens advertises within a lot of AARP vehicles.

12 They have different newsletters or magazines, and

13 then we also have an effort to try and connect AARP

14 members to become Balance Rewards members. So we

15 show AARP members the benefit of joining Walgreens

16 Balance Rewards, and they get an additional

17 discount for doing so.

18 Q. What is Balance Rewards?

19 A. Balance Rewards is Walgreens' loyalty

20 program. So if you are a Balance Rewards member,

21 you get access to the discounts on products. You

22 also get points for different types of promotions.

23 Q. Do Balance Reward members get any sort of

24 tool to use at checkout to show they are in the

25 rewards program?

Page 51


CRYSTAL FOUCHARD

1 A. There are -- you can get a Balance Reward

2 card. You can also access the benefit by typing in

3 your phone number at the PIN pad at checkout.

4 Q. Do you know whether the "Walgreens" mark

5 appears on the Balance Rewards card?

6 A. I don't think it does.

7 Q. How many Balance Rewards members are

8 there, if you know?

9 A. We have over 100 million Balance Rewards

10 members. In my personal experience, I think the

11 latest number of active members, meaning that

12 they've used the card more than once in a 52-week

13 period, is 80 million.

14 Q. And what's "Internal Distribution"?

15 A. I'm not sure what that is referring to.

16 Q. "Public Relations"?

17 A. "Public Relations," again, there is a wide

18 range within that headline. So those are things

19 like -- associated with press releases; could be

20 associated with financials, like earnings calls;

21 could be associated with a specific program, like

22 when we launched the "Feel More Like You" program,

23 we had press releases associated with that.

24 It could be an event, something where we

25 host an event and have media and other parties

Page 52


CRYSTAL FOUCHARD

1 attend where we talk about and promote the event

2 from their forum.

3 Q. And "Digital Roto/Shop Local," what does

4 that mean?

5 A. So our roto is available online. So Roto

6 and Shoplocal is a third party who, I think, helps

7 with the formatting and giving access to kind of

8 the digital functionality. So I think those are

9 the expenses associated with giving consumers

10 access to our roto online.

11 Q. Does your online roto contain the mark

12 "Walgreens"?

13 A. It does.

14 Q. And what is "Brand Influencer"?

15 A. "Brand Influencer" would be a third party

16 that we contract with to kind of talk about

17 Walgreens from -- again, from their platform. So

18 it could be somebody who has a lot of Instagram

19 followers or other types of followers on Facebook,

20 and they're talking about Walgreens from their

21 perspective to their followers.

22 Q. "Website," would that be walgreens.com, or

23 do you know?

24 A. I'm not certain.

25 Q. "Paid Content/Integrations," what does

Page 53


CRYSTAL FOUCHARD

1 that mean?

2 A. That's similar to some of the examples

3 that I gave for "Content" above. So integration is

4 the example that I used where the Walgreens shows

5 up on, like, within Kelly Clarkson's show or other

6 types of integrations within a different program

7 where it's not like, first and foremost, marketing

8 led -- I'm sorry -- Walgreens led, but Walgreens is

9 showing up within other content.

10 Q. And "Promo Tools/IT Capabilities," do you

11 know what that is?

12 A. I'm not certain.

13 Q. What about "Coupons/Promotional Ad"?

14 A. It looks like it's an offset. I am not

15 exactly sure.

16 Q. And for some of the rows, there is blanks

17 in the column. For example, "Online Video" for

18 fiscal year '14 actual, there is nothing listed.

19 Do you know why that would be?

20 A. In that case I would assume that -- online

21 video is a newer technology. So we probably didn't

22 have -- we didn't activate in that channel in FY14

23 and began in FY15.

24 Q. And looking at "Streaming Audio" in fiscal

25 year 2014, there is nothing listed. Why would that

Page 54


CRYSTAL FOUCHARD

1 be?

2 A. I think that's the same example of it

3 being a newer technology and Walgreens not being

4 active in that channel until more recently.

5 Q. Okay. Would the same be true for "Mobile

6 APP Downloads" or not?

7 A. Related. We developed the mobile app --

8 I don't know exactly when we developed it, but at

9 the end it's relatively new, and trying to promote

10 for downloads would have happened more recently.

11 Q. And what about for "Research"? There is

12 blanks in 2014 and '15.

13 A. So "Research," I think there has been

14 different ways of representing research within

15 Walgreens' accounting. So it may be that research

16 was in a different bucket in those earlier years,

17 within a separate insight bucket, for example, and

18 then with a desire to try and get the costs more

19 closely associated with the kind of end result,

20 bringing the research associated with marketing

21 into the marketing budget.

22 Q. And what about "Content," why would there

23 be blanks in 2014 and '15?

24 A. Content is a newer area of focus for us.

25 So we put more emphasis in that recently.

Page 55


CRYSTAL FOUCHARD

1 Q. And then I'll skip "In-Store Print," since

2 you testified you don't really know what that is.

3 What about "Remarketing"?

4 A. "Remarketing" is, again, something that is

5 a newer technology for Walgreens. So something

6 that we began looking at and utilizing more

7 recently.

8 Q. And how about "Relations"? Why would

9 there be blanks for all years until 2018?

10 A. That may be an example like insights -- or

11 "Research" where there was a separate budget for

12 public relations and, again, in the desire to have

13 costs associated with marketing be reflected in the

14 marketing budget, that that was included within the

15 marketing view.

16 Q. And what would be the situation for

17 "Digital Roto/Shop Local"?

18 There is blanks in 2014 and '15.

19 A. I think we didn't offer the digital

20 version in this kind of really digitally dynamic

21 format until more recently.

22 Q. And "Brand Influencer," there is nothing

23 listed until fiscal 2018. Do you know why?

24 A. I think we may have pulled that out as a

25 distinct category more recently. Again, that's an

Page 56


CRYSTAL FOUCHARD

1 area of more recent focus for us.

2 Q. And does Walgreens have brand influencers?

3 A. We don't have, like, a company

4 spokesperson, but we use brand influencers on

5 different types of campaigns. So within a Summer

6 Sun campaign, we had influencers, who were kind of

7 in the beauty and health space, who -- we had

8 generated content.

9 An example is they had their picture taken

10 with a UV camera to see kind of the hidden sun

11 damage, and then they used that photo to talk about

12 protecting their skin, and there are some

13 protection products available at Walgreens, for

14 example.

15 Q. And then "Website," do you know why fiscal

16 year 2016 would be blank in Walgreens' records?

17 A. I don't.

18 Q. And "Paid Content/Integrations," do you

19 know why those columns would be blank in 2014 and

20 2015?

21 A. I think just like the "Content"

22 discussion, a newer area of focus for us.

23 Q. And "Promo Tools/IT Capabilities," do you

24 know why 2016, '17 and '18 are blank?

25 A. I'm not familiar with that line.

Page 57


CRYSTAL FOUCHARD

1 Q. You said you weren't sure about

2 "Coupons/Promotional Ads" either?

3 A. Right.

4 Q. Correct.

5 MS. MILLER: Let's take a five-minute break.

6 (A short break was taken.)

7 BY MS. MILLER:

8 Q. Ms. Fouchard, you mentioned, when we just

9 went through the last exhibit, one of the items was

10 TV. What kind of TV advertising does Walgreens do?

11 A. We have mass TV throughout the year. So,

12 for example, we have TV spots on flu shots and

13 Med D. Last year we had TV spots on summer skin.

14 So it's generally mass advertising to a broad

15 audience.

16 Q. And when you say "broad audience," what

17 does that mean?

18 A. Nationally, like showing up on network and

19 cable programming.

20 Q. Med D, what is that in reference to?

21 A. That's Medicare Part D, talking about

22 prescription co-pays.

23 Q. You have television advertisements that

24 address that?

25 A. Yes.

Page 58


CRYSTAL FOUCHARD

1 Q. Okay. Do you know approximately how many

2 television commercials Walgreens might do in a

3 year?

4 A. I would say probably about eight different

5 messages. There might be different versions of

6 those, a 15-second spot versus a 30-second spot.

7 So I would say about eight different messages.

8 Q. About eight per year?

9 A. Per year.

10 Q. And you mentioned -- I think when you were

11 talking about Red Nose Day, but correct me if I'm

12 wrong -- a partnership with NBC. What is that

13 partnership?

14 A. So NBC is another partner within the

15 Red Nose Day initiative. So on Red Nose Day, which

16 is in May, they have a broadcast, almost like a

17 telethon fund-raising with different programming

18 associated with that. And then, in addition, you

19 know, for a week leading up to the actual day, they

20 have different integrations with either television

21 shows or celebrities that they have partnerships

22 with.

23 So last year, I believe it was

24 Julia Roberts going with Bear Stearns on some type

25 of adventure and talking about her experience. So

Page 59


CRYSTAL FOUCHARD

1 we've been doing it for years. There is different

2 types of NBC and celebrity integrations either in

3 that programming or with celebrities they have

4 access to.

5 Q. And in those integrations, is the mark

6 "Walgreens" ever used, if you know?

7 A. Yes.

8 Q. In what ways?

9 A. Generally, there is a reference about

10 Walgreens being a partner and that the red noses

11 are available at Walgreens to purchase to generate

12 funding for the charity.

13 Q. Are the red noses available for purchase

14 anywhere else other than Walgreens?

15 A. They are not.



18 identification.)

19 BY MS. MILLER:



22 Do you have an understanding of what this

23 document is?

24 A. Yes.

25 Q. What is this?

Page 60


CRYSTAL FOUCHARD

1 A. This is representing our print roto, which

2 is the circular that highlights a subset of our

3 offers.

4 Q. Okay. And --

5 MR. KERMAN: Can we just clarify? I don't know

6 if you referred to 70 or I misheard and wrote 70.

7 Is it 70? Did I do this wrong? I have this chart

8 as 68. Is the chart 69?

9 THE WITNESS: Are you asking me?

10 MR. KERMAN: Yes.

11 Off the record.

12 (Discussion off the record.)

13 BY MS. MILLER:

Page 61


CRYSTAL FOUCHARD

Page 62


CRYSTAL FOUCHARD

Page 63


CRYSTAL FOUCHARD



5 identification.)

6 BY MS. MILLER:



9 Do you know what this document is?

10 A. This looks like a front page of our

11 circular.

12 Q. And the circular is equivalent to roto, as

13 you testified earlier?

14 A. Yes.

15 Q. What is the purpose of a roto or circular?

16 A. It is to communicate to consumers what

17 promotions are available at Walgreens that week.

18 Q. Okay. And do you see on the front page

19 the mark "Walgreens" in its red script at the

20 bottom?

21 A. I do.

22 Q. Do you know -- is that always used on the

23 front page, the logo?

24 A. To my knowledge, it is always used.

25 Q. If you turn to W-2317.

Page 64


CRYSTAL FOUCHARD

1 MR. KERMAN: Can you repeat the page, please?

2 MS. MILLER: 2317.

3 BY MS. MILLER:

4 Q. Do you see, at the bottom, in the middle,

5 there are some products there?

6 A. Yes.

7 Q. It looks like they all have at the top

8 "Well At Walgreens"?

9 A. Yes.

10 Q. And is this -- are these examples of the

11 types of products that you had testified about

12 earlier that actually bear the "Walgreens" mark?

13 A. Yes.

14 Our health and wellness products that have

15 the Walgreens branding, that brand is -- actually,

16 the branding is transitioning. So this is all

17 transitioning to -- well, it just says "Walgreens."

18 So the "Well At" has been removed.

19 Q. Okay. Looking at the next page, W-2318,

20 what is this page in reference to?

21 A. "Find Care Now" is a service available on

22 our Walgreens app, as well as on walgreens.com,

23 that shows different types of care providers by

24 need.

25 So, for example, if you have an optical

Page 65


CRYSTAL FOUCHARD

1 need, it will highlight Walgreens Optical. It also

2 highlights our health system partners that have

3 clinics available in Walgreens stores. So this

4 allows you to search for, basically, a provider

5 that can meet your specific need.

6 Q. You testified when we were looking at the

7 marketing spend document, that Walgreens does

8 social media?

9 A. Yes.

10 Q. What social media is Walgreens on?

11 A. Walgreens has a -- is on Facebook, on

12 Instagram, Twitter. We just started utilizing

13 Pinterest a bit more.

14 Q. And on those social media pages, does the

15 mark "Walgreens" appear?

16 A. Yes.



19 identification.)

20 BY MS. MILLER:



23 Do you know what this is?

24 A. This is our LinkedIn page, Walgreens'

25 LinkedIn page.

Page 66


CRYSTAL FOUCHARD

1 Q. And does Walgreens have any people that

2 follow it on LinkedIn?

3 A. That follow it. I'm not sure.

4 Q. Looking at -- just to the right of the red

5 W, where it says "Walgreens," and underneath it it

6 says "Retail Deerfield, Illinois"?

7 A. There it is, yep.

8 Q. "338,453 Followers." Do you have an

9 understanding of what that means?

10 A. Yes. That would be a number of people on

11 LinkedIn who have chosen to follow Walgreens.

12 Q. Do you know how long Walgreens has had a

13 LinkedIn site?

14 A. I don't.



17 identification.)

18 BY MS. MILLER:




22 A. This is the Walgreens YouTube page.

23 Q. What is the purpose of Walgreens having a

24 YouTube page, if you know?

25 A. It gives us a repository for placing video

Page 67


CRYSTAL FOUCHARD

1 assets. So if somebody is searching YouTube for

2 something related to Walgreens or one of our

3 videos, then it would likely take them to this

4 page.

5 Q. The red Walgreens script appears here at

6 the top?

7 A. Yes.

8 Q. And does anyone follow or subscribe to

9 Walgreens' page on YouTube?

10 A. This says there is about 48,300

11 subscribers.


13 YouTube page?

14 A. I don't.

15 Q. Do you know if it's been more than a year?

16 A. Yes.

17 Q. Do you know if it's been more than three

18 years?

19 A. I don't.



22 identification.)

23 BY MS. MILLER:



Page 68


CRYSTAL FOUCHARD


2 A. This looks like the Walgreens Pinterest

3 page.

4 Q. And the mark "Walgreens" appears at the

5 top?

6 A. Yes.

7 Q. What is the purpose of Walgreens having a

8 Pinterest page?

9 MR. KERMAN: I have a question. Is this just

10 not showing or does this not have a document Bates

11 number on it?

12 MS. MILLER: It doesn't have a Bates number.

13 MR. KERMAN: So it's never been produced?

14 MS. MILLER: No. It's a publicly available

15 online document. It's got the path and the date.

16 MR. KERMAN: I am going to object to it as not

17 being produced to us contemporaneous so that we can

18 go in and get the same document.

19 MS. MILLER: Can you read back where I was?

20 (Whereupon, the record was

21 read.)

22 THE WITNESS: This allows us to post content

23 that would be relevant for our consumers within the

24 Pinterest environment.

25

Page 69


CRYSTAL FOUCHARD

1 BY MS. MILLER:

2 Q. And does this printout from the page show

3 how many views this Pinterest page of Walgreens

4 gets?

5 A. It says 10M monthly viewers.

6 Q. What do you understand 10M to mean?

7 A. I don't know for sure.



10 identification.)

11 BY MS. MILLER:




15 A. This is the Walgreens Instagram page.

16 MR. KERMAN: Same objection with respect to

17 Exhibit A-75 and for A-74, as using documents that

18 were never produced to us during discovery or

19 otherwise.

20 BY MS. MILLER:

21 Q. And does the mark "Walgreens" appear on

22 the Instagram page?

23 A. Yes.

24 Q. And do you see under the name "Walgreens"

25 where it says "294K Followers"?

Page 70


CRYSTAL FOUCHARD

1 A. Yes.

2 Q. And do you have an understanding of what

3 that means?

4 A. 294,000 followers.



7 identification.)

8 BY MS. MILLER:




12 MR. KERMAN: Object to the use of this exhibit

13 with the witness for the same reasons that is with

14 respect to A-74 and A-75 in that it was never

15 produced to us at any time.

16 THE WITNESS: It's our Walgreens Facebook page.

17 BY MS. MILLER:


19 Facebook page?

20 A. I don't.

21 Q. Has it been more than three years?

22 A. I don't know.

23 Q. Does the mark "Walgreens" appear on

24 Walgreens' Facebook page?

25 A. Yes.

Page 71


CRYSTAL FOUCHARD

1 Q. Is it in the red script?

2 A. Yes.

3 Q. And if you look on the right where it says

4 "Community" --

5 A. Yes.

6 Q. -- does the page show how many people like

7 the Walgreens Facebook page?

8 A. Yes. 4,472,488 people like this.

9 Q. And does it show how many people follow

10 the Walgreens Facebook page?

11 A. Yes, 4,228,900 people follow this.

12 Q. Do you have any reason to doubt those

13 numbers?

14 A. No.



17 identification.)

18 BY MS. MILLER:


20 been previously marked Applicant's Trial

21 Exhibit 77.


23 MR. KERMAN: Object to -- before she answers,

24 I object to the use of this exhibit for the same

25 reasons as Exhibit A-74 through A-76 inclusive

Page 72


CRYSTAL FOUCHARD

1 being that it wasn't produced to us.

2 THE WITNESS: This looks like our walgreens.com

3 site.

4 BY MS. MILLER:

5 Q. And can people -- what can people do on

6 your site -- find on your site?


8 BY MS. MILLER:

9 Q. Let me withdraw.

10 What's the purpose of having a website for

11 Walgreens?

12 A. It gives us the opportunity both -- for

13 digital commerce. So people can purchase products

14 from walgreens.com. It also gives us the

15 opportunity to provide information and education on

16 various topics and also to share content on various

17 topics.

18 Q. What types of topics?

19 A. We have health-related content,

20 beauty-related content.

21 Q. And by "content," what do you mean?

22 A. We have a lot of articles available on

23 walgreens.com on different topics.

24 It is something like is it a cold or an

25 allergy and tips to help people understand the

Page 73


CRYSTAL FOUCHARD

1 difference between the two.

2 Like, within beauty we have tips on, like,

3 new trends within beauty. So those would be

4 examples of different types of content in health

5 and wellness and beauty.

6 We also have information available on

7 prescriptions.

8 You can refill your prescriptions online,

9 and then there is information on various

10 prescriptions in terms of the information you might

11 find when you pick up your prescription with, like,

12 what are the -- what is the ingredients, what are

13 the indications, what is the usage, what is the

14 dosage, those types of things, so you can manage

15 your own kind of prescription refill, as well as

16 look at more general information.

17 Q. Do you know if there are ever any

18 unsolicited mentions of Walgreens in the media?

19 A. Yes.

20 Q. What would be the -- what would be the

21 cause of that?

22 A. Somebody sharing their own experience or

23 reacting to something that we put out from a

24 marketing message standpoint.

25 Q. Do you know whether the name "Walgreens"

Page 74


CRYSTAL FOUCHARD

1 ever appears in any newspaper articles?

2 A. Yes.

3 Q. Why would it be included in a newspaper

4 article?

5 A. There could be discussion about Walgreens'

6 earnings or financial performance, for example.

7 Q. Okay. And do you know whether Walgreens

8 has won any awards?

9 A. Yes.

10 Q. What awards are you aware of?

11 A. For example, recently, Morning Consult

12 named Walgreens as one of the most loved brands in

13 America.

14 There is various awards from a PR

15 perspective based on different campaigns that we

16 do.

17 Awards from a marketing perspective, we

18 just won a brand week award relatively recently for

19 our "Feel More Like You" program and for our HIV

20 partnership for National HIV Testing Day.



23 identification.)

24 BY MS. MILLER:

Page 75


CRYSTAL FOUCHARD

15 MR. KERMAN: I am going to object to you

16 reading from the document. The witness hasn't

17 identified she's familiar with the document. You

18 asked her if she knew any of the authors or

19 recipients. She said she knew of two. That

20 doesn't show she knows anything about this

21 document. It's improper to try to get in it

22 through her.

23 BY MS. MILLER:

Page 76


CRYSTAL FOUCHARD



8 identification.)

9 BY MS. MILLER:



12 Have you seen this type of document

13 before?

14 MR. KERMAN: Object to the form of the "this

15 type of document." The normal question is, "Have

16 you seen this document?" I don't know what "this

17 type of document" means.

18 MS. MILLER: I'll rephrase.

19 BY MS. MILLER:

Page 77


CRYSTAL FOUCHARD

Page 78


CRYSTAL FOUCHARD

7 Q. In what manner are Walgreens goods and

8 services sold?

9 MR. KERMAN: Object to the form. Vague.

10 BY MS. MILLER:

11 Q. Do you understand my question?

12 A. Yes.

13 Q. How -- let's do them one at a time.

14 How does Walgreens sell its -- well, does

15 Walgreens -- how does Walgreens sell its products?


17 THE WITNESS: We sell our products through our

18 stores and fill prescriptions through our stores.

19 We also sell our products through walgreens.com and

20 also fill prescriptions on walgreens.com.

21 BY MS. MILLER:

22 Q. Okay. And where are Walgreens stores?


24 THE WITNESS: Walgreens stores are in the

25 United States. They are in all 50 states.

Page 79


CRYSTAL FOUCHARD

1 BY MR. KERMAN:

2 Q. And how would a person going to -- would a

3 person going to a Walgreens store see the mark

4 "Walgreens"?

5 A. Yes.

6 Q. How would they see it?

7 MR. KERMAN: Object to form.

8 THE WITNESS: On the outside of our stores, we

9 have the "Walgreens" mark. Also outside of our

10 store, the mark shows up on reader boards and other

11 signs.

12 Within the store, it would show up on the

13 circular, printed materials like the circular, our

14 savings book, on signage within the store or

15 outside the storefront door, posters in the

16 pharmacy waiting room, on our prescription bags.

17 When you get a prescription filled, the "Walgreens"

18 mark is on the bags.

19 So various places within the stores based on

20 where the consumer is shopping.

21 BY MS. MILLER:

22 Q. Do you know about how many prescriptions

23 Walgreens fills in a year?

24 A. Just over a billion.

25 Q. Do you know what Walgreens' revenues are

Page 80


CRYSTAL FOUCHARD

1 for its U.S. sales in a year?

2 A. In fiscal '19, it was about 100 billion.

3 Q. Does the "Walgreens" mark appear in any

4 stores other than stores with Walgreens on the

5 sign?

6 A. In the Dwayne Reed stores we acquired, the

7 "Walgreens" mark appears on materials within the

8 store.

9 On the Rite Aid stores that we acquired,

10 all of the pharmacies within those stores have been

11 converted to Rite Aid pharmacies. The process of

12 converting the entire stores are in progress. My

13 personal understanding is that about 900 stores

14 have been converted fully to Walgreens.

15 We have a partnership with Kroeger. Some

16 Kroeger products appear within Walgreens stores,

17 and then Walgreens now has our health and wellness

18 products within Kroeger stores, as well as

19 information within the pharmacy area.

20 Q. The health and wellness products in

21 Kroeger stores, do you know whether they bear the

22 mark "Walgreens" or not?

23 A. Yes.

24 Q. I'm sorry. You said there is what in the

25 pharmacy area?

Page 81


Kroger

Kroger

Kroger

Kroger

Walgreens

Duane Reade

CRYSTAL FOUCHARD


2 THE WITNESS: Material within the pharmacy

3 area.

4 BY MS. MILLER:

5 Q. Do you know what would those material

6 relate to?

7 A. Walgreens' pharmacy services.

8 Q. Would the name "Walgreens" appear on those

9 materials?

10 A. Yes.

11 Q. You talked earlier about the

12 Balance Rewards members?

13 A. Yes.

14 Q. And that that's a loyalty program?

15 A. Yes.

16 Q. You mentioned that Balance Reward card

17 that members have?

18 A. Yes.

19 Q. Can the Balance Reward card be used

20 anywhere other than Walgreens stores?

21 A. If you are separating out Dwayne Reed and

22 Rite Aid, it could be used in those stores as well.

23 Q. Any other stores?

24 A. Not that I'm aware of.

25 Q. Do you consider Walgreens to be a

Page 82


Duane Reade

CRYSTAL FOUCHARD

1 well-known mark?


3 THE WITNESS: Yes.

4 BY MS. MILLER:

5 Q. And in your role, do you become aware of

6 other specialty pharmacies?

7 A. Peripherally.

8 Q. And how does that happen?

9 MR. KERMAN: I missed -- was the answer

10 peripherally? I couldn't hear.

11 THE WITNESS: Yes.

12 BY MS. MILLER:

13 Q. How do you become aware of other specialty

14 pharmacies?

15 A. In the course of business talking to our

16 business partners on the specialty pharmacy team.

17 That would generally be how I'd become aware.

18 Q. And do you know the trademark of the party

19 on the other side of this case?

20 A. Through this case.

21 Q. Okay. What is that trademark?

22 A. Reliance Rx.

23 Q. And when did you first hear about

24 Reliance Rx?

25 A. During this case.

Page 83


CRYSTAL FOUCHARD

1 Q. Are you personally aware of any actual

2 confusion having arisen between Reliance Rx and

3 AllianceRx Walgreens Prime?

4 A. No.

5 Q. In your opinion, is there any likelihood

6 of confusion between the marks?

7 MR. KERMAN: Object to the form. Calls for

8 speculation.

9 THE WITNESS: In my opinion, no.

10 BY MS. MILLER:

11 Q. Why is that?

12 MR. KERMAN: Objection. Same objection.

13 THE WITNESS: AllianceRx Walgreens Prime has

14 Walgreens and Prime as part of the mark, which both

15 are well known, particularly, Walgreens from a

16 consumer perspective, and Prime with other

17 stakeholders. And Alliance has a different

18 consumer meaning then Reliance.

19 BY MS. MILLER:

20 Q. Okay. And you mentioned stakeholders and

21 Prime. What other stakeholders?

22 A. So Prime, as a pharmacy benefit manager,

23 has other stakeholders beyond the patients with

24 payors and providers.

25 MS. MILLER: I think we should break for lunch.

Page 84


CRYSTAL FOUCHARD

1 I'll review my notes to see if we have anything

2 else. Maybe you can prepare for your cross.

3 MR. KERMAN: I don't want to break for lunch at

4 11:40. That's crazy. We started at 9:30, and we

5 are breaking for lunch at 11:40.

6 MS. MILLER: Okay. We can take a break, and

7 we'll go upstairs and figure out if we have

8 anything else.

9 MR. KERMAN: Okay. Thank you.

10 MS. MILLER: If you want to start preparing for

11 your cross, I am almost done.

12 MR. KERMAN: I will wait until you come back,

13 and then I will prepare.

14 MS. MILLER: You are free to use the other room

15 too.


17 MS. MILLER: We don't have any further

18 questions.

19 CROSS-EXAMINATION.

20 BY MR. KERMAN:

21 Q. We just hit good afternoon, so good

22 afternoon. I am going to ask you questions, as

23 I've done at least once before in December of 2018.

24 If you don't understand any of my questions, please

25 tell me that, and I'll try to rephrase it. Please

Page 85


CRYSTAL FOUCHARD

1 don't answer with "uh-huhs" or things like that.

2 They need to be yes or no or other words. Okay?

3 A. Okay.

4 Q. Besides the deposition we took of you once

5 before, have you ever given any other depositions?

6 A. Once in another case.

7 Q. Did that involve Walgreens or someone

8 else?

9 A. It was a different company.

10 Q. You started with Walgreens on

11 December 28, 2010; is that correct?

12 A. Yes.

13 Q. And you stayed employed by Walgreens since

14 that date?

15 A. Yes.

16 Q. Have you ever worked for AllianceRx

17 Walgreens Prime?

18 A. No.

19 Q. Do you have any specific knowledge of

20 AllianceRx Walgreens Prime's daily business

21 functions?

22 A. Not specific knowledge.

23 Q. When the two companies that you referred

24 to, Walgreens and Prime, you referred to created a

25 new point -- a new company through a joint venture

Page 86


CRYSTAL FOUCHARD

1 to support a specialty pharmacy, that was with

2 respect to AllianceRx Specialty Pharmacy and not

3 Walgreens Specialty; is that correct?

4 A. That's correct, with AllianceRx

5 Walgreens Prime.

6 Q. How did you prepare for your deposition

7 today, assuming you did?

8 A. I met with Tammy and Laura last Friday and

9 also this morning.

10 Q. Did you review any documents in connection

11 with your preparation for today's deposition?

12 A. We did, yes.

13 Q. Okay. I thought you said we didn't.

14 You did?

15 A. We did.

16 Q. What documents, specifically, did you look

17 at?

18 A. Various documents. We looked at the

19 provider media plan, the complete trademark search

20 report, emails, something that is a financial

21 document, marketing expenditures.

22 Q. Were some of these documents used at your

23 prior deposition?

24 A. Yes.

25 Q. Were some of these documents not used at

Page 87


CRYSTAL FOUCHARD

1 your prior deposition?

2 A. Yes.

3 Q. Were some of these documents being seen by

4 you for the very first time?

5 A. In preparation?

6 Q. Yes.

7 A. Yes.

8 Q. Which documents did you see in your

9 preparation for the very first time?

10 A. The "FY18 Provider Media Plan."

11 Should I look through them?

12 Q. Yes, please.

13 If you start with whatever document was

14 used with you first today, starting with your

15 deposition notice. So the first one was 66. It

16 would be the deposition. I don't need you to tell

17 me if you've seen that.

18 Starting with 67?

19 A. Yes, I saw that for the first time in

20 preparation for this.

21 Q. Is that the one you said was the FY 2018?

22 A. "FY18 Provider Media Plan."

23 Q. So Exhibit 7, you saw for the first time

24 today?

25 A. Not today. In preparation.

Page 88


CRYSTAL FOUCHARD

1 Q. In your preparation, which was last

2 Friday?

3 A. Yes.

4 Q. Okay. So January of 2019; correct?

5 A. That's correct.

6 Q. Therefore, you never saw it or used it in

7 your -- in connection with your employment by

8 Walgreens in the normal course of your employment;

9 correct?

10 A. Not that specific document.

11 Q. Okay. That's my question about that

12 specific document.

13 The Exhibit 68 that is the full search

14 probably with the rubber band.

15 A. I saw this for the first time at the

16 previous deposition.

17 Q. Okay. So you did see it before?

18 A. Yes.

19 Q. And at the previous deposition. If that

20 was the first time you saw it, that meant you

21 haven't seen that at the time you were actually

22 working on the selection of the name?


24 Q. Okay. Did you ever see excerpts from that

25 or a shortened version of that or never saw any

Page 89


CRYSTAL FOUCHARD

1 pages from it at all?

2 A. Not prior to the last deposition.

3 Q. Okay. Go to the next document, please.

4 Is it a one-page document, 3012, on the

5 bottom?

6 A. Yes.

7 Q. Okay. That's where I messed up my

8 numbering. So is that 69?

9 A. Yes.

10 Q. Is the first time you saw that at your

11 deposition preparation last week?

12 A. This specific document, yes.

13 Q. And that's the one with the money spent on

14 various marketing?

15 A. Yes.

16 Q. Exhibit 70, did you ever see that before

17 your -- did you see that after your preparation

18 meeting?

19 A. I did.

20 Q. Did you ever see it before then?

21 A. No.

22 Q. And that's the roto document, if I call it

23 for short?

24 A. Yes.

25 Q. 71, the circular, I'm sure you've seen

Page 90


CRYSTAL FOUCHARD

1 circulars; right?

2 A. I've seen circulars.

3 Q. But typed -- or not type -- but stapled,

4 as it is there, did you see that at your meeting

5 with your counsel?

6 A. Yes, I saw a stapled circular.

7 Q. Was it that one?

8 A. I can't recall if it was this specific

9 one.

10 Q. And do you recall ever receiving that --

11 I'll start over.

12 Do you recall ever seeing that exact

13 document at any time prior to your meeting with

14 counsel?

15 A. No.

16 Q. Then all pages, 72, 3, 4, 5 and 6, which

17 are -- to be short with it -- are different social

18 media-type printouts; is that correct?

19 A. Yes.

20 Q. Starting with LinkedIn, YouTube,

21 Pinterest -- I'm never sure how you say that --

22 Instagram and Facebook, did you see those at your

23 meeting with your counsel?

24 A. I saw some -- I'm not sure that I saw all

25 of them.

Page 91


CRYSTAL FOUCHARD

1 Q. Okay. If you turn to the second page of

2 each one, don't they show a printout date of just

3 yesterday? 1-9-2010?

4 A. Yes.

5 Q. So 2020. Excuse me. 1-9-2020 on each

6 one?

7 A. Yes.

8 Q. So then you couldn't have seen those pages

9 last week; right?

10 A. I saw a printout of pages representing our

11 Facebook page.

12 Q. When you met last week?

13 A. Yes.

14 Q. So -- but they weren't dated 1-9-2020;

15 correct?

16 A. They would not have been.

17 Q. Do you know when they were dated?

18 A. I don't know.

19 Q. Do you know why these documents were

20 substituted to be used with you instead of the

21 other ones?

22 A. I don't know.

23 Q. I didn't include 77 with that. So if you

24 would go to 77, that's a -- is that a printout of a

25 web page?

Page 92


CRYSTAL FOUCHARD

1 A. Yes.

2 Q. Do you -- have you -- you've seen your

3 company's website; right?

4 A. I have.

5 Q. Do you normally see it on a computer

6 screen or phone screen, an iPad screen, something

7 like that?

8 A. Yes.

9 Q. Have you seen it printed out like that

10 before?

11 A. I've seen printouts from our website

12 before.

13 Q. Did you see that at your meeting for

14 preparing for today?

15 A. I don't recall seeing the website printed

16 out.

17 Q. Does that appear to be like -- it looks

18 like the bottom of page 1 continues on the bottom

19 of page 2. Is it, to your knowledge, a printout of

20 the home page for Walgreens, and it took multiple

21 pages to print out?

22 A. That is my -- yes, that's what I would

23 assume.

24 Q. Okay. If you would go to Exhibit 78.

25 Is that a document that you ever saw

Page 93


CRYSTAL FOUCHARD

1 before -- well, did you see it when you met with

2 your counsel to prepare?

3 A. Yes.

4 Q. Had you ever seen it before?

5 A. Not that specific email.

6 Q. How about Exhibit 79?

7 A. I saw this document when we met to

8 prepare.

9 Q. Had you ever seen it before?

10 A. Not this specific document.

11 Q. If you'd look at Exhibit 67, please.

12 A. Okay.

13 Q. So you said you had never seen this

14 document before you had met with your attorneys;

15 correct?


17 Q. You were asked all sorts of questions

18 about it, but what were you basing your answers on,

19 if you had never seen this document before?

20 A. Based on my experience working within

21 marketing at Walgreens, we used these types of

22 documents, as I said, to plan our campaigns for

23 specific objectives. So the type of document and

24 much of the content is familiar to me.

25 Q. Did you have any responsibility personally

Page 94


CRYSTAL FOUCHARD

1 for any of the content in this document?

2 A. I did not.

3 Q. In fact, if I recollect correctly, in

4 column 3 on page 2 under "Engage," you didn't even

5 know what "NPP" meant; correct?


7 Q. On page 4 of that document where there are

8 the five photos, and at the bottom of each one

9 there is a co-branding situation of

10 "Walgreens|AllianceRx Walgreens Prime"; correct?

11 A. I see that programming on three of the

12 five, yes.

13 Q. On the three of the five that it's on, can

14 you personally, with your own eyes, right now, read

15 the words below AllianceRx if you didn't know what

16 they were?

17 A. No.

18 Q. And that's because AllianceRx is written

19 in significantly larger-type size or font than

20 Walgreens Prime when it's used in the logo; is that

21 correct?

22 MS. MILLER: Objection. Vague.

23 THE WITNESS: The material themselves are

24 relatively small, and, yes, AllianceRx portion is

25 written bigger.

Page 95


cobranding

CRYSTAL FOUCHARD

1 BY MR. KERMAN:

2 Q. Significantly bigger; right?

3 MS. MILLER: Objection.

4 THE WITNESS: It's bigger.

5 BY MR. KERMAN:

6 Q. Do you know what the word "significantly"

7 means?

8 A. I do.

9 Q. Okay. So you don't want to admit it's

10 significantly because your attorney is objecting?

11 MS. MILLER: Objection. Badgering the witness.

12 THE WITNESS: "Significant" is subjective.

13 BY MR. KERMAN:

14 Q. Okay. How would you describe it -- if you

15 weren't an interested party in this litigation, how

16 much bigger would you say it is than the words

17 below it?

18 MS. MILLER: Object to the form of the

19 question.

20 THE WITNESS: It is bigger.

21 BY MR. KERMAN:

22 Q. And I asked you to put an adjective on

23 that, to the best of your ability.

24 Don't look at your counsel. She's not

25 allowed to answer or help you answer.

Page 96


CRYSTAL FOUCHARD

1 A. It is substantially bigger.

2 Q. Thank you.

3 So you had trouble saying it's

4 "significantly," but you are okay with

5 "Substantially"; correct?

6 A. I think when you asked me to put an

7 adjective in front of it, I put an adjective in

8 front of it.

9 Q. My point it's not just slightly bigger;

10 correct?


12 THE WITNESS: Yes, it is substantially bigger.

13 BY MR. KERMAN:

14 Q. Could you go to page 7 of that document.

15 And I could be wrong, but I think you said

16 on the left picture is somehow an ad on an email;

17 is that correct? Or did I misunderstand?

18 A. The visual shows it's circling and

19 highlighting an ad at the bottom of the phone

20 screen.

21 Q. I see that.

22 But what is everything above it? Is that

23 an email?

24 A. It's not clear to me what that is.

25 Q. Did you testify it was an email, or did

Page 97


CRYSTAL FOUCHARD

1 I mishear you?

2 A. I think -- yes, I think I did.

3 Q. But looking at it now, would you clarify

4 your testimony that you really can't say it's an

5 email?

6 A. That is true. I can't tell what it is.

7 Q. Because I was going to ask how would

8 somebody put an ad on an email. If I sent someone

9 an email, is it likely that even if I'm a Walgreens

10 customer or Walgreens knew I was looking at their

11 site, can they inject an ad into an email I send or

12 receive?

13 A. Not from a printed standpoint, certainly.

14 Q. From some digital standpoint?

15 A. Not inject it into the email itself.

16 Q. So it's, therefore, impossible that that's

17 an ad on an email -- right? -- even though you said

18 it was?

19 A. I can't tell if it's an email.

20 Q. Focusing on -- okay. I understand that.

21 You don't know what it is either; right?

22 It's pretty small is why?

23 A. Yes.

24 Q. All I'm asking is, to your knowledge --

25 and if you don't know, that's fine -- can Walgreens

Page 98


CRYSTAL FOUCHARD

1 inject an ad into somebody's email?

2 A. No.

3 Q. So, therefore, it's impossible. It is not

4 just an email. It's impossible to be an ad in an

5 email; correct?

6 A. To my knowledge, I'm not aware that we can

7 inject an ad into someone's email.

8 Q. Therefore, to that extent, are you willing

9 to change your earlier testimony that this was an

10 ad in an email?

11 A. Yes.

12 Q. On page 9 you referred to a banner ad in

13 some combinations with an electronic health record;

14 is that correct?

15 A. Yes.

16 Q. What type of website -- it says "Patient

17 Dashboard." Would this be from some provider is

18 how you would see your electronic health record?

19 A. Who is "you"?

20 Q. The person looking at this screen.

21 How would someone -- to see an electronic

22 health record, can a patient see their own

23 electronic health record generally?

24 A. I'm not aware of that.

25 Q. Who would be able to see an electronic

Page 99


CRYSTAL FOUCHARD

1 health record where Walgreens might run a banner ad

2 on or anyone might run a banner ad on?

3 A. A provider.

4 Q. In order for Walgreens to put a banner ad

5 on such a document or computer digital document,

6 wouldn't Walgreens have to pay that provider to do

7 so?

8 A. Pay the provider?

9 Not that I'm aware of.

10 Q. How would they get the right or the

11 opportunity to put their ad into somebody's

12 electronic health record, digital health record?

13 A. It doesn't look to me that it is inserted

14 in the digital health record. That it is part of

15 the environment that the digital health record is

16 being viewed within.

17 Q. So would that be within a browser?

18 A. It could be within a browser.

19 Q. Who would Walgreens pay to run their ad

20 within a browser?

21 A. Within our media company, we have

22 activation within digital advertising. So finding

23 that -- the partners who can -- who have access to

24 be able to deliver the messaging in the right

25 context. So I don't know the specific partner.

Page 100


CRYSTAL FOUCHARD

1 Q. So you don't know how these ads could be

2 placed on a document where somebody, whoever that

3 was, was looking at an electronic health record;

4 correct?

5 A. I don't know the partner that would

6 provide it in this environment.

7 Q. The last page of the document, page 12,

8 W-938, I pretty much understand it. But I'm

9 curious if you know, say there was advertising for

10 flu treatment, it might be seasonally; correct?

11 A. Yes.

12 Q. Do you know why things like transplants or

13 oncology or HIV appear to be represented here as

14 advertising during certain time and not others?

15 A. I am not familiar with the MPP section of

16 this, so, no.

17 Q. Again, so the entire document is not a

18 document you ever dealt with in your employment.

19 Some of the stuff, you might have some familiarity

20 with. In other respects, due to your employment,

21 on this last page, you have absolutely no knowledge

22 other than your seeing it like we're seeing it;

23 correct?


25 question.

Page 101


CRYSTAL FOUCHARD

1 BY MR. KERMAN:

2 Q. Is that accurate?

3 MS. MILLER: Same objection.

4 THE WITNESS: I'm very familiar with the media

5 flow chart.

6 BY MR. KERMAN:

7 Q. Summary flow chart, is that what you're

8 calling a media flow chart?

9 A. Yes.

10 Q. Okay. If you're very familiar with it,

11 why does transplant advertising only start in the

12 last week of March and run until the end of April?

13 A. I am very familiar with a media flow chart

14 as it's used to represent different channels that

15 are being activated.

16 In this particular case, I am not familiar

17 with MPP, so I can't speak to your specific

18 question.

19 Q. So you're able to explain this chart, but

20 you don't know why this chart shows what it does?

21 You don't know what goes into those decisions of

22 when to run advertising; correct?

23 A. Not specifically for MPP section.

24 Q. For other sections, you do know? For

25 print?

Page 102


CRYSTAL FOUCHARD

1 A. Within print, based on what was set up

2 front in terms of the objectives and the strategy,

3 there is portions of this where the objectives and

4 strategy was to be always on. So digital was

5 represented in that section of the document. Print

6 was offered as targeted to specific providers or

7 relevant audiences.

8 Q. This flow chart is for Walgreens

9 advertising?

10 A. It doesn't say that specifically.

11 Q. Do you know?

12 A. Based on the document itself, it looked

13 like there were some aspects that were specifically

14 Walgreens and some aspects that were co-branded

15 Walgreens and AllianceRx Walgreens Prime.

16 Q. On the flow chart specifically, do you

17 have any basis to conclude that any of this

18 represents -- the top column is "Display," "MPP,"

19 "EHR," or "Print" that was done for AllianceRx?

20 A. I can't tell from this page specifically.

21 Q. So insofar as if we are concerned about or

22 interested in what advertising or marketing is done

23 by AllianceRx, this chart and this document doesn't

24 tell us; correct?


Page 103


CRYSTAL FOUCHARD

1 question.

2 THE WITNESS: The document as a whole includes

3 reference to AllianceRx Walgreens Prime.

4 This particular chart doesn't say which portion

5 of the marketing and media is inclusive of

6 AllianceRx Walgreens Prime.

7 BY MR. KERMAN:

8 Q. And the reference to AllianceRx is those

9 three out of five on an earlier page?

10 A. That's the visual representation of print,

11 and then on page 50931, it also includes Walgreens

12 and AllianceRx Walgreens Prime.

13 Q. Do you have any idea how much was spent on

14 any print campaign in medical journals that

15 included co-branding between Walgreens and


17 A. I do not.

18 Q. Look at 21.

19 I used the word "string of emails." Are

20 you familiar with that term?

21 A. Yes.

22 Q. I don't know if it's correct or not. So

23 it's a series of emails?

24 A. Yes.

25 Q. And you are at least a recipient of some

Page 104


CRYSTAL FOUCHARD

1 part of it; correct?

2 A. Yes.

3 Q. And at the top which meant -- which

4 appears to be the most recent one, someone named

5 David Barber writes to you, and says, "I will give

6 you a call on this"; correct?

7 A. Yes.

8 Q. Do you recollect receiving this at or

9 about the time it's shown here, October 20, 2016?

10 A. I remember receiving emails about this

11 beginning around that time.

12 Q. So unlike some other exhibits we had, this

13 is something that you would have seen back when?

14 A. Yes.

15 Q. And, therefore, if you get the top email,

16 it has at least the other two or three -- I guess

17 it's two emails attached to it in this string?

18 A. Yes.

19 Q. So you get an email from Mr. Barber

20 saying, "I'll give you a call on this," and that

21 includes an email from James Oconor to various

22 people and CC to various people; correct?

23 A. That is correct.

24 Q. Would it have been logical that you would

25 have read that email below. "I will give you a

Page 105


CRYSTAL FOUCHARD

1 call on this" when you got this?

2 A. I can't recall specifically but --

3 Q. That's why I asked would it have been

4 logical for you to read if someone says, "I'm going

5 to call you about this" within your job duties,

6 you'd logically read what you are going to get a

7 call about; right?

8 A. Logically, yes.

9 Q. Therefore, do you assume you did so?

10 A. I can't say specifically on this email if

11 I read through everything in advance of subsequent

12 conversations.

13 Q. Then that one had, below it, an email from

14 Joel Wright to James Oconor; is that correct?

15 A. Yes.

16 Q. Who is Joel Wright?

17 A. Joel Wright is the -- is now the president

18 of Walgreens Specialty Pharmacy Holdings AllianceRx

19 Walgreens Prime.

20 Q. Well, you said "now." What was he then?

21 A. I don't know his title then.

22 Q. If I told you he's actually the CEO, would

23 that ring a bell and refresh your memory?

24 A. For AllianceRx Walgreens Prime?

25 Q. Yes.

Page 106


CRYSTAL FOUCHARD

1 A. That sounds right.

2 Q. You said he was the president a minute

3 ago. So you don't even know him well enough to

4 know his job title?


6 question.

7 THE WITNESS: I didn't know his job title.

8 BY MR. KERMAN:

9 Q. How often did you ever work with

10 Joel Wright?

11 A. I interacted with him infrequently.

12 Q. Is there anybody at AllianceRx, since its

13 formation, that you have interacted with more than

14 infrequently?

15 A. No.

16 Q. You are located within the Walgreens

17 headquarters in Deerfield?


19 Q. And does AllianceRx have any facility in

20 Deerfield?

21 A. I don't know that they have a facility

22 within Deerfield.

23 Q. Have you ever been within a physical

24 location of AllianceRx?

25 A. No.

Page 107


CRYSTAL FOUCHARD

21 Q. So then it says from Joel Wright to

22 James Oconor, "Thanks, Joel," and there is no

23 subject material there; correct?


25 Q. Well, the word "Subject" is there, but

Page 108


CRYSTAL FOUCHARD

1 there is no body of the email. Do you know if that

2 was redacted or removed for any reason?

3 A. I am not aware that it was redacted or

4 removed.

5 Q. And then there is an email from Cameron to

6 Joel, and you see that; correct?

7 A. Yes.

8 Q. And that's just one day before you were

9 told by Mr. Barber, "I'll give you a call on this";

10 right?

11 A. Yes.

12 Q. Okay. And within that body of the

13 email -- who is Cameron Olig?

14 A. Cameron Olig was at Prime. He was the

15 primary Prime contact that I worked with as part of

16 the naming recommendation.

17 Q. As with Joel, were you only in infrequent

18 contact with Mr. Olig?

19 A. I don't know --

20 Q. Or interacted with, as you said, with

21 respect to Mr. Wright?

22 A. With Mr. Wright.

23 Q. Earlier -- I'll rephrase it.

24 Earlier you said you interacted with

25 Mr. Wright infrequently; correct?

Page 109


CRYSTAL FOUCHARD

1 A. Yes.

2 Q. Is the same true with respect to your

3 interaction if any, with Mr. Olig?

4 A. During the discussion about the name,

5 I had more frequent interaction with Mr. Olig than

6 I did with Mr. Wright.

7 Q. So you dealt more with the person --

8 you're at Walgreens. You are a Walgreens employee,

9 but you dealt more with the person at Prime than

10 you dealt with the person either at Walgreens or on

11 the joint venture to be formed, Mr. Wright?


13 THE WITNESS: I worked primarily with

14 Jim Oconor within WBA, and then our Prime contact

15 was Cameron Olig.

16 BY MR. KERMAN:

17 Q. Okay. So let me -- did you work more with

18 Mr. Olig than you did with Mr. Oconor or not?

19 A. No, I worked more with Mr. Oconor than

20 Mr. Olig.

Page 110


CRYSTAL FOUCHARD

Page 111


CRYSTAL FOUCHARD

Page 112


CRYSTAL FOUCHARD

20 Q. Okay. Do you know what core means?

21 A. I think core is subjective.

22 Q. What do you think -- core is, actually,

23 very definable, as are most words. What do you

24 think core means? What's your understanding of the

25 word "core"?

Page 113


CRYSTAL FOUCHARD

1 A. Generally?

2 Q. What's your understanding of the word

3 "core," the definition? If you were asked to

4 define the word "core," what would you say?

5 A. What comes to mind is central.

6 Q. Any other synonyms?

7 A. Yeah, central is what pops to mind for

8 core.

9 Q. That's why I asked if you had any other

10 synonyms. If you were on Jeopardy and you had to

11 come up with -- to win all the money -- another

12 synonym for core?

13 A. The other ones don't feel quite as tight

14 to me. So...

15 Q. So central is the best you could come up

16 with?

17 A. Central is what feels best to me.

Page 114


CRYSTAL FOUCHARD

Page 115


CRYSTAL FOUCHARD

Page 116


CRYSTAL FOUCHARD

18 Q. Do you understand some concept of combined

19 equity naming options?

20 A. Yes.

21 Q. And that involves using Walgreens and

22 Prime to some degree?

23 A. Yes.

Page 117


CRYSTAL FOUCHARD

6 Q. And AllianceRx, ultimately, was used in

7 part of the name that was selected?

8 A. Yes.

9 Q. Okay. This one, though, says, in smaller

10 letters, "a Walgreens-Prime Venture." Do you

11 remember that being discussed?

12 A. That was not an area of focus when I was

13 part of the discussion.

14 Q. So what was an area of focus when you were

15 part of the discussion?

16 A. I was aware that that existed through

17 various communications, but we were -- when

18 I joined, there was a lot of momentum specifically

19 around AllianceRx Walgreens and Prime as the

20 elements of the name and the mark.

21 Q. Isn't that what this document page shows,

22 AllianceRx, and it also shows Walgreens, and it

23 also shows Prime?

24 A. I thought you were referencing,

25 specifically, the whole phrase as I think Cameron

Page 118


CRYSTAL FOUCHARD

1 said, "a Walgreens-Prime Venture."

2 Q. Well, that's what shows on this page;

3 right?

4 A. Yes.

5 Q. Do you remember that being discussed, "a

6 Walgreens-Prime Venture" or not?

7 A. I recall that being part of the materials

8 that were available to me and in emails, but that

9 was not a focus when I was part of the discussion

10 on naming.

11 Q. Had this already been dismissed and the

12 ultimate name already chosen?

13 A. No, I don't think it had been chosen.

14 Q. Well, what -- do you remember -- what

15 names do you remember being discussed, if you don't

16 remember this name being discussed?

17 A. When I joined, the focus was, as I said,

18 on AllianceRx Walgreens and Prime being the

19 elements of the name.

20 Q. Without the word "venture"?


22 Q. Okay. Do you see the ultimate name

23 anywhere in this document?

24 A. The ultimate name?

25 I do not.

Page 119


CRYSTAL FOUCHARD

1 Q. Do you know if it's in 18 at all?

2 A. I do not see the ultimate name in either

3 of these decks.

4 Q. Are you aware of any deck that discusses

5 the consideration of the ultimate name?

6 A. Any document.

7 There were email documents.

8 Q. Okay. Are you -- have you seen them in

9 your preparation for your deposition?

10 A. I was part of email discussions with the

11 trademark attorney about the selection of the name

12 and the mark.

13 Q. An attorney in-house or --

14 A. Yes.

15 Q. -- private law firm?

16 Okay. So those haven't been produced

17 because I presume they are regarded as privileged.

18 Other than communications with your own

19 in-house attorney, are you aware of any written

20 documents discussing the potential choice of the

21 ultimate name?

22 A. There were discussions among Jim and

23 Cameron about the name.

24 Q. My question was about documents.

25 A. Documents.

Page 120


CRYSTAL FOUCHARD

1 I know there were discussions via email

2 about the name. I don't know exactly what the

3 details of what's in each email.

4 Q. You say "you know." Did you see them?

5 Did you personally receive them?

6 A. Yes, there were discussions about the name

7 via email I was part of.

8 Q. And did all of the emails have an in-house

9 attorney being a recipient of it or the author of

10 it?

11 A. I don't recall. I don't think every email

12 had an in-house attorney on it.

13 Q. Did you produce those emails to your

14 counsel in this case to give to us?

15 A. I produced what I had available, yes.

16 Q. Do you specifically recollect producing an

17 email where the name AllianceRx Walgreens Prime,

18 whether or not it had a plus sign in it, was being

19 discussed, and you produced that document?

20 A. I don't specifically recall if I had an

21 email with AllianceRx Walgreens Prime without an

22 attorney referenced on it.

23 Q. That's what I'm asking.

24 A. I don't recall that specifically.

25 Q. If you turn to Exhibit 69. It's a

Page 121


CRYSTAL FOUCHARD

1 one-page document with expenses.

2 A. I'm sorry. I'm messing my piles here.

3 I think I'm in this pile.

4 Q. I do that too.

5 You spent about a half hour explaining

6 what you saw on this page -- correct? -- this

7 morning? When did you first see this page?

8 A. I first saw this representation of our

9 expenses last Friday.

10 Q. Okay. So that was in a meeting with

11 counsel; correct?


13 Q. You never saw this page in your employment

14 by Walgreens; correct?

15 A. In my -- in the course of my employment

16 with Walgreens, I do have visibility to our

17 marketing investment. I hadn't seen this

18 particular representation of that.

19 Q. Okay. Nobody ever gave it to you;

20 correct?

21 A. Gave it to me, no, not this.

22 Q. Handed it to you? Sent it to you by

23 email?


25 Q. Other than your meeting; right?

Page 122


CRYSTAL FOUCHARD


2 Q. Did you supply any information that goes

3 into this sheet, to your knowledge?

4 A. I did not supply any information for

5 purposes of creating this sheet.

6 Q. So you have no idea who created this

7 sheet; correct?

8 A. I don't know.

9 Q. You actually, despite question where you

10 said they seem reasonable, you actually have no

11 knowledge to personally know whether these numbers

12 are correct or not correct?

13 A. I have visibility to our total marketing

14 spend by year, and based on my personal knowledge

15 as part of my job, at least for fiscal '16, '17,

16 and '18, which I recall, those are within the range

17 of what I'm -- what I'm familiar with.

18 Q. Turn the page upside down, please.

19 No. Over. Over.

20 How much did your company spend in fiscal

21 year 2014 as a whole on marketing?

22 A. '14 and '15, I'm less familiar with.

23 Q. So you don't know '14; correct?

24 A. No.

25 Q. You say "less familiar." So I don't know.

Page 123


CRYSTAL FOUCHARD

1 A. Yes.

2 Q. So you're willing to say you don't know

3 what they spent in '14; correct?


5 Q. Do you know what they spent in '15?

6 A. No.

7 Q. Do you know what they spent in '16?

8 A. About 580,000.

9 Q. And do you know what they spent in '17?

10 A. Similarly, around 600,000.

11 Q. Do you know if they spent or what was

12 forecast to be spent in '18?

13 A. Lower, like around in the 500,000.

14 Q. Turn your page back over. See how you

15 did.

16 So you would say those numbers are in the

17 ballpark, is what you're saying?

18 A. Yes.

19 Q. But I don't know how many line items there

20 are here. Whether it's 20, 25, 30, you don't have

21 any knowledge where you would know whether each

22 individual line item is accurate or within an

23 acceptable range; correct?


25 Q. And then you were asked a bunch of times

Page 124


500,000s

CRYSTAL FOUCHARD

1 about missing entries for years, and if I think

2 I understand your testimony, some were because the

3 item wasn't used then. In other words -- I don't

4 want to make one up -- but in streaming audio,

5 I think you said, for example, it doesn't show in

6 '14. You sort of said it wasn't as popular yet;

7 right?

8 A. Yeah. For -- in some cases, the

9 technology or the channel is new. In other cases,

10 it might just be Walgreens --

11 Q. Chose not to --

12 A. -- participating was new to that channel.

13 Q. And then I think the other group of

14 potentially blank lines were because in other

15 years -- in those years they might have been

16 grouped differently or categorized differently;

17 correct?

18 A. Right. Within our accounting.

19 Q. So they are accounted for but just not on

20 that line item?

21 A. They weren't within the marketing

22 investment.

23 Q. So if this is a forecast for 2018, that

24 would suggest this document was created sometime

25 before 2018 was over, fiscal year 2018?

Page 125


CRYSTAL FOUCHARD

1 A. That would be my assumption.

2 Q. Do you know if it was forecast before

3 fiscal year '18 even started?

4 A. I would think it was during the course of

5 the fiscal year. We usually use -- budget is the

6 terminology that we use before the fiscal year

7 starts.

Page 126


CRYSTAL FOUCHARD

Page 127


CRYSTAL FOUCHARD

2 Q. And when did AllianceRx start up?

3 A. There may have been expenses associated

4 with it, but there wasn't, in this case,

5 direct-to-consumer marketing associated with

6 AllianceRx in fiscal '16.

7 Q. Do you know a date that AllianceRx started

8 up? Actual operations.

9 A. I don't.

10 Q. Do you have an estimate?

11 A. I don't want to guess.

12 Q. Well, you do know when a name was being

13 looked at; right?

14 A. I do.

15 Q. And when was that?

16 A. My involvement began at the end of

17 October of 2016.

18 Q. There was -- we saw earlier a search was

19 done in the end of November of that same year;

20 correct?

21 A. Yes.

22 Q. And there was a filing done to try to

23 protect that name; correct?

24 A. Yes.

25 Q. Are you aware of the status of that name?

Page 128


CRYSTAL FOUCHARD

1 A. I'm not aware of the legal status, no.

2 Q. Are you aware that a trademark has not yet

3 issued for that name?

4 A. I am not aware of the detail.

5 Q. You didn't know that.

10 Q. And AllianceRx would have started up

11 sometime during fiscal year '17?

12 A. I was not involved in the support of

13 AllianceRx Walgreens Prime. So I don't know for

14 sure when they started marketing support.

15 Q. But you do know it was operating at some

16 time during fiscal year '17; right?

17 A. That is my understanding.

18 Q. And, to your knowledge, if it was

19 operating -- well, when was fiscal year '16 run

20 from? From when to when?

21 A. From September 1 of 2016 to October --

22 sorry -- August 31 of 2016.

23 Q. So is it clear that AllianceRx was not yet

24 operating during fiscal year '16?

25 A. Yes.

Page 129


CRYSTAL FOUCHARD

21 Q. Are you involved at all with respect to

22 sales or promotions of AllianceRx products?

23 A. I am not.

24 Q. To your knowledge, does AllianceRx

25 Walgreens Prime have any mechanism in place to

Page 130


CRYSTAL FOUCHARD

1 alert anyone about if confusion is discovered as

2 between itself and any third party such as

3 Reliance Rx?

4 A. I am not aware.

5 Q. Earlier you testified on direct

6 examination by your counsel that you are not aware

7 of any confusion by -- involving AllianceRx and

8 Reliance Rx; correct?


10 Q. You would have no reason to learn of any

11 such confusion since you are not involved with

12 AllianceRx at all anyway; right?

13 A. Not in my course of business. That's

14 correct.

15 Q. So there could be significant confusion,

16 but it wouldn't enter your knowledge; correct?


18 question. Calls for speculation.


20 BY MR. KERMAN:

Page 131


CRYSTAL FOUCHARD

5 Q. And after that was done -- was that done

6 in November roughly?

7 A. Submitting the trademark?

8 Q. Yeah.

9 A. No, I don't think so. I think it was

10 later, but I don't exactly know when.

11 Q. Did you have continued involvement, or did

12 your involvement end after you transmitted the

13 search to legal?

14 A. I continued involvement in work on the

15 logo.

16 Q. What are you calling "the logo"?

17 A. The actual creative design of the name.

18 Q. So after it was selected -- AllianceRx

19 Walgreens + Prime which was the original selected

20 name; correct?

21 A. Correct.

22 Q. What work did you do on the logo?

23 A. There was actually work being done in

24 parallel. So even back in November, before there

25 was a final recommendation or selection, there was

Page 132


CRYSTAL FOUCHARD

1 work done on different logo designs.

2 Q. Was there ultimately one chosen or

3 multiple chosen for logos?

4 A. I think over the course of my involvement,

5 we narrowed it down. I don't know that I was still

6 involved -- I don't think I was still involved

7 when -- in terms of logo design in terms of a final

8 design.

9 Q. Did you get involved with anything

10 involving the colors used in Rx, for example?

11 A. There was some discussion with our design

12 team about the colors of, yes, the Rx.

13 Q. Did you get involved with them?

14 A. Did I get involved?

15 Yes. I was -- I was part of those

16 discussions. I was not involved in terms of a

17 final decision.

18 BY MR. KERMAN:

19 Q. You are aware of what the final decision

20 was?

21 A. No.

22 Q. Okay. Sitting here today, do you know

23 what colors are used in AllianceRx's trademark?

24 A. I'm familiar with general colors.

25 Q. What colors are used?

Page 133


CRYSTAL FOUCHARD

1 A. We have the Walgreens red, the Prime blue,

2 AllianceRx -- yeah, I guess when I was involved

3 was -- had blue, and then there was discussion

4 about melding the colors in the Rx, but I'm not

5 certain of the final.

6 Q. Your involvement with anything involving

7 AllianceRx ended then; correct?

8 A. Yes. At some point.

9 Q. Look at Exhibit A-70, please.

10 I apologize. Before you do that, you said

11 you had some initial involvement in talking about

12 colors but not the final decision; correct?


14 Q. Did you have any involvement in the

15 relative size that we talked about earlier of

16 AllianceRx being -- I think you used

17 "substantially" instead of "significantly" --

18 bigger than Walgreens + Prime. Did you have

19 personally any involvement in discussions about

20 that issue?

21 A. Yes.

22 In working with our design team, we looked

23 at a lot of different variations over the course of

24 exploration of order of the different elements of

25 the mark, as well as relative size of the elements.

Page 134


CRYSTAL FOUCHARD

1 Q. So relevant size would involve a ratio of

2 two sizes; correct?

3 A. My involvement, we never spoke

4 specifically about a ratio.

5 Q. Did you ever discuss numbers at all, that

6 one would be twice as big? One would be three

7 times as big? Anything like that?

8 A. I don't recall that.

9 Q. Did you ever use adjectives like I asked

10 you? So instead of accepting where I was trying to

11 force you to tell me how much you thought one was

12 bigger than the other, back when did you people

13 discuss how much bigger one should be than the

14 other?

15 A. The discussions that I was involved in

16 were, like, from an aesthetic standpoint of kind of

17 how it appears as a whole. So not necessarily that

18 Walgreens would be bigger than Prime or Prime would

19 be bigger than Walgreens, but AllianceRx Walgreens

20 Prime, as a whole, like, how does that look

21 esthetically. So should AllianceRx

22 Walgreens Prime -- you know, how does it -- how do

23 the different elements fit together visually?

24 Q. What was the discussion about AllianceRx

25 being bigger than Walgreens + Prime, as best as you

Page 135


CRYSTAL FOUCHARD

1 recall?


3 question.

4 THE WITNESS: I think that was just the way

5 that the logo development -- as the different

6 options were presented, that was the visual option.

7 BY MR. KERMAN:

8 Q. But you were part of those discussions,

9 were you not?

10 A. Yes.

11 Q. At those discussions, what was discussed

12 in terms of relative size?

13 A. I don't recall having a specific

14 discussion about, like, relative size of AllianceRx

15 and Walgreens.

16 Q. To your knowledge, why are they not the

17 same size?

18 A. From a logo development standpoint, we

19 looked at a lot of different options, and that's

20 where we netted out.

21 Q. Why?

22 A. Why?

23 I think visually that was the best option.

24 Q. Was it because the words that are bigger

25 are the core words?

Page 136


CRYSTAL FOUCHARD


2 question.

3 BY MR. KERMAN:

4 Q. Or the core name?

5 MS. MILLER: Same objection.

6 THE WITNESS: We did not have a discussion

7 about core words.

8 BY MR. KERMAN:

9 Q. Did you ever discuss using Walgreens Prime

10 the same size as AllianceRx?

11 A. I think we had different versions where

12 AllianceRx or where Walgreens and Prime may have

13 been the same size as AllianceRx.

14 Q. Why was that not selected?

15 A. Various reasons.

16 I think, esthetically, that is very big

17 and bulky from a logo standpoint, but we looked at

18 a lot of different options.

19 Q. Well, why would it be big and bulky if you

20 reduced the size of AllianceRx and increased the

21 size of Walgreens so that they were the same? It

22 could still be the same total size as the way it's

23 done now. It wouldn't be any bulkier.

24 A. I think your question was having Walgreens

25 and Prime and AllianceRx all the same size.

Page 137


CRYSTAL FOUCHARD

1 Q. I said was that considered, and you said

2 yes, but you decided not to do that.

3 And I asked why, and you said it would be

4 bulky or bulkier. I don't understand how that

5 would be bulkier.

6 You could fit both within -- if I gave you

7 dimensions and said, "Fit it within a two-inch-wide

8 by one-inch-high block, you could make them both

9 the same. How would that be any bulkier than

10 making AllianceRx big and Walgreens + Prime small

11 and fitting it in that exact box?

12 A. I'm sorry. I'm not tracking with your

13 example that you are envisioning.

14 Q. Okay. I'll go back to it.

15 You said that it was discussed, the

16 possibility of AllianceRx and Walgreens Prime,

17 instead of being how they are with AllianceRx being

18 substantially bigger, you discussed one possibility

19 was making them the same size; correct?

20 A. I don't know that we discussed it. It

21 was -- there were various options that our creative

22 team came up with.

23 Q. And that was one of them; correct?

24 You just said it was.

25 A. I recall -- I said I think there may have

Page 138


CRYSTAL FOUCHARD

1 been one where they were the same size.

2 MS. MILLER: Objection. Asked and answered.

3 BY MR. KERMAN:

4 Q. We are back to where we were.

5 And you said it was because it was too

6 bulky, and I don't understand how that makes it

7 bulky.

8 A. To have everything in the same size

9 creates a very large visual logo.

10 Q. Not if you make everything smaller. Equal

11 but smaller; right?

12 MS. MILLER: Objection. Argumentative.

13 BY MR. KERMAN:

14 Q. Well, your conclusion is factually wrong

15 is the problem. Making everything the same size

16 does not make the total size bigger. If you

17 reduce -- instead of using a 16 font and a 4 font

18 -- and I'm making those numbers up -- you use

19 an 8 font and an 8 font, it wouldn't be any bulkier

20 or bigger?

21 A. I don't think we looked at that option.


23 question.

24 BY MR. KERMAN:

25 Q. And I asked -- do you recall why?

Page 139


CRYSTAL FOUCHARD

1 A. I didn't direct the design team to look at

2 an 8 font and 8 font, for example, and the design

3 team didn't come back with that option.

4 Q. You said it was one of the choices. Was

5 it discussed?

6 A. You're saying "discussed." I don't

7 remember discussion about it. I said I think

8 I remember there may have been an option where they

9 were the same size. I don't know for sure.

10 Q. Was there any option, to your

11 recollection, where Walgreens + Prime was bigger

12 than AllianceRx?

13 A. Not that I recall.

14 Q. Now, if you would go to Exhibit 7, please.

15 If I recollect correctly, all of the

16 information and numbers on the left, they all

17 relate to distribution of the Walgreens circular;

18 correct?


20 Q. And the next exhibit, 71, is an example of

21 a circular; correct?

22 A. Yes, that's correct.

23 Q. Is this a photocopy of a web-based on

24 Internet accessed circular?

25 A. That's what it looks like to me based on

Page 140


CRYSTAL FOUCHARD

1 some of the examples that are included on the

2 subsequent pages.

3 Q. For example, when I occasionally get a

4 Walgreens circular in my Sunday newspaper, page 1

5 -- would look like this page 1, but I was trying to

6 figure out what page 2 is because I don't recall

7 seeing that in a hard copy. Is that correct that

8 this would only be digital and not hard copy?

9 It says, "To learn more, tap the box."

10 That wouldn't really work on a hard copy if

11 I tapped my circular.

12 A. I am not sure if the "Tap to Learn More"

13 shows up in the circular, but for certain this

14 would because of the interactivity of "Learn More."

15 Q. And the same happens with a couple of

16 other pages within this document. The type is

17 almost microscopic, but there is a "Learn to Watch"

18 with the picture of a dog; correct?

19 A. Oh, "Learn More. Tap to Watch"?

20 Q. Yes.

21 A. Yes.

22 Q. So that again. Okay.

23 Other than those additional pages,

24 generally -- well, and then there is one with a

25 woman and a child and a computer, "Find Care Now"

Page 141


CRYSTAL FOUCHARD

1 you talked about. That would only be in a digital

2 version; correct?

3 A. We have advertised "Find Care" in our

4 circular, but this example where you can see

5 "Find Services" that would be in a digital version.

6 Q. Now, when you put that in your circular,

7 it's a full page?

8 A. No.

9 Q. Because I get circulars and I've never

10 seen anything like that.

11 So it might be a little, small, part of

12 the page?

13 A. Yeah. We have different sizes, but I have

14 never seen a full page with something like this for

15 the printed circular.

16 Q. Third page from the back, where it says 65

17 on the top right, would that be an example of how

18 that other thing, "Find Care Now," might be

19 inserted into a written circular as a small part of

20 the page?

21 A. That's an example of how it could be, yes.

22 Q. And with no link or computer type feature;

23 correct?

24 A. We would probably include a URL in that

25 case.

Page 142


CRYSTAL FOUCHARD

1 Q. This entire circular, is there a single

2 reference to AllianceRx?

3 A. I did not look at every page, but I would

4 not expect there is a reference to AllianceRx.

5 Q. Why not?

6 A. I haven't seen AllianceRx advertised in

7 our circular that I'm aware of.

8 Q. Is there a reason for that?

9 A. It's not something that I've been part of

10 discussions.

11 Q. Do you know what submission or use of this

12 exhibit is supposed to portray or show?

13 A. I'm not sure of your question.

14 Could you repeat it?

15 Q. Do you know why this document is being

16 used here today? Walgreens has a circular. Is

17 that what you're showing?

18 A. This is an example of where the Walgreens

19 mark is used for consumer purposes.

20 Q. But not the AllianceRx Walgreens Prime

21 mark; correct?


23 Q. Is there a single product in here that

24 AllianceRx Walgreens Prime sells, to your

25 knowledge?

Page 143


CRYSTAL FOUCHARD

1 A. Product?

2 No, there is no product that I'm aware of

3 that they sell.

4 Q. Are there any pharmaceuticals at all other

5 than over-the-counter pharmaceuticals shown in this

6 document?

7 A. I don't think -- I did not look through it

8 all.

9 Q. Well, you are free to, if you want.

10 Have you ever seen pharmaceuticals

11 advertised in a circular unless they were

12 over-the-counter?

13 A. So, for example, we advertise our flu

14 shots, which are a prescription item. It's not a

15 pharmaceutical item. So that's an example. We are

16 talking about our pharmacy services but not

17 pharmaceutical products, as far as I know.

18 Q. It's not where -- I see on a page,

19 Prilosec, but that's over-the-counter?

20 A. That would be referencing Over the

21 Counter. We do advertise an Rx to OTC switch. So

22 we do make our consumers aware.

23 Q. But there is nothing that says, "You can

24 get your Lipitor here for 2.99 co-pay instead of

25 something else"?

Page 144


CRYSTAL FOUCHARD

1 A. We advertise general co-pay like the Med D

2 example.

3 Q. I'm talking -- that's why I used the word

4 "product."


6 Q. There is no advertisement of

7 pharmaceutical products; correct?


9 Q. And, therefore, if there is no

10 advertisement of pharmaceutical products --

11 excluding over-the-counter, so I don't have to say

12 it every time -- therefore, inherently, there is no

13 advertising of specialty pharmaceuticals; correct?

14 A. Of the products?

15 Q. Right.


17 Q. And you understand what specialty

18 pharmaceuticals are?

19 You don't have to give me the definition.

20 You generally understand what I'm talking

21 about?

22 A. Generally, yes.

23 Q. And, therefore, Exhibit A-70, about these

24 circulars that 71, to the extent that -- well,

25 strike that. I am going to start over.

Page 145


CRYSTAL FOUCHARD

1 Does 70 show how many people access the

2 circular online in any of these numbers?

3 A. Not that I see.

4 Q. Okay. So assuming 71 we're treating as a

5 circular you get in hard copy and print; right?

6 A. Yes.

7 Q. Because you said this is a digital

8 version, but it does -- as we see in 70, it goes

9 out to people; right?

10 A. Yes.

11 Q. And it's in the store; correct?

12 A. Yes.

13 Q. So to the extent 70 is referring to

14 documents like this, it has no relationship

15 whatsoever to any circular or advertising that

16 relates to AllianceRx Walgreens Prime's business;

17 correct?

18 A. Yes, correct.

19 Q. Yes, I'm correct. Thank you.

20 MS. MILLER: Larry, it's 1:15. Can we break

21 for lunch?

22 MR. KERMAN: If you want.

23 (A lunch break was taken.)

24 BY MR. KERMAN:

25 Q. If you'd look at Exhibit 72, please.

Page 146


CRYSTAL FOUCHARD

1 A. Okay.

2 Q. Is it fair to say you testified this is a

3 printout of Walgreens' LinkedIn page?

4 A. Yes.

5 Q. And like a web page, this is what you

6 would see on opening the page?

7 A. If you went to LinkedIn and searched

8 Walgreens, yes.

9 Q. There would presumably be more information

10 then what's shown on this. You could continue to

11 scroll down on LinkedIn?

12 A. It looks like it, yes.

13 Q. Does this have anything to do with

14 Reliance Rx Walgreens Prime?

15 A. No.

16 Q. Does the number of -- does AllianceRx

17 Walgreens Prime even have an Instagram -- or a

18 LinkedIn page? Excuse me.

19 A. I am not aware of that.

20 Q. You are not aware one way or the other, or

21 you believe they don't have one?

22 A. I don't know if they have one.

23 Q. Have you ever seen one?

24 A. I have not.

25 Q. Have you ever heard mention of one?

Page 147


CRYSTAL FOUCHARD

1 A. I have not.

2 Q. I think where you got the followers is in

3 kind of microscopic print on top, 338,000 and

4 change?

5 A. Yes, that's what I was reading.

6 Q. That would be with respect to followers of

7 Walgreens on LinkedIn?

8 A. That's likely what that represents, yes.

9 Q. It would have no bearing on whether anyone

10 follows AllianceRx Walgreens Prime; correct?

11 A. Correct.

12 Q. If you go to 73, please.

13 I believe you testified 73 is a printout

14 of the Walgreens YouTube home page?

15 A. Yes.

16 Q. On the first page, I believe it's showing

17 eight videos; is that correct or not?

18 A. Yes, that's what is being shown there.

19 Q. To your knowledge, is that all the videos

20 that are available on the Walgreens home page?

21 A. No. To my knowledge, this is only a

22 subset of videos available on the Walgreens YouTube

23 page.

24 Q. Below the name "Walgreens" -- well, it's

25 there twice, but there is a number of subscribers;

Page 148


CRYSTAL FOUCHARD

1 correct?

2 A. Yes.

3 Q. To your knowledge, that's people or

4 entities that subscribe to follow Walgreens on

5 YouTube?

6 A. Yes.

7 Q. And this document has nothing to do

8 whatsoever with AllianceRx Walgreens Prime; is that

9 correct?


11 Q. Do you know if AllianceRx has a YouTube

12 page or channel or whatever the appropriate word?

13 A. I am not aware if AllianceRx

14 Walgreens Prime has a YouTube page.

15 Q. You've never heard of or seen one?

16 A. I have not.

17 Q. Okay. Turn to 74, please.

18 Fair to say you said this was a printout

19 of a Walgreens Pinterest page?

20 A. Yes.

21 Q. I always say it wrong. I always want to

22 say "pin interest."

23 Below one of the Walgreens Ws in the word

24 Walgreens and to the right and above, there is a

25 checkmark. It says "10M plus monthly viewers." Do

Page 149


CRYSTAL FOUCHARD

1 you see that?

2 A. Yes.

3 Q. Would that be relayed to followers or

4 anything on Pinterest, if you know?

5 A. I'm not sure what that "10M plus monthly

6 viewers" represents.

7 Q. A viewer can be someone who doesn't

8 necessarily follow Walgreens on Pinterest, or do

9 those terms not apply on Pinterest?

10 A. I don't know if a viewer and follower are

11 the same thing.

12 Q. That's what I meant. Okay.

13 Do you know if the M stands for thousands?

14 A. I wasn't sure, so I didn't want to guess.

15 Q. To your knowledge, this applies to

16 Walgreens only and not to AllianceRx

17 Walgreens Prime?

18 A. Yes.

19 Q. Do you know if AllianceRx has its own

20 Pinterest page?

21 A. I am not aware if AllianceRx

22 Walgreens Prime has their own page.

23 Q. You are not aware one way or the other.

24 Or you don't believe they have one?

25 A. I am not aware that they have one.

Page 150


CRYSTAL FOUCHARD

1 Q. Have you ever seen or heard of them having

2 one?

3 A. I have not.

4 Q. At least insofar as this document shows,

5 it says -- well, actually, it says 50 boards. Do

6 you know what that means?

7 A. Each of these examples are generally

8 boards, so more like if you would have a board that

9 has multiple pins within that board related to that

10 topic.

11 Q. Do you know why this shows 9 boards, if 50

12 boards exist?

13 A. I do not know.

14 Q. Do you believe these 9 boards are

15 representative of the 50 boards that exist? Fairly

16 representative?

17 A. I am not aware of all the boards. So

18 I couldn't say that they are representative.

19 Q. To the extent that your company, through

20 its attorneys, is putting this document into use

21 here, at least five of the nine refer to beauty.

22 Some might be cut off.

23 Where it says "B-e-a" in the top middle

24 one, would you believe that would be

25 "New Year New Beauty"?

Page 151


CRYSTAL FOUCHARD

1 A. I do.

2 Q. So counting "New Year, New Beauty,"

3 "Holiday Beauty," "Fall Beauty," "Summer Beauty"

4 -- I guess you get all the seasons -- and

5 "Walgreens Beauty" on the second page, I described

6 those accurately?

7 A. Yes, in terms of reading the board titles.

8 Q. So they are not related to pharmaceuticals

9 at all; correct?

10 A. No, they are not related to

11 pharmaceuticals.

12 Q. Can you tell from "Feel More Like You," if

13 that relates to any sort of pharmacy, or what does

14 it relate to? It's too small for me to tell.

15 A. I'm familiar with the "Feel More Like You"

16 content, and that's related to our "Feel More Like

17 You" program where we have pharmacists and beauty

18 consultants who are specially trained to help

19 patients with the side effects of their treatment.

20 So this content is more focused on, like, skin care

21 and --

22 Q. Hair loss?

23 A. -- hair loss, yes.

24 Q. Nothing specifically about pharmaceuticals

25 mentioned there or shown there?

Page 152


CRYSTAL FOUCHARD

1 A. There might be something about side

2 effects of treatment and the side effects of

3 certain medications, but that's more related to

4 providing over-the-counter solutions for those side

5 effects.

6 Q. The "Cold & Flu Care," bottom left, none

7 of those are prescription medicines; correct?

8 A. No. It doesn't look like there is any

9 prescription medications.

10 Q. Looks like bottom middle is about, like,

11 lozenges and that kind of thing?

12 A. I can't tell for sure what all of the

13 packages represented are.

14 Q. Next page, photo cards is, obviously, not

15 related to pharmaceuticals; correct?

16 A. Correct.

17 Q. And "Grad Gifting" would not be related to

18 pharmaceuticals; correct?

19 A. Correct.

20 Q. And are you aware of any Pinterest board

21 that relates to Walgreens pharmaceuticals?

22 A. I am not.

23 Q. And, therefore, you are not aware of any

24 Walgreens board on Pinterest that relates to

25 specialty pharmacy; correct?

Page 153


CRYSTAL FOUCHARD

1 A. Correct.

2 Q. If you go to Exhibit 75.

3 Fair to say you described this as a

4 printout of the Walgreens' Instagram page?

5 A. Yes.

6 Q. Would that be -- would Instagram have a

7 home page of sorts or a personal page or home page?

8 A. Instagram as a platform or Walgreens.

9 Q. For Walgreens.

10 A. Yes, if you want --

11 Q. Go ahead.

12 A. Go to Instagram and type in "Walgreens."

13 Q. Instagram is -- for the most part, people

14 post photos?

15 A. Yes.

16 Q. And actually, top right, top middle,

17 little movie camera shown. That would be for

18 posting a video?

19 A. Top middle. I am not sure.

20 Q. With a checkbook or a calendar.

21 A. Oh, the little icon that's there?

22 Q. I don't know if it's an icon. Look at the

23 one to the right of that, top right, where there is

24 a clock or a watch.

25 A. Okay.

Page 154


CRYSTAL FOUCHARD

1 Q. Do you see in the top right of that

2 picture, there is a little symbol or a drawing?

3 Does that represent a video, to your knowledge?

4 A. Yes.

5 Q. So you can post photos or videos; correct?

6 A. Correct.

7 Q. And the only way you can really write

8 something is by writing it within the photo or

9 video?

10 A. You can do an Instagram post that has post

11 copy associated with it.

12 Q. "Post copy," meaning after the photo or of

13 the photo or what?

14 A. My experience, it comes after the photo.

15 Q. This document doesn't show any such thing;

16 correct?

17 A. It does not.

18 Q. Okay. Do any of these representations, as

19 shown on your page, relate in any way to

20 pharmaceutical sales of any kind?

21 A. No.

22 Q. Does anything in here relate to AllianceRx

23 Walgreens Prime?

24 A. No.

25 Q. Are you aware if anything concerning

Page 155


CRYSTAL FOUCHARD

1 AllianceRx Walgreens Prime is ever posted on

2 Walgreens Instagram page?


4 Q. And the same with documents we already

5 discussed. I think I forgot to ask you about the

6 last one on Pinterest. Are you aware of whether

7 Walgreens ever posts anything on behalf of

8 AllianceRx Walgreens Prime on its Pinterest page?


10 Q. Are you aware of whether AllianceRx

11 Walgreens Prime has a Pinterest page?

12 A. I am not.

13 Q. Are you aware of whether AllianceRx

14 Walgreens Prime has an Instagram page?

15 A. I am not.

16 Q. Have you ever seen a Pinterest page or an

17 Instagram page or heard of one for AllianceRx

18 Walgreens Prime?

19 A. I have not.

20 Q. 76, please.

21 This is a screenshot of Walgreens' home

22 page on Facebook?

23 A. Yes.

24 Q. Finally, I'm a little more familiar with

25 Facebook than some of these other things. So this

Page 156


CRYSTAL FOUCHARD

1 would be -- when you go to someone's, person or an

2 entity, Facebook page, you could, actually,

3 depending how many posts they have, you could

4 scroll and scroll forever, for a long time?

5 A. For a long time, yes.

6 Q. So how do you know -- was this just the

7 screenshot of the -- was this the first screenshot

8 that could be taken, and nobody scrolled further,

9 to your knowledge?

10 A. Yeah. I think it's representing what

11 shows up at the top of the page. So a section of

12 photos, a section of videos, and then, to your

13 point, it's cut off. So you can see on the second

14 page of it, it says "Posts," which is, I think,

15 what you're referring to in terms of you can scroll

16 and see multiple posts.

17 Q. Do you know why on page 2, it says "See

18 more Walgreens on Facebook. Log in or create an

19 account"? It looks like that is a printout that

20 was obtained without signing in to Facebook at all?

21 A. I'm not aware of what the printout is --

22 like what -- how somebody accessed the page or what

23 that's representing.

24 Q. To your knowledge, does Walgreens block

25 people who comment, if they do, negatively about

Page 157


CRYSTAL FOUCHARD

1 Walgreens on Facebook?

2 A. In my experience, we do not.

3 Q. How about on Twitter?

4 A. I'm not certain, but in my experience, we

5 do not.

6 Q. You are aware of the concept of blocking

7 that I'm referring to in social media?

8 A. Yes.

9 Q. The Walgreens Facebook page is

10 Walgreens-owned, and it does not relate in any way

11 to AllianceRx Walgreens Prime?


13 Q. Does AllianceRx Walgreens Prime ever get

14 their name put on Walgreens' Facebook page?

15 A. Not to my knowledge.

16 Q. To your knowledge, does AllianceRx

17 Walgreens Prime have its own Facebook page?


19 Q. Do you know why not?

20 A. No.

21 Q. As to any of the social media things we've

22 discussed, Exhibit 72 through 75 being LinkedIn,

23 YouTube, Pinterest, and Instagram, you have no

24 knowledge why AllianceRx doesn't get involved with

25 those?

Page 158


CRYSTAL FOUCHARD

1 MS. MILLER: Object to form.

2 BY MR. KERMAN:

3 Q. Assuming they don't -- based on your prior

4 testimony, to your knowledge, they don't do those.

5 Do you know why?

6 A. I'm not aware that they do. I am not

7 involved in their day-to-day operations.

8 Q. And assuming that they don't, do you know

9 why?

10 A. I'm not involved in their day-to-day.

11 Q. Exhibit 77, I believe you testified this

12 was out of a Walgreens web page; is that correct?

13 A. Yes, walgreens.com.

14 Q. Would this be the home page, or you can't

15 tell?

16 A. This looks to me to be the home page.

17 Q. To your knowledge, does AllianceRx --

18 well, strike that.

19 AllianceRx has its own separate website;

20 is that correct? Or you don't know?

21 A. I believe they do, but I don't know for

22 sure.

23 Q. Were you involved at all in the selection

24 of a web address for AllianceRx Walgreens Prime?

25 A. Yes.

Page 159


CRYSTAL FOUCHARD

1 Q. What was your involvement?

2 A. Working with our internal attorney,

3 Cary Pumphrey, as well as another Walgreens team

4 member, to look at ownership of various URLs and

5 availability of various URL.

6 Q. Who was that other person besides Cary?

7 A. I can't remember that person's name right

8 now.

9 Q. Do you remember if they worked for

10 Walgreens or worked for AllianceRx or worked for

11 someone else?

12 A. They worked for Walgreens.

13 Q. Male? Female? Do you know what

14 department?

15 A. I don't know.

16 Q. Do you know why they were participating in

17 this -- was it just you three?

18 A. It was generally just us three, yes.

19 Q. So Cary was involved because he was an

20 attorney?

21 A. I had been talking to him about pursuing

22 the name, and this was related to the name based on

23 what name we decided.

24 Q. Just trying to figure out the role of the

25 three of you. So you're from marketing from

Page 160


CRYSTAL FOUCHARD

1 Walgreens; correct?

2 A. Yes.

3 Q. Cary is an in-house attorney for

4 Walgreens; correct?

5 A. Yes.

6 Q. Any way to decide what this other third

7 person did as their normal job?

8 A. I don't know the normal job. I know his

9 role in this case was helping with exploration of

10 URL, domain names.

11 Q. Do you know if he was an attorney, or you

12 know he wasn't an attorney?

13 A. I don't think he was an attorney.

14 Q. Had you ever encountered working with him

15 before?

16 A. I have not.

17 Q. Have you ever encountered working with him

18 since?

19 A. No.

20 Q. So it was a one-time thing which is why

21 you don't recall --

22 A. Yes.

23 Q. -- about him?

24 A. Yes.

25 Q. Do you know what names were considered for

Page 161


CRYSTAL FOUCHARD

1 addresses or URLs, as you call them?

2 A. We actually did a search of a number of

3 different variations, including all of the elements

4 of the name. We looked at AllianceRx Walgreens

5 Prime, AllianceRx WP, AllianceRx, and then all of

6 those elements in various order. We may have done

7 searches earlier on other names, but I don't recall

8 that.

9 Q. To your recollection, when you do that

10 kind of search, do you have to individually input

11 each of those combinations? In other words, you

12 said "in different orders." Do you have to

13 manually type those in in a search, or will the

14 search consider that automatically? Scramble it

15 and tell you whether -- in other words, if there is

16 two words, A and B are the two words, will the

17 search automatically also search BA, or do you have

18 to enter that as a separate search?

19 A. Are you talking in looking at domain name

20 availability? That search?

21 Q. Yes.

22 A. I am not aware of the person whose name

23 I don't recall had to go about that search.

24 Q. Okay. So that's what that person was

25 doing? Specifically doing the search on the

Page 162


CRYSTAL FOUCHARD

1 computer somehow?

2 A. I'm not sure how he did it.

3 Q. Okay. To your knowledge, was AllianceRx

4 Walgreens + Prime actually searched of whether that

5 could be a URL?

6 A. I'm not sure if the "+" was included.

7 Q. That was going to be my next question.

8 Subtract the plus. But at the time you were doing

9 it -- at the time you were doing this URL search,

10 had they already decided to drop the "+" or not?

11 A. I don't recall. I am not sure.

12 Q. Okay. So don't jump to deleting the "+"

13 yet, and just answer whether you recall, yes or no,

14 that a search was done to see if a URL was

15 available for alliancerxwalgreensprime.com or

16 dot-net or dot-anything?

17 A. AllianceRx Walgreens Prime?

18 Q. With a plus symbol.

19 A. Oh, I do not recall.

20 Q. Do you recall if the same thing was done

21 without the plus symbol?

22 A. I don't recall if this was part of the

23 search for the domain name.

24 Q. You don't recall or it was?

25 A. I don't recall.

Page 163


CRYSTAL FOUCHARD

1 Q. So you can't recall, either with or

2 without the plus, whether they searched the full

3 name?

4 A. There was various conversations at various

5 stages of choosing the name. So in the initial

6 searches that I was working with Cary and the

7 person I don't recall if it was or not.

8 Q. Are you aware of what name was -- name for

9 a URL or what URL was ultimately chosen?


11 Q. Are you aware that the URL that was chosen

12 is part of every employee of AllianceRx's email?

13 That it, like, an initial, a surname @, and then

14 it's at the URL?

15 A. I was involved in early discussions about

16 what the employee email would be, but I'm not aware

17 where it landed.

18 Q. Is that how it's done at Walgreens where

19 you work?

20 A. How what is done?

21 Q. Email addresses of employees of Walgreens.

22 A. So my email address, which I think is

23 pretty consistent, is

24 [email protected].

25 Q. And walgreens.com is your company's URL;

Page 164


CRYSTAL FOUCHARD

1 right?

2 A. It is.

3 Q. So have you ever had reason to send or

4 receive an email with someone from AllianceRx?

5 A. Yes.

6 Q. Do you remember what their email addresses

7 were for any single employee?

8 A. I don't want to guess. I have something

9 in my head, but I'm not certain.

10 Q. What do you think is in your head?

11 A. At alliancerxwp.com.

12 Q. And I was going to tell you, if I told you

13 that, would you believe me. So do you know why

14 that was selected?

15 A. The finalization of the selection was

16 after I was involved.

17 Q. So, therefore, should I take that to be

18 you don't know why it was selected, or do you know?

19 A. I know some of the discussions about it,

20 but I don't know that a final -- the reasons for

21 the final decision.

22 Q. Well, tell me what discussions you know.

23 A. About just brevity in that instance.

24 Q. So all you know is that before the final

25 decision was made, there was a discussion of

Page 165


CRYSTAL FOUCHARD

1 brevity of the URL?

2 A. Yes. For the email you're talking about.

3 That's what I'm referring to.

4 Q. But the email, we've said, is synonymous

5 with the URL for the company's website?

6 A. You said that that was the same for

7 Walgreens in terms of walgreens.com and then on the

8 email in walgreens.com for our website. I am not

9 certain what their AllianceRx Walgreens com is.

10 Q. If I tell you -- well, when you put the

11 one with "WP," were you talking an email address or

12 a website?

13 A. I was talking email address. You had

14 asked if I emailed anybody.

15 Q. Trying to be precise.

16 If I told you that the web address for

17 AllianceRx Walgreens Prime is not

18 alliancerxwalgreensprime.com, it's

19 alliancerxwp.com, would you be surprised to learn

20 that, or did you learn that?

21 A. I wouldn't be surprised to learn that.

22 Q. Have you ever had occasion to go on their

23 website for any reason?

24 A. Not that I recall.

Page 166


CRYSTAL FOUCHARD

Page 167


CRYSTAL FOUCHARD

Page 168


CRYSTAL FOUCHARD

Page 169


CRYSTAL FOUCHARD

Page 170


CRYSTAL FOUCHARD

Page 171


CRYSTAL FOUCHARD

Page 172


CRYSTAL FOUCHARD

Page 173


CRYSTAL FOUCHARD

Page 174


CRYSTAL FOUCHARD

21 Q. So you don't know whether AllianceRx

22 administers pharmacy reimbursement programs?

23 A. I am not sure.

24 Q. So you really don't know much about the

25 business of AllianceRx other than it's just a

Page 175


CRYSTAL FOUCHARD

1 specialty pharmaceutical company, to your

2 knowledge?


4 THE WITNESS: I am not familiar with the

5 day-to-day works of the company.

6 BY MR. KERMAN:

7 Q. Okay. To the best of your knowledge,

8 sitting here today, what do you believe the

9 business of AllianceRx is?

10 A. AllianceRx is providing specialty pharmacy

11 drugs and services in terms of mail order

12 prescriptions and the central facility, like

13 central call services.

14 Q. Would other companies that provide

15 specialty pharmaceutical services be competitors of

16 Alliance?



Page 176


CRYSTAL FOUCHARD

Page 177


CRYSTAL FOUCHARD

Page 178


CRYSTAL FOUCHARD

Page 179


CRYSTAL FOUCHARD

15 Q. There was mention, including in that

16 exhibit, of all the Walgreens expenses and may have

17 been mentioned otherwise about TV advertising. Do

18 you remember some questions at least?

19 A. Yes.

20 Q. Do you know if AllianceRx Walgreens Prime

21 has ever done any TV advertising at all?

22 A. I do not know if they have.

23 Q. Have you personally ever seen a commercial

24 for AllianceRx Walgreens Prime?

25 A. I have not.

Page 180


CRYSTAL FOUCHARD

1 Q. Do you know if AllianceRx Walgreens Prime

2 does any radio advertising?

3 A. I do not, no.

4 Q. Have you ever personally seen -- strike

5 that.

6 Radio, have you ever personally heard a

7 commercial for AllianceRx Walgreens Prime on the

8 radio?

9 A. I have not.

10 Q. How about electronically on Spotify, any

11 other connection, Pandora, have you ever heard a

12 commercial for AllianceRx Walgreens Prime on any of

13 those?

14 A. On streaming audio?

15 Q. Yes.

16 A. No, I haven't.

17 Q. Are you aware they otherwise do it, and

18 you just may not have heard it?


20 Q. Have ever heard of or seen a banner ad for


22 A. I saw a banner ad example in the FY18

23 provider deck that we reviewed here.

24 Q. Have you ever seen one, actually, as the

25 ad? Not as a brochure that we may advertise this

Page 181


CRYSTAL FOUCHARD

1 way. Have you ever actually seen one in an ad on a

2 computer? An iPhone? An iPad? You know, any

3 other type of phone?

4 It doesn't have to be Apple products.

5 A. No, not as a consumer.

6 Q. On a web page ever where you are watching

7 one web page, not a Walgreens web page, you know,

8 you are Googling something, and you hit an article.

9 Have you ever seen an ad pop up for AllianceRx

10 Walgreens Prime?

11 A. Not as a consumer, no.

12 Q. You said Walgreens is sometimes heard of

13 in the newspaper or news, that it makes the news?

14 A. Yes.

15 Q. Right before you said it was one of the

16 most loved brands in America. That was according

17 to one survey?

18 A. Yes.

19 Q. Was it loved or most known, or did it

20 actually used the word "love"?

21 A. This one was "most loved."

22 Q. Do you know who did that study?

23 A. Morning Consult.

24 Q. Do you know what other companies she found

25 to be most loved as well?

Page 182


CRYSTAL FOUCHARD

1 A. There were a lot of companies. I don't

2 recall specific ones.

3 Q. How many is "a lot"?

4 A. Walgreens made it into the top 25. So

5 I know there were 25.

6 Q. Did AllianceRx make it onto that list, to

7 your knowledge?

8 A. Not to my knowledge.

9 Q. You heard of news of Walgreens this week

10 anywhere?

11 A. News of Walgreens?

12 Q. Yes.

13 A. Yes.

14 Q. What did you hear?

15 A. We had our earnings report this week.

16 Q. How did your stock do this week?

17 A. I haven't checked it today.

18 Q. Did you check it after Wednesday's close?

19 A. I checked it during the course of

20 Wednesday.

21 Q. Did you check it on Thursday to see how it

22 did on Wednesday at close?

23 A. I checked it during the course of

24 Thursday.

25 Q. Yeah. How did it do on Wednesday?

Page 183


CRYSTAL FOUCHARD

1 A. It was down.

2 Q. How much?

3 A. I can't remember the percentage.

4 Q. If I tell you 5.8 percent, does that ring

5 a bell?

6 A. I would believe you.

7 Q. And would that be attributable to sales

8 and earnings fell short of analysts' expectations?

9 Did you see that reported anywhere?

10 A. Yes. For the quarter, yes.

11 Q. So would that be good publicity with

12 respect to the Walgreens name and reputation?

13 A. I wouldn't call it good publicity.

14 Q. Would you call it bad?

15 A. In terms of financials, yeah.

16 Q. If you lose 6 percent of the business's

17 value in one day, that's almost unheard of;

18 correct?


20 THE WITNESS: I don't know about "unheard of."

21 BY MR. KERMAN:

22 Q. It's not good, though; right?

23 A. It's not good.

24 MR. KERMAN: I have nothing further.


Page 184


CRYSTAL FOUCHARD

1 REDIRECT EXAMINATION

2 BY MS. MILLER:

Page 185


CRYSTAL FOUCHARD

15 Again, this is a document that you had no

16 personal knowledge of yourself; correct?

17 A. Not prior to this case.

18 Q. Right.

19 Well, not prior to last week when you met

20 with your attorneys?


22 Q. Not when this case started; correct?


24 Q. And you didn't have this document when we

25 took your deposition in December of '18; correct?

Page 186


CRYSTAL FOUCHARD

1 A. Correct.

2 Q. So when you say "not prior to this case,"

3 you meant not prior to last Friday when you met

4 with your attorneys who showed you this document;

5 correct?

6 A. Correct.

7 Q. And they told you about this document?

8 A. They showed me this document.

9 Q. Did you tell them what's on this document?

10 A. Did I tell them what's on it?

11 Q. Yes.

12 A. I don't know what you mean by that.

13 Q. Well, you had never seen it before; right?

14 A. I never saw this particular document

15 before.

16 Q. And you didn't create it?


18 Q. And you didn't supply the information in

19 it; correct?


21 Q. And in a line-by-line item basis, you have

22 no idea what the source of this information is;

23 correct?

24 A. I have visibility to our marketing finance

25 forecast as part of my job.

Page 187


CRYSTAL FOUCHARD

1 Q. You told me that's the last line in this;

2 right?

3 A. No, I have the ability to different

4 channel spend as well.

5 Q. If we turn the page over again, would you

6 have any estimate of any specific line item, if

7 I were to ask you about it?

8 A. Not specific line item.

9 Q. So you'd have no way of knowing if any

10 specific line item was accurate or not; right?

11 A. In terms of the specific numbers?

12 Q. Right.

13 A. That's true. I have a general

14 understanding in terms of our TV spend being a big

15 portion of our spend.

16 Q. Okay. But if TV spend was 50 million and

17 radio spend was 25 million, and you reverse that to

18 TV being 25 and radio being 50, the totals would

19 still be the same; right?

20 A. Yes.

21 Q. And you said, "The totals appear to be

22 within a range that I'm familiar with," but you

23 wouldn't really know individual lines? If I said

24 to you how much was spent on email in each of those

25 years, would you have any idea?

Page 188


CRYSTAL FOUCHARD

1 A. No.

2 Q. Because we could play that game.

3 So you really have no knowledge of any of

4 the supporting information on here, and you're just

5 saying the totals seem reasonable; right?

6 A. I don't know what you mean by the

7 "supporting information."

8 Q. Every one of those line items that add up

9 to the total.

10 A. In terms of the numbers themselves?

11 Q. Yes.

12 A. I don't have visibility to those specific

13 numbers or haven't memorized those specific

14 numbers.

15 Q. Right.

16 And without even memorizing them, you

17 don't have visibility to them, as you say. So you

18 wouldn't know them or be familiar with them; right?

19 A. I have general exposure to what we spend

20 in different channels, but I haven't memorized the

21 numbers.

22 Q. And if you haven't memorized them, you

23 can't tell, by looking at this document, whether

24 those individual numbers are accurate or not;

25 right?

Page 189


CRYSTAL FOUCHARD

1 A. That's correct, not for all the individual

2 numbers.

3 Q. And even if every one of these is accurate

4 as to the amount of money that Walgreens spent,

5 none of it, as we've already said, relates to

6 AllianceRx in the slightest degree; correct?


8 MR. KERMAN: Nothing further.

9 RE-REDIRECT EXAMINATION

10 BY MS. MILLER:

11 Q. One more question.

12 These totals on the bottom of exhibit,

13 Applicant's Trial Exhibit 69, before you saw this

14 document, did you have a -- did you have personal

15 knowledge in your capacity as senior director of

16 Walgreens what the marketing spend was?

17 A. Yes.

18 Q. And did you rely on that knowledge when

19 you flipped the page over and testified about those

20 numbers?

21 A. Yes.

22 MS. MILLER: Nothing further.

23 MR. KERMAN: Nothing further either. Thank you

24 for your time and patience.

25 (Whereupon the proceedings concluded at 3:15 p.m.)

Page 190


CRYSTAL FOUCHARD

1 Veritext Legal Solutions

1100 Superior Ave

2 Suite 1820

Cleveland, Ohio 44114

3 Phone: 216-523-1313

4

January 23, 2020

5

To: Tamara A. Miller Esq.

6

Case Name: Speciality Pharmacy Management, LLC v. Walgreen Co.

7

Veritext Reference Number: 3830975

8

Witness: Crystal Fouchard Deposition Date: 1/10/2020

9

10 Dear Sir/Madam:

11

Enclosed please find a deposition transcript. Please have the witness

12

review the transcript and note any changes or corrections on the

13

included errata sheet, indicating the page, line number, change, and

14

the reason for the change. Have the witness’ signature notarized and

15

forward the completed page(s) back to us at the Production address

16 shown

17 above, or email to [email protected].

18

If the errata is not returned within thirty days of your receipt of

19

this letter, the reading and signing will be deemed waived.

20

21 Sincerely,

22 Production Department

23

24

25 NO NOTARY REQUIRED IN CA

Page 192


CRYSTAL FOUCHARD

&

& 2:4,12 8:9 40:5153:6

0

084-003999 1:23

1

1 18:14,15 93:18129:21 141:4,5

1,100 62:71-9-2010 92:31-9-2020 92:5,141/10/2020 192:8

193:3 194:310 1:16 191:12100 52:9 81:210m 70:5,6 149:25

150:51100 62:2 192:1117 5:1011:40 85:4,512 101:7 117:8,10

117:11,1512384 191:2414 54:18 123:22,23

124:3 125:6 129:8178:24

14150 2:914221-5430 2:515 3:10 37:5 55:12

55:23 56:18 59:6123:22 124:5129:8

150 14:515th 191:2116 3:13 123:15

124:7 127:14,22128:6 129:19,24130:1 139:17178:21 179:2,4,8180:8

17 57:24 123:15124:9 127:7129:11,16

18 18:11,13,1538:4 57:24 63:15114:19 115:12116:5,10,25 117:7120:1 123:16124:12 126:3,9180:3 185:7186:25

180 1:19 2:14173:3 191:12

182 179:161820 192:21846 171:7185 3:6186 3:7187 173:3189 3:819 62:22 63:1 81:2

171:71901 34:23,25197 63:3,5,71991 7:6 8:21993 8:41999 7:14 8:13 9:31:15 146:20

2

2 24:5 93:19 95:4141:6 157:17

2.99 144:2420 5:10 105:9

114:19 115:13116:3,3,7,13 117:1117:7,13,14124:20 193:16194:22 195:22

2001 9:7,192005 9:20

2008 10:112009 179:152010 10:16 86:11

178:2,3,9,13,242012 178:16,19,212013 179:2,4,8

180:3,82014 54:25 55:12

55:23 56:18 57:19123:21

2015 57:202016 27:13 31:23

37:9 57:16,24105:9 128:17129:21,22 185:22186:4

2017 18:15 37:23130:5 185:21186:4

2018 18:16 56:9,2361:23 85:23 88:21125:23,25,25

2019 89:42020 1:16 92:5

191:12,21 192:421 5:11 27:16

104:18 178:16,19216-523-1313

192:322 63:10,12,13,1423 192:42317 64:25 65:22318 65:1924 24:1025 124:20 183:4,5

188:17,1826 130:72645 2:827 5:1128 10:16 86:11

294,000 71:4294k 70:25

3

3 24:3 91:16 95:430 59:6 124:20

178:2,3,9,133012 90:431 3:16 18:16

129:22312 2:1532 62:9,11,24338,000 148:3338,453 67:83485 117:9,1235 171:12,24

174:14 176:20177:3,14 178:1,6179:22

36 3:193830975 192:7

193:2 194:2 195:2387 171:7 179:163:15 190:25

4

4 63:17 91:16 95:7139:17

4,228,900 72:114,472,488 72:844 171:12,24 177:8

177:23 178:12179:22

44114 192:248,300 68:104900 1:19 2:14

191:13

5

5 91:165.16.2018 5:35.8 184:4

[& - 5.8] Page 1


CRYSTAL FOUCHARD

50 79:25 151:5,11151:15 188:16,18

500 185:16,17500,000 124:13

185:15,16,1950931 104:1152 52:12 61:2553 61:16,235555 2:5566 126:10,11566,509,657

126:23566,509,657.52

185:9566,509,657.52.

38:8580,000 124:8

186:5581,000 127:8581,349,088 37:24

6

6 3:4 91:16 184:166.15.2018 5:660 3:22600,000 124:10

186:460601-6731 2:15607 127:20 130:3607,000 127:15607,630,537 37:8616-5600 2:15626-1564 2:664 4:365 142:166500 63:866 3:12 4:6 15:24

16:3 88:1567 3:15 4:9 16:13

16:17 88:18 94:1168 3:18 4:12 31:6

31:11 61:8 89:13

166:25 167:1569 3:21 36:14,18

61:8 90:8 121:25185:4 190:13

7

7 31:23 88:2397:14 140:14

7-8-2018-7-14-2...

4:370 3:24 4:15 60:17

60:21 61:6,6,790:16 134:9145:23 146:1,8,13

71 4:5,18 64:4,890:25 140:20145:24 146:4

716 2:6,972 4:8,21 66:18,22

91:16 146:25158:22

73 4:11 67:16,20148:12,13

74 4:14 23:8,1668:21,25 70:1771:14 72:25149:17

75 4:17 5:3 70:970:13,17 71:14154:2 158:22

76 4:20 71:6,1072:25 156:20

77 4:23 5:6 72:1672:21 92:23,24159:11

78 5:5 75:22 76:193:24

79 5:8 77:7,1194:6

8

8 139:19,19 140:2140:2

80 52:13834-9445 2:985 3:5 62:23 63:287/353,224 1:7

9

9 13:17,18 99:12151:11,14

9,000 40:390 13:17 79:6900 81:1391236453 1:5928 18:18930 20:23931 22:8933 23:18935 24:18937 25:13938 26:1 101:898 24:129:30 85:49:38 1:17 191:12

a

a.m. 1:17 191:12aarp 51:7,10,11,13

51:15abbreviated

171:11ability 50:16,25

96:23 188:3able 24:7 78:17

99:25 100:24102:19

absolutely 101:21acceptable 124:23accepting 135:10access 11:20 39:21

39:22 51:21 52:2

53:7,10 60:4100:23 146:1

accessed 140:24157:22

account 157:19accounted 125:19accounting 55:15

125:18accumulates 78:16accumulator 44:1accumulators

43:23accurate 32:23

37:13 38:2,11102:2 124:22185:10,25 188:10189:24 190:3

accurately 152:6acknowledge

193:11 194:16acquired 10:4

81:6,9acquisition 10:3acronym 18:5

48:5act 37:5,5,7

193:14 194:20action 50:12

191:16activate 54:22activated 102:15activation 40:10

100:22activations 36:24active 26:14,16,19

52:11 55:4actual 37:9,23

38:23 54:18 59:1984:1 128:8 132:2132:17 185:22,22

[50 - actual] Page 2


CRYSTAL FOUCHARD

actuals 37:7ad 20:16 21:9

22:17 23:4,2425:3,5,6,7 41:1842:12,12,14,15,1842:20 43:18 47:447:5,12 48:3 50:751:1 54:13 97:1697:19 98:8,11,1799:1,4,7,10,12100:1,2,4,11,19181:20,22,25182:1,9

add 111:24 113:9189:8

addition 48:659:18 62:4

additional 51:16112:22 113:9141:23

address 58:24159:24 164:22166:11,13,16192:15

addresses 162:1164:21 165:6

adherence 11:17adherent 11:18adjective 96:22

97:7,7adjectives 135:9administering

175:14administers

175:22administration

7:4admit 96:9adopts 30:10ads 11:1,2,2 20:15

21:24 22:6,10,11

23:2 26:22 35:1140:8,11 43:1344:17 47:7 48:1458:2 101:1

advance 106:11advantage 12:21adventure 59:25advertise 144:13

144:21 145:1181:25

advertised 142:3143:6 144:11

advertisement

44:12 145:6,10advertisements

44:23,25 48:2349:23 58:23

advertises 51:11advertising 9:14

9:15 12:12 47:2258:10,14 100:22101:9,14 102:11102:22 103:9,22145:13 146:15180:17,21 181:2

advice 35:17aesthetic 135:16affiliates 43:20,21affixed 193:15

194:21afternoon 85:21

85:22agencies 17:24,25

18:3 29:16agency 17:20,21

17:23 18:5,7,7,826:5 40:12,14

ago 11:10 107:3ahead 154:11aid 81:9,11 82:22

aisle 46:5alcohol 62:15,16

62:17alert 23:18,23

131:1algorithms 50:11aligned 115:25

116:2allay 116:21 117:1allayrx 116:21allergy 73:25alliance 3:17

34:13,14,16,17,1884:17 130:2 167:3170:17 173:6176:16

alliancerx 14:8,1214:15,22 15:8,1317:3 21:11,18,2022:2 23:1,5 26:2529:10,19 30:531:3 32:19 33:3,433:8,16,21 34:4,1184:3,13 86:16,2087:2,4 95:10,15,1895:24 103:15,19103:23 104:3,6,8104:12,16 106:18106:24 107:12,19107:24 111:5,7,10111:13,24 112:24113:14 117:25118:6,19,22119:18 121:17,21126:24 127:1,10127:19,24 128:2,6128:7 129:10,13129:23 130:6,10130:12,13,17,19130:22,24 131:7131:12 132:18

134:2,7,16 135:19135:21,24 136:14137:10,12,13,20137:25 138:10,16138:17 140:12143:2,4,6,20,24146:16 147:16148:10 149:8,11149:13 150:16,19150:21 155:22156:1,8,10,13,17158:11,13,16,24159:17,19,24160:10 162:4,5,5163:3,17 165:4166:9,17 170:23172:9 173:13175:8,10,17,21,25176:9,10 177:21179:9 180:11,20180:24 181:1,7,12181:21 182:9183:6 190:6

alliancerx's

133:23 164:12177:2

alliancerxwalgre...

163:15 166:18alliancerxwp.com

166:19alliancerxwp.com.

165:11allow 20:3allowed 96:25

178:21allows 66:4 69:22alyssa 13:21alyssa's 14:4america 75:13

182:16

[actuals - america] Page 3


CRYSTAL FOUCHARD

amore 1:23 191:3191:25

amount 38:16190:4

analysts 184:8animated 22:17answer 33:19 83:9

86:1 96:25,25113:18 163:13

answered 139:2answers 72:23

94:18anybody 107:12

166:14anyway 131:12apologize 134:10app 35:7 39:22

47:15,16,17,19,2147:24 55:6,765:22

appeal 1:2appear 22:12 23:1

42:3,5,6 46:2066:15 70:21 71:2381:3,16 82:893:17 101:13179:22 188:21193:11 194:15

appearances 2:1appeared 108:7appears 23:23

25:5 52:5 68:569:4 75:1 81:7105:4 135:17

appended 194:11194:18

apple 182:4applicable 23:4applicant 1:8 2:11

6:4,6

applicant's 3:103:13,16,19,22 4:34:6,9,12,15,18,215:3,6,10,11 15:2316:3,12,17 27:1631:5,10 36:13,1860:16,21 64:3,866:17,22 67:15,2068:20,25 70:8,1371:5,10 72:15,2075:21 76:1 77:677:11 185:4190:13

application 176:25177:2,5,21

applied 42:18applies 150:15apply 150:9applying 174:20appreciate 116:9approach 19:9,25

30:13appropriate

149:12approximately

8:12 9:5,7,1932:17,20 59:1130:7

april 102:12area 48:18 55:24

57:1,22 81:19,2582:3 118:12,14

areas 15:17,21argumentative

139:12arisen 84:2article 75:4 182:8articles 49:5 73:22

75:1asked 27:4 30:6

76:18 94:17 96:22

97:6 106:3 114:3114:9 124:25135:9 138:3 139:2139:25 166:14168:9,16,17185:14

asking 61:9 98:24121:23

aspects 103:13,14assets 35:1,3,5

68:1assignment 193:2

194:2 195:2assistance 20:2associate 8:11,14associated 15:4

42:16 47:11 52:1952:20,21,23 53:955:19,20 56:1359:18 127:23128:3,5 155:11

assortment 9:25assume 54:20

93:23 106:9127:22 168:1,1

assuming 87:7146:4 159:3,8

assumption 25:25126:1

attached 105:17194:7

attend 53:1 108:18attorney 96:10

120:11,13,19121:9,12,22 160:2160:20 161:3,11161:12,13

attorneys 94:14151:20 186:20187:4

attributable 184:7attributes 77:3audience 19:12

25:16,17 46:9,958:15,16

audience's 43:10audiences 30:14

30:16 103:7audio 46:23,24

47:1,2,4,5 54:24125:4 181:14

august 18:1626:17,19 128:1129:22 178:16,19

author 121:9authorize 194:11authors 76:18automatically

162:14,17availability 160:5

162:20available 13:4,13

39:15,19,20 53:557:13 60:11,1362:4,5,7 63:1764:17 65:21 66:369:14 73:22 74:6119:8 121:15148:20,22 163:15

ave 192:1avenue 1:19 2:14

191:13average 62:24avro 76:6,11award 75:18awards 75:8,10,14

75:17aware 12:20 18:3

30:13 63:20,2375:10 78:8 79:482:24 83:5,13,17

[amore - aware] Page 4


CRYSTAL FOUCHARD

84:1 99:6,24100:9 109:3118:16 120:4,19122:24 128:25129:1,2,4 131:4,6133:19 143:7144:2,22 145:5,8147:19,20 149:13150:21,23,25151:17 153:20,23155:25 156:3,6,9156:10,13 157:21158:6,18 159:6162:22 164:8,10164:11,16 168:15170:4,7 172:7,14174:14 181:17,19

awareness 5:476:24 77:3 78:478:10

b

b 151:23 162:16ba 162:17bachelor 7:3bachelor's 7:7back 41:23 48:21

69:19 77:4 85:12105:13 124:14132:24 135:12138:14 139:4140:3 142:16169:2 178:4192:15

bad 184:14badgering 96:11bags 80:16,18balance 51:14,16

51:18,19,20,2352:1,5,7,9 82:1282:16,19

ballpark 124:17band 89:14banner 20:15,16

22:10 23:2 40:840:11 99:12 100:1100:2,4 181:20,22

barber 28:8,9105:5,19 109:9

based 19:3 22:2224:4,8 28:2230:22 32:15,1662:19 75:15 80:1994:20 103:1,12108:6 123:14140:23,25 159:3160:22 169:7174:25 185:9,23

basically 18:2430:21 40:11 41:1442:25 43:25 66:4

basing 94:18basis 103:17

187:21bates 18:18 20:23

69:10,12 117:12171:5

bear 41:10 59:2465:12 81:21

bearing 148:9beauty 35:20 57:7

73:20 74:2,3,5151:21,25 152:2,3152:3,3,5,17

began 8:11 9:1010:14 54:23 56:6128:16

beginning 105:11116:11 177:13

begins 18:14behalf 2:2,11 6:3,5

6:7,9 16:9 127:9

127:19 156:7believe 59:23

111:2 115:12147:21 148:13,16150:24 151:14,24159:11,21 165:13168:3 176:8 177:6184:6 185:6,22186:4

bell 106:23 184:5benefit 51:15 52:2

84:22 175:2,16best 96:23 114:15

114:17 135:25136:23 176:7

beyond 84:23big 36:6 117:25

135:6,7 137:16,19138:10 188:14

bigger 95:25 96:296:4,16,20 97:1,997:12 134:18135:12,13,18,19135:25 136:24138:18 139:16,20140:11

billboard 44:1949:20

billboards 49:19billion 80:24 81:2

126:17bing 40:22bit 66:13black 61:20blank 57:16,19,24

125:14blanks 54:16

55:12,23 56:9,18block 138:8

157:24

blocking 158:6blood 36:9 191:16blue 61:15 134:1,3board 1:2 151:8,9

152:7 153:20,24boards 35:3 80:10

151:5,8,11,12,14151:15,17

body 109:1,12bold 116:21book 35:6 39:13

39:15 80:14boots 34:13bottom 21:9,10

23:24 25:3,7 37:164:20 65:4 90:593:18,18 95:897:19 108:2110:22 117:11126:8 153:6,10170:3 171:6190:12

box 61:15 138:11141:9 173:22174:3

brand 5:7 7:238:19,20 9:10,1213:22 17:3 20:923:18,23 30:1050:5 53:14,1556:22 57:2,465:15 75:18 77:177:3,25 78:3,10,2279:4

branded 35:25103:14

branding 21:7,2321:25 65:15,1695:9 104:15

brands 9:9,11 10:419:21 22:25 34:9

[aware - brands] Page 5


CRYSTAL FOUCHARD

75:12 182:16break 58:5,6 84:25

85:3,6,16 146:20146:23 184:25

breaking 85:5brevity 165:23

166:1bring 34:9 108:13bringing 49:9

55:20broad 19:11 46:9

58:14,16broadcast 59:16broader 15:10

19:11brochure 46:17

181:25brochures 46:21browser 100:17,18

100:20bucket 45:6 46:16

55:16,17budget 55:21

56:11,14 126:5building 45:1

167:11bulkier 137:23

138:4,5,9 139:19bulky 137:17,19

138:4 139:6,7bullet 20:18 23:6

25:16bunch 124:25bus 49:19business 6:11 7:3

7:12,23 9:1310:22 14:23,2517:10 32:23 83:1583:16 86:20131:13 146:16175:7,10,25 176:9

179:13business's 184:16businesses 11:14

12:3,8buy 45:24

c

c 21:5,25 22:3191:1,1

ca 192:25cable 58:19calendar 26:13

154:20call 13:6 15:2

25:21,22 28:1634:2 35:4 90:22105:6,20 106:1,5,7109:9 115:4,15162:1 176:13184:13,14

called 6:13 12:15callero 76:5,9calling 102:8

132:16calls 23:13 52:20

84:7 113:16131:18 172:16,21

camera 57:10154:17

cameron 29:5,23109:5,13,14110:15 118:25120:23

cameron's 113:2campaign 57:6

104:14campaigns 12:7

21:1 57:5 75:1594:22

cancer 12:1822:18

candy 35:22capabilities 54:10

57:23capacity 190:15card 52:2,5,12

82:16,19cards 153:14care 15:18 19:17

22:18 35:20 65:2165:23 141:25142:3,18 152:20153:6 175:2

carry 45:23 62:14cary 30:1,3,4

160:3,6,19 161:3164:6 168:6,16169:2,3,7,23 170:9176:24

case 13:4 21:2,322:16 32:4 54:2077:22 83:19,20,2586:6 102:16121:14 128:4142:25 161:9186:17,22 187:2192:6 193:3 194:3

cases 43:24 47:1749:14 125:8,9

categories 10:2335:19 36:12

categorized

125:16category 49:5

56:25cause 45:4 74:21cc 76:5 105:22celebrities 59:21

60:3celebrity 60:2center 46:5

central 14:23,2415:1,3 114:5,7,15114:17 176:12,13

cents 126:9,14ceo 106:22certain 12:3 23:12

53:24 54:12 78:14101:14 111:19112:4 116:5,6134:5 141:13153:3 158:4 165:9166:9

certainly 98:13certificate 194:11certification 193:1

194:1certify 191:5,15cetera 35:12cf 21:25 22:3chance 27:18change 99:9

126:10 127:8,15130:3,8 148:4192:13,14 194:8195:3

changes 192:12193:7 194:7,9

channel 3:1918:18,25 19:1,1,119:3 26:11,1339:5 51:2 54:2255:4 125:9,12149:12 188:4

channels 17:1518:23,24 19:1126:6,10 36:2438:25 42:13 43:743:9 46:24 47:3102:14 189:20

charity 45:8,2560:12

[brands - charity] Page 6


CRYSTAL FOUCHARD

chart 61:7,8 102:5102:7,8,13,19,20103:8,16,23 104:4

check 183:18,21checkbook 154:20checked 183:17,19

183:23checking 170:20

170:23checkmark 149:25checkout 51:24

52:3cheese 7:22chicago 1:20 2:15

191:13child 141:25children's 9:11,11

9:17choice 120:20

179:13choices 108:10

116:22 140:4choosing 164:5

180:12chose 125:11chosen 67:11

119:12,13 131:21131:24 133:2,3164:9,11

chronic 11:15circling 97:18circular 4:4 35:6

39:8,19 40:1761:2,18,23,25 62:562:7,11,16 64:1164:12,15 80:13,1390:25 91:6 140:17140:21,24 141:4141:11,13 142:4,6142:15,19 143:1,7143:16 144:11

146:2,5,15circulars 91:1,2

142:9 145:24circulation 63:12civil 193:5 194:5clarify 61:5 98:3clarkson 45:22clarkson's 54:5class 171:12,24

174:14 175:13176:21 177:3,8,23178:1,6,12 179:22

classes 174:15,20176:25

clear 24:6 36:1197:24 129:23186:11

cleveland 192:2click 24:4 50:7clicks 24:1 50:6clinics 66:3clock 154:24close 170:15

183:18,22closely 55:19

115:25 116:2closer 185:16,16cold 10:23 35:20

36:7 73:24 153:6collaborative

25:19collateral 46:18college 6:20 7:15colon 31:13 175:4colors 133:10,12

133:23,24,25134:4,12

column 20:6,1731:13 54:17 61:1495:4 103:18171:18 172:4

185:7columns 36:22

57:19 185:24com 166:9combination

19:16 33:5combinations

99:13 162:11combined 117:7

117:18come 77:4 78:25

85:12 114:11,15114:19 140:3169:1

comes 114:5155:14

comic 45:17comment 157:25commerce 73:13

178:2,7,12commercial

180:23 181:7,12commercials 59:2commission

193:19 194:25195:25

committee 108:8108:10,12,16131:22,24

communicate 32:764:16

communicated

32:13communicating

176:25communication

10:25 44:12176:24

communications

111:20 112:4118:17 120:18

community 13:714:20 72:4

companies 86:23176:14 182:24183:1

company 14:1434:10,13,14 57:386:9,25 100:21123:20 151:19167:7 170:5 172:9174:1 176:1,5

company's 93:3164:25 166:5

competitors 20:5176:15

complete 87:19completed 192:15component 47:11

116:12computer 93:5

100:5 141:25142:22 163:1167:20,21 182:2

concept 117:18158:6

concerned 103:21concerning 155:25conclude 18:16

103:17concluded 190:25conclusion 32:7,8

113:12 139:14conditions 11:15

11:16 12:3 21:421:24 22:4

conducts 32:6confusion 84:2,6

131:1,7,11,15conjunction 17:21

30:25

[chart - conjunction] Page 7


CRYSTAL FOUCHARD

connect 20:451:13

connection 87:1089:7 181:11

connects 34:15consider 29:5

30:14 82:25162:14

consideration

20:11 30:18,2034:12 120:5

considerations

33:25considered 29:15

108:10 116:15,17116:19,22 138:1161:25

considering 112:7179:12

consistent 164:23consult 75:11

182:23consultants 12:17

152:18consumables

35:21consumer 7:24 8:8

10:3,25 11:16,2012:2,24,24 14:1835:9 49:5 50:1278:13,17 80:2084:16,18 128:5143:19 182:5,11

consumers 11:2312:5,20 14:1720:10 48:18 49:1053:9 64:16 69:2378:21 79:4 144:22

contact 109:15,18110:14

contain 53:11contemporaneous

69:17content 21:16 49:1

49:2,3,9,13,1553:25 54:3,955:22,24 57:8,1857:21 69:22 73:1673:19,20,21 74:494:24 95:1 115:23152:16,20

contents 20:2422:9

context 28:21100:25

continue 147:10continued 132:11

132:14 175:13continues 93:18continuing 112:9contract 53:16conversation

28:22conversations

106:12 164:4converted 81:11

81:14converting 81:12copies 63:13,14,17copy 21:7 32:24

141:7,8,10 146:5155:11,12

core 112:11,17,23112:24 113:10,14113:20,21,22,24113:25 114:3,4,8114:12 136:25137:4,7

corner 44:16correct 58:4 59:11

86:11 87:3,4 89:4

89:5,9,23 91:1892:15 94:15,1695:5,6,10,21 97:597:10,17 99:5,14101:4,10,23102:22 103:24104:22 105:1,6,22105:23 106:14107:18 108:11,16108:19,20,23,24109:6,25 111:8,13111:14,25 112:18112:24 116:13118:1,4 119:21122:6,11,12,14,20123:1,7,12,12,23124:3,4,23,24125:17 126:15,18126:21 127:5,16127:17 128:20,23130:3,8,12,17131:8,9,14,16132:20,21 134:7134:12,13 135:2138:19,23 140:18140:19,21,22141:7,18 142:2,23143:21,22 145:7145:13,16 146:11146:17,18,19148:10,11,17149:1,9,10 152:9153:7,15,16,18,19153:25 154:1155:5,6,16 158:12159:12,20 161:1,4167:3,4,18,19170:1,17,24,25171:4 172:5,6173:6,7,10,11,13174:5 177:18

178:13,14 179:10179:11,13,14,23179:24 180:13184:18 185:12,25186:1,16,21,22,23186:25 187:1,5,6187:17,19,20,23190:1,6,7

corrected 127:21correcting 186:12corrections 192:12

194:17correctly 95:3

140:15 173:20corsearch 3:16corsearch.com

170:3cosmetics 35:21cost 42:11 174:24costs 55:18 56:13cough 10:23 35:19

36:7counsel 2:1 91:5

91:14,23 94:296:24 121:14122:11 131:6

counter 41:7,8144:5,12,19,21145:11 153:4

counting 111:1152:2

county 191:5193:10 194:15

couple 10:14141:15

coupons 39:1643:23 44:6,7 48:754:13 58:2

course 34:1 83:1589:8 122:15 126:4131:13 133:4

[connect - course] Page 8


CRYSTAL FOUCHARD

134:23 183:19,23court 16:2,16 31:9

36:17 60:20 64:766:21 67:19 68:2470:12 71:9 72:1977:10 193:7

cover 39:14crazy 85:4create 157:18

187:16created 21:6 86:24

123:6 125:24creates 139:9creating 63:13

123:5creative 13:22

18:7 21:3,7 22:2040:17 132:17138:21

cross 3:5 85:2,1185:19

crr 1:23 191:25crystal 1:13 3:3,11

6:12 191:6 192:8193:4,9 194:4,13195:20

crystal.fouchard

164:24csr 1:23 191:25curious 101:9custody 167:14custom 7:24customer 43:1

48:17 98:10cut 151:22 157:13cystic 21:5

d

d 3:1 11:20 58:1358:20,21 145:1

daily 86:20

damage 57:11dashboard 99:17data 78:16date 69:15 86:14

92:2 128:7 178:16179:8 180:1,2192:8 193:3,9,19194:3,13,25195:20,25

dated 92:14,17dates 178:5david 28:8,9,13,18

28:20 105:5day 12:9 45:7,9,15

45:16,18 46:3,559:11,15,15,1961:21 75:20 109:8159:7,7,10,10176:5,5 184:17191:21 193:16194:22 195:22

days 192:18dealt 101:18 110:7

110:9,10deanna 1:23 191:3

191:25dear 192:10deb 76:6,11december 10:16

85:23 86:11186:25

decide 161:6decided 138:2

160:23 163:10decision 33:12

133:17,19 134:12165:21,25 168:18168:19

decisions 102:21deck 115:2,3,4,9

115:16 116:16

120:4 181:23decks 120:3deed 193:14

194:20deemed 192:19deerfield 67:6

107:17,20,22167:8,10

definable 113:23define 114:4defined 10:8definition 114:3

145:19 174:19175:19

degree 6:25 7:2,57:7 117:22 190:6

deleting 163:12deliver 100:24delivered 24:9

63:16department

160:14 192:22depending 9:12

157:3deposition 3:10

16:7 86:4 87:6,1187:23 88:1,15,1689:16,19 90:2,11108:6 112:15120:9 186:25192:8,11 193:1,3194:1,3

depositions 86:5derives 116:19describe 96:14

173:25 175:7described 152:5

154:3describes 175:10description 4:2

5:2 175:5 177:10

descriptions

179:21design 132:17

133:7,8,11 134:22140:1,2 171:23172:12 174:5179:20

designs 133:1desire 55:18 56:12despite 123:9detail 129:4detailed 24:5details 112:7

121:3develop 12:7

42:11,13 49:3,4,7developed 55:7,8developing 9:13

17:14development 9:15

40:17 132:1 136:5136:18

diabetes 11:17difference 74:1different 9:14,16

9:23 14:16 15:1715:19,21 17:1518:23,24 19:921:4 26:5,10 29:629:17 33:24 34:935:5 36:22,2343:6,8,22 45:13,2145:22 47:23 48:1750:3 51:12,2254:6 55:14,1657:5 59:4,5,7,1759:20 60:1 62:1262:13,19,20 63:6,765:23 73:23 74:475:15 76:13 77:384:17 86:9 91:17

[course - different] Page 9


CRYSTAL FOUCHARD

102:14 115:14133:1 134:23,24135:23 136:5,19137:11,18 142:13162:3,12 167:11169:21 188:3189:20

differentiate 20:4differently 125:16

125:16digital 19:1,14,15

20:13,14 22:1026:7 35:11 40:540:10 42:12 47:1151:1 53:3,8 56:1756:19 73:13 98:14100:5,12,14,15,22103:4 141:8 142:1142:5 146:7167:21

digitally 56:20dimensions 138:7direct 11:16,23

12:2,5,24 14:17,1835:9 42:22,2343:1 128:5 131:5140:1

directly 168:8director 9:2,22

10:6,10,19 11:3,511:7,7,12 13:1537:18 63:19190:15

discount 51:17discounts 51:21discovered 131:1discovery 70:18discuss 135:5,13

137:9discussed 30:7

117:3,4 118:11

119:5,15,16121:19 136:11138:15,18,20140:5,6 156:5158:22

discusses 120:4discussing 120:20discussion 29:22

29:24,25 57:2261:12 75:5 110:4118:13,15 119:9133:11 134:3135:24 136:14137:6 140:7165:25 170:14

discussions 29:22120:10,22 121:1,6133:16 134:19135:15 136:8,11143:10 164:15165:19,22 168:6

disease 26:12dismissed 119:11dispensing 177:17display 19:14,15

20:13,14 26:6,7,1640:4 44:10,1146:4,6 103:18

displays 8:21 40:740:10 42:2 44:15

distinct 56:25distribution 52:14

140:17distributorship

174:23 177:18divisions 63:6dmas 63:5,5doctor 15:18document 16:5

17:6,7,9,12,2025:23 27:22,24

29:15,17 31:25,2536:19 39:16 50:1960:23 64:9 66:767:21 69:10,15,1871:11 76:16,17,2177:12,15,16,17,2077:21,23 87:2188:13 89:10,1290:3,4,12,22 91:1393:25 94:7,10,1494:19,23 95:1,797:14 100:5,5101:2,7,17,18103:5,12,23 104:2117:8,15 118:21119:23 120:6121:19 122:1125:24 127:2,11129:7 130:16141:16 143:15144:6 149:7 151:4151:20 155:15167:15 173:3186:15,24 187:4,7187:8,9,14 189:23190:14

documented 30:12168:12

documents 70:1787:10,16,18,22,2588:3,8 92:1994:22 114:21120:7,20,24,25146:14 156:4

dog 141:18doing 6:10 19:12

33:24 51:17 60:1162:25,25 163:8,9170:1 177:4

dollars 36:2138:23 40:23

126:17domain 161:10

162:19 163:23donation 45:25donations 46:2door 41:5 80:15dosage 74:14dot 163:16,16doubt 32:21 64:1

72:12download 47:18

47:21downloads 47:15

47:16 55:6,10drawing 155:2drawn 32:8drive 2:8drop 163:10drugs 12:25 15:5

22:3 176:11due 101:20duke 7:11duly 6:2,13 191:8dupage 191:5duties 7:21 9:8

10:20 106:5dwayne 81:6

82:21dynamic 56:20

62:13dynamics 50:4

e

e 3:1 151:23 191:1191:1

earlier 22:1140:16 45:11 55:1664:13 65:12 82:1199:9 104:9 109:23109:24 128:18131:5 134:15162:7 180:7,13

[different - earlier] Page 10


CRYSTAL FOUCHARD

185:6,23early 32:20 116:23

164:15 170:14earnings 52:20

75:6 183:15 184:8education 6:19 7:8

20:1 73:15educational 19:25effects 12:19

152:19 153:2,2,5efficient 10:1,2effort 25:19 28:19

51:13 130:14efforts 11:18

12:14 38:20 45:19ehr 24:18,20 26:7

103:19eight 59:4,7,8

148:17either 7:24 46:8,18

58:2 59:20 60:298:21 110:10115:7,22 116:7,12120:2 164:1 171:2190:23

electronic 24:2125:1 26:7,1899:13,18,21,23,25100:12 101:3

electronically

181:10elements 116:5,7

118:20 119:19134:24,25 135:23162:3,6

ellen 2:4 6:9email 5:3 23:19,25

24:7,9 27:25 28:228:4,7,13,17 29:2132:14,15 46:7,8,846:12 51:3 76:3,8

76:14 94:5 97:1697:23,25 98:5,8,998:11,15,17,1999:1,4,5,7,10105:15,19,21,25106:10,13 108:1109:1,5,13 110:23112:8,13,14 113:2115:1 120:7,10121:1,3,7,11,17,21122:23 164:12,16164:21,22 165:4,6166:2,4,8,11,13169:12 188:24192:17

emailed 166:14emails 87:20

104:19,23 105:10105:17 119:8121:8,13

emphasis 55:25employed 86:13employee 110:8

164:12,16 165:7employees 164:21employment 89:7

89:8 101:18,20122:13,15

employs 14:3enclosed 192:11encountered

161:14,17encourage 12:21ended 134:7ends 62:22 127:25engage 20:3,17

95:4engine 50:1,10engines 40:22enter 131:16

162:18

entered 194:9enterprise 9:24entire 14:6 81:12

101:17 143:1193:5 194:5

entities 149:4entitled 16:17

18:18 23:18entity 157:2entries 125:1environment

25:11 69:24100:15 101:6

environments

19:19envisioning

138:13equal 139:10equity 33:8 34:8

117:8,19equivalent 64:12errata 192:13,18

194:7,10,18 195:1esc 108:4,5esimpson 2:6esq 192:5esthetically

135:21 137:16estimate 128:10

188:6et 35:12event 45:16,18,18

52:24,25 53:163:12

exact 91:12 138:11exactly 50:14,19

54:15 55:8 121:2132:10 175:19

examination 3:2,43:5,6,7 6:15 85:19131:6 185:1 186:9

190:9 191:7,14examined 6:14example 9:17 12:8

12:12 19:10,1321:8 22:12 25:225:10 38:18 40:1540:16,25 41:16,1943:11 44:7,2446:5 47:13 49:450:8 54:4,17 55:255:17 56:10 57:957:14 58:12 62:1465:25 75:6,11125:5 133:10138:13 140:2,20141:3 142:4,17,21143:18 144:13,15145:2 181:22

examples 12:2217:14 21:4 35:1054:2 65:10 74:4141:1 151:7

excerpts 89:24excluding 145:11excuse 92:5

147:18executed 194:10execution 193:14

194:19executive 108:7,9

108:12 131:21,24exhibit 3:12,15,18

3:21,24 4:5,8,114:14,17,19,23 5:55:8,10,11 15:2416:3,13,17 27:1631:6,11 36:14,1858:9 60:17,2164:4,8 66:18,2267:16,20 68:21,2570:9,13,17 71:6,10

[earlier - exhibit] Page 11


CRYSTAL FOUCHARD

71:12 72:16,21,2472:25 75:22 76:177:7,11 88:2389:13 90:16 93:2494:6,11 117:13,14121:25 134:9140:14,20 143:12145:23 146:25154:2 158:22159:11 180:16185:4 190:12,13

exhibits 3:9 4:15:1,9 27:15,16105:12

exist 151:12,15existed 118:16expect 143:4expectations

184:8expenditures

87:21expenses 50:17

53:9 122:1,9128:3 180:16

experience 23:1225:2,4 30:2137:12,15,19 38:138:10 52:10 59:2574:22 78:9,2494:20 155:14158:2,4

expert 22:18expertise 19:16expiration 193:19

194:25 195:25explain 11:23 22:9

23:21 26:2 38:1347:15 51:7 102:19

explaining 122:5exploration

134:24 161:9

exposure 50:11189:19

extent 14:6,2099:8 145:24146:13 151:19

exterior 35:2,3extra 62:1 126:12

126:13eyes 95:14

f

f 191:1facebook 4:18

43:7,11 53:1966:11 71:16,19,2472:7,10 91:2292:11 156:22,25157:2,18,20 158:1158:9,14,17

facilitate 27:428:23,25 29:1,20

facility 107:19,21176:12

fact 95:3 167:1factors 34:6 38:17factually 139:14fair 111:8 147:2

149:18 154:3168:1

fairly 151:15fall 152:3familiar 17:5,7

22:4 57:25 76:1777:1 78:21 94:24101:15 102:4,10102:13,16 104:20112:12 114:20115:8,23 116:6,7116:16 123:17,22123:25 133:24152:15 156:24175:6 176:4

188:22 189:18familiarity 101:19family 12:10 45:11

45:12far 144:17 168:20

168:22fcst 38:5 185:7feature 62:16

142:22featuring 175:1feed 43:10feel 12:15 52:22

75:19 114:13152:12,15,16

feels 114:17fees 40:12,14,14fell 184:8female 160:13fibrosis 21:5field 174:24

175:15figure 85:7 141:6

160:24figures 63:20,23

63:25filed 178:23,24filing 30:9 128:22

132:2fill 79:18,20filled 80:17fills 80:23final 33:12 132:25

133:7,17,19 134:5134:12 165:20,21165:24

finalization

165:15finally 156:24finance 187:24financial 3:20 20:2

75:6 87:20

financials 52:20184:15

find 20:15 27:1627:18 65:21 73:674:11 141:25142:3,5,18 192:11

finding 100:22fine 98:25 186:12finish 111:22firm 120:15first 5:9 6:13 7:16

7:17 20:6,1822:17 25:16 39:554:7 61:15 83:2388:4,9,14,15,19,2389:15,20 90:10114:24 116:11122:7,8 148:16157:7 170:16174:22 177:25178:2,6,12 191:7

fiscal 18:11,12,1418:15 36:23,2537:5,9,23 38:454:18,24 56:2357:15 61:23 81:2123:15,20 125:25126:3,5,6,8 127:7127:14,22,24128:6 129:11,16129:19,24 130:1,5185:7,15,21,22

fit 135:23 138:6,7fitting 138:11five 58:5 95:8,12

95:13 104:9151:21

flip 185:13flipped 186:2

190:19

[exhibit - flipped] Page 12


CRYSTAL FOUCHARD

flow 102:5,7,8,13103:8,16

flowchart 26:2flu 58:12 101:10

144:13 153:6focus 11:13 14:18

14:22 15:17,2126:12 48:7,18,1955:24 57:1,22118:12,14 119:9119:17

focused 7:22 10:2112:2 22:18 31:3152:20

focusing 37:498:20

folks 9:16follow 24:9 67:2,3

67:11 68:8 72:972:11 149:4 150:8

followed 30:11follower 150:10followers 53:19,19

53:21 67:8 70:2571:4 148:2,6150:3

follows 6:14148:10

font 95:19 139:17139:17,19,19140:2,2

force 23:13,13135:11

forecast 38:6124:12 125:23126:2,9,23 185:7187:25

forecasted 127:1foregoing 193:13

194:18

foremost 54:7forever 157:4forgetting 126:9forgot 156:5form 25:8 28:15

29:2 32:10 33:637:14 47:8 63:2173:7 77:14 79:979:16,23 80:782:1 83:2 84:796:18 101:24103:25 107:5112:25 131:17136:2 137:1139:22 159:1167:20,21 176:3176:17 184:19

format 56:21formation 107:13formatting 53:7formed 110:11forth 29:6 191:7forum 53:2forward 111:20

112:10 192:15forwarded 28:17

115:2fouchard 1:13 3:3

3:12 6:12,1726:24 31:9,1558:8 167:25 168:2185:3 191:6 192:8193:4,9 194:4,13195:20

found 32:22182:24

foundation 12:1020:7 45:11,12

four 177:13,15free 12:10 85:14

144:9 193:14

194:20freestanding 48:8frequent 110:5friday 61:20 87:8

89:2 122:9 187:3front 27:15 32:22

41:5,7 64:10,18,2397:7,8 103:2

full 30:8,22 32:338:16,25 89:13142:7,14 164:2169:20,22,24

fully 81:14 112:20functionality 53:8functions 86:21fund 59:17funding 38:19

60:12fundraiser 45:18

45:24fuqua 7:12further 85:17

115:24 157:8184:24 186:7190:8,22,23191:15

fy 88:21fy14 3:21 54:22fy15 54:23fy17 5:6fy18 3:13,21 16:18

18:9 61:17 88:1088:22 181:22

g

g 45:12gain 28:19game 189:2gamut 11:1gastrointestinal

36:8

general 30:1346:16 49:2 74:16133:24 145:1168:13,14 174:19188:13 189:19

generally 17:2224:21 35:13 40:742:5,16 44:1651:6 58:14 60:963:20,22 79:583:17 99:23 114:1141:24 145:20,22151:7 160:18174:15,16,17175:9

generate 9:2560:11

generated 57:8getting 19:24 50:7gi 36:7gifting 153:17give 17:14 27:18

47:23 105:5,20,25109:9 114:22121:14 145:19186:8

given 19:14 34:886:5 169:9,11191:9

gives 67:25 73:1273:14

giving 53:7,9glucose 36:10go 6:20,22 12:24

33:13 47:20 69:1885:7 90:3 92:2493:24 97:14111:17,20 112:10138:14 140:14148:12 154:2,11154:12 157:1

[flow - go] Page 13


CRYSTAL FOUCHARD

162:23 166:22171:21 178:4

goes 30:19 42:2578:8 102:21 123:2146:8 173:25

going 17:15 22:1830:15 41:23 48:2149:10 59:24 63:1563:15 69:16 76:1580:2,3 85:22 98:7106:4,6 111:16,17111:22 145:25163:7 165:12

good 6:17 85:2185:21 111:2184:11,13,22,23

goods 35:13 79:7174:13 177:25

google 40:22googling 182:8grabowski 167:5grad 153:17graphical 49:8greatest 10:1gross 36:20 37:2,8

37:23 38:7,13,1538:16,18,21,24185:8

group 9:2,22 10:610:9 13:21,2514:4 15:10,16,2018:8 76:10 125:13

grouped 125:16groups 48:19guess 105:16

128:11 134:2150:14 152:4165:8 175:5

h

hair 152:22,23half 11:10 122:5

126:17hand 31:13 191:21handed 16:2,16

31:10 36:17 60:2064:7 66:21 67:1968:24 70:12 71:972:19 75:25 77:10122:22

handing 114:25happen 83:8happened 33:12

55:10happening 115:15happens 24:3

141:15hard 141:7,8,10

146:5head 165:9,10headline 52:18headquarters

107:17health 10:22 11:14

13:9 15:18 24:2225:1 26:8,1835:18,23 36:457:7 65:14 66:273:19 74:4 81:1781:20 99:13,18,2299:23 100:1,12,12100:14,15 101:3175:2,2,15

healthcare 15:20hear 47:9 83:10,23

183:14heard 14:8 23:11

24:16 147:25149:15 151:1156:17 181:6,11

181:18,20 182:12183:9

heartburn 36:8help 11:18 12:18

12:19 27:4 28:1828:22 40:16 73:2596:25 152:18

helped 17:2172:19

helping 161:9helps 50:10 53:6

114:24hep 21:5,25 22:3hereinbefore

191:7hereunto 191:20hi 76:14 111:1hidden 57:10hide 111:16high 50:5 79:5

138:8 174:24higher 79:6highlight 19:16

39:11 42:17 66:1highlighting 48:9

97:19highlights 61:2

66:2highway 49:21hit 85:21 182:8hiv 11:16 12:7,8,9

12:11 21:5 75:1975:20 101:13

holding 18:8holdings 106:18holiday 152:3home 45:10 49:17

49:18,23 63:15,1693:20 148:14,20154:7,7 156:21159:14,16

honest 116:8horizontal 22:13

22:21hospital 13:9host 52:25hour 122:5hours 24:10house 120:13,19

121:8,12 161:3huhs 86:1

i

icon 154:21,22idea 34:18,19

104:13 123:6187:22 188:25

idealawyers.com

2:6identical 115:13identification

15:25 16:14 25:1731:7 36:15 60:1864:5 66:19 67:1768:22 70:10 71:772:17 75:23 77:8

identified 25:1876:17

identify 25:20illinois 1:20 2:15

67:6 167:8 191:5191:13

imagery 21:6immediately

171:21immunizations

11:14important 34:18impossible 98:16

99:3,4improper 76:21incentivize 47:18

50:6

[go - incentivize] Page 14


CRYSTAL FOUCHARD

incentivizing

47:21inch 138:7,8

167:17include 12:6 34:7

39:1 42:10 43:1746:15,17 47:648:15,16 78:2092:23 142:24177:1

included 23:4 36:441:20,21 42:2243:12 48:24 49:1349:22 51:5 56:1475:3 104:15126:14 141:1163:6 192:13

includes 11:14,1918:7 45:6 104:2104:11 105:21

including 8:2011:15 21:14 35:16162:3 180:15

inclusion 31:4inclusive 72:25

104:5 130:19incorporated

194:12increased 137:20indicate 23:14indicated 167:11indicating 192:13indications 74:13individual 124:22

188:23 189:24190:1

individually

162:10influencer 53:14

53:15 56:22

influencers 57:2,457:6

infographic 49:8inform 19:24informal 170:8information 19:20

23:3 35:17 50:973:15 74:6,9,10,1681:19 123:2,4140:16 147:9187:18,22 189:4,7

infrequent 109:17infrequently

107:11,14 109:25infusion 174:25ingredients 74:12inherently 145:12initial 30:21

134:11 164:5,13169:23

initially 30:633:16,18,19

initials 39:12initiated 169:24initiative 17:16

19:4 59:15initiatives 9:24

10:24inject 98:11,15

99:1,7injectable 174:25input 162:10inputs 17:13insert 24:6 48:2,8inserted 100:13

142:19insight 55:17insights 56:10

76:10insofar 103:21

151:4

instagram 4:1543:7 53:18 66:1270:15,22 91:22147:17 154:4,6,8154:12,13 155:10156:2,14,17158:23

instance 165:23int'l 171:24integration 54:3integrations 45:21

53:25 54:6 57:1859:20 60:2,5

interacted 107:11107:13 109:20,24

interaction 30:2110:3,5

interactivity

141:14interest 149:22interested 96:15

103:22 191:17interior 35:4internal 52:14

160:2internally 27:5

29:4 33:25international

171:10,12 174:14174:15 176:21177:3,8,23 178:1,5178:12 179:22

internet 140:24interpretation

22:6investment 36:21

37:2,9,23 38:7,1438:15,21,22,24122:17 125:22185:8

involve 86:7 135:1involved 26:24

27:9,10 29:9,13,1834:10 78:2 129:12130:21 131:11133:6,6,9,13,14,16134:2 135:15158:24 159:7,10159:23 160:19164:15 165:16

involvement 27:3128:16 131:22132:11,12,14133:4 134:6,11,14134:19 135:3160:1 168:4,8

involves 117:21involving 131:7

133:10 134:6ipad 93:6 182:2iphone 182:2ipsos 76:12 77:2

78:6,8,12,16issue 131:23

134:20issued 129:3issues 26:22item 39:5 40:4

124:22 125:3,20144:14,15 187:21188:6,8,10

items 58:9 124:19189:8

ivc 39:5,12ivcs 41:23

j

james 28:16105:21 106:14108:22

january 1:1626:17 89:4 191:12

[incentivizing - january] Page 15


CRYSTAL FOUCHARD

191:21 192:4jeopardy 114:10jim 28:16,17 29:23

108:13 110:14120:22

job 7:16,17 8:1,3106:5 107:4,7123:15 161:7,8187:25

jobs 8:6joel 106:14,16,17

107:10 108:3,21108:22 109:6,17111:1

johnson 8:9,9joined 118:18

119:17joining 51:15joint 14:12 28:6,20

86:25 110:11journal 26:21journals 21:1,3

26:9 104:14julia 59:24july 179:2,4,8

180:8jump 163:12june 178:23,24

180:3juvo 116:12,12,15

116:18juvos 116:12,18juvosrx 116:13

k

kaiser 12:10 45:12karam 167:12kelly 45:22 54:5kerman 2:7,8 3:5

3:7 6:7,7 13:1725:8 27:18 28:1529:2 32:10 33:6

37:14 47:8 61:561:10 63:21 65:169:9,13,16 70:1671:12 72:23 73:776:15 77:14 79:979:16,23 80:1,782:1 83:2,9 84:784:12 85:3,9,12,2096:1,5,13,21 97:13102:1,6 104:7107:8 110:16113:4,17 131:20133:18 136:7137:3,8 139:3,13139:24 146:22,24159:2 172:18,22173:1 176:6,19184:21,24 185:13186:8,10 190:8,23

key 17:13kind 27:4 42:18

53:7,16 55:1956:20 57:6,1058:10 74:15135:16 148:3153:11 155:20162:10

knew 76:18,1998:10 172:20

know 13:14 14:2,414:15 15:6,616:22 17:2 18:2,618:10,12 20:3,1320:21 21:19 22:122:5,12 23:10,1523:22 24:20,2329:9 30:19,2431:2 32:15,1733:2,23 34:4,2136:19 37:5 38:539:6,12,23 42:12

43:15 44:22 45:1948:5 49:1 50:1552:4,8 53:2354:11,19 55:856:2,23 57:15,1957:24 59:1,1960:6 61:5 62:2364:9,22 66:2367:12,21,24 68:1268:15,17 69:170:7,14 71:11,1871:22 72:22 74:1774:25 75:7 76:2,776:9,11,24 77:1677:23 80:22,2581:21 82:5 83:1892:17,18,19,2295:5,15 96:698:21,25 100:25101:1,5,9,12102:20,21,24103:11 104:22106:21 107:3,4,7107:21 108:5109:1,19 110:21113:20 114:24115:5,8,10 116:18116:22 120:1121:1,2,4 123:8,11123:23,25 124:2,5124:7,9,11,19,21126:2 127:18128:7,12 129:5,13129:15 132:10133:5,22 135:22138:20 140:9143:11,15 144:17147:22 149:11150:4,10,13,19151:6,11,13154:22 157:6,17

158:19 159:5,8,20159:21 160:13,15160:16 161:8,8,11161:12,25 165:13165:18,18,19,20165:22,24 167:5167:12 168:20,22168:23 169:15170:2,9,12 172:14172:17,19,23175:21,24 177:20177:22 180:20,22181:1 182:2,7,22182:24 183:5184:20 187:12188:23 189:6,18

knowing 37:19188:9

knowledge 61:2261:24 64:24 86:1986:22 93:19 98:2499:6 101:21 123:3123:11,14 124:21127:4,6,12 129:6129:18 130:24131:16 136:16143:25 148:19,21149:3 150:15155:3 157:9,24158:15,16,24159:4,17 163:3169:1,3,13,16,20170:19 175:18176:2,7 179:9183:7,8 185:10,24186:16 189:3190:15,18

known 83:1 84:15174:10 182:19

knows 76:20

[january - knows] Page 16


CRYSTAL FOUCHARD

komen 45:12kraft 7:18,19 8:5kroeger 81:15,16

81:18,21

l

landed 164:17language 112:12

175:7large 139:9larger 95:19larry 2:7,8 6:7

146:20larrykermanlaw....

2:10latest 52:11 179:8launched 12:15

52:22laura 2:13 6:5

87:8laurin 167:5law 2:7 120:15lead 28:19,22leading 59:19learn 78:25 131:10

141:9,12,14,17,19166:19,20,21

leaves 112:23leaving 8:5led 54:8,8left 24:12 26:5

27:15 31:18 61:1597:16 140:16153:6 173:16,18

legal 29:25 30:1730:19 32:6,18,2433:11 62:13 129:1132:2,13 168:13192:1 195:1

letter 42:24192:19

letters 117:25118:10

leydig 2:12leydig.com 2:16

2:16liability 174:1life 49:9likelihood 84:5likes 111:7likewise 185:21limited 174:1line 57:25 124:19

124:22 125:20126:8 175:20187:21,21 188:1,6188:8,10 189:8192:13 194:7195:3

lines 125:14171:14 177:13,15188:23

link 142:22linkedin 4:6 66:24

66:25 67:2,11,1391:20 147:3,7,11147:18 148:7158:22

lipitor 144:24list 23:8,17 24:12

24:15 25:21,22,23183:6

listed 37:24 54:1854:25 56:23 61:15194:7,17

listen 47:1listening 46:25listing 26:11 194:7lists 26:10litigation 96:15

172:8

little 63:1 114:18127:23 142:11154:17,21 155:2156:24 179:25

lkerman 2:10llc 6:8 171:15

172:2 173:23192:6 193:3 194:3

local 13:6 14:2015:2 53:3 56:17

located 107:16167:9

location 107:24locations 15:2log 157:18logical 105:24

106:4logically 106:6,8logo 21:10,11

64:23 95:20 132:1132:15,16,22133:1,7 136:5,18137:17 139:9

logos 21:15 22:7133:3

long 8:3,22 9:1810:9 34:21 45:1967:12 68:12 71:18157:4,5

look 22:16 37:1338:2,10,21 72:374:16 87:16 88:1194:11 96:24100:13 104:18114:22 116:6,7117:1 126:8 134:9135:20 140:1141:5 143:3 144:7146:25 153:8154:22 160:4166:25 185:3,24

looked 87:18103:12 115:9128:13 134:22136:19 137:17139:21 162:4167:23

looking 19:20 20:620:17 25:13 26:128:1,18 37:2238:4 39:4 41:1754:24 56:6 65:1966:6 67:4 98:3,1099:20 101:3162:19 189:23

looks 19:14 22:1722:22 24:25 25:926:11,16,19,20,2136:20 54:14 62:2564:10 65:7 69:273:2 93:17 115:8115:23 140:25147:12 153:10157:19 159:16170:2

lose 184:16loss 152:22,23lot 48:16 51:11

53:18 73:22 115:8115:23 116:10118:18 134:23136:19 137:18183:1,3

love 182:20loved 75:12

182:16,19,21,25lower 124:13loyalty 51:19

82:14lozenges 153:11lschaefer 2:16

[komen - lschaefer] Page 17


CRYSTAL FOUCHARD

lunch 84:25 85:3,5146:21,23

m

m 2:13 150:13191:25

madam 192:10magazine 21:2

43:15,18magazines 26:8

43:16 51:12mail 13:13 14:21

14:23 15:4,442:22,23,25176:11

mailing 15:4main 2:5making 40:24

138:10,19 139:15139:18

male 160:13manage 74:14management 1:4

2:3 6:8,10 171:15172:2 173:23192:6 193:3 194:3

manager 8:11,149:1,6,18 28:1084:22

manner 79:7manually 162:13march 26:19

102:12mark 29:10 30:9

32:18 33:2,12,2134:5,21,24 35:1535:23 41:10,21,2442:3,6,20 43:12,1744:14,21,24 46:1146:20 47:6,1448:23 49:12,2251:4 52:4 53:11

60:5 64:19 65:1266:15 69:4 70:2171:23 76:25 77:580:3,9,10,18 81:381:7,22 83:184:14 118:20120:12 134:25143:19,21 170:17170:22 173:5179:23

marked 5:9 15:2416:3,13,17 31:6,1036:14,18 60:17,2164:4,8 66:18,2267:16,20 68:21,2570:9,13 71:6,1072:16,20 75:22,2577:7,11 185:4

market 11:2045:14

marketing 3:197:20,23 8:6,11,149:1,6,18 10:5,8,1910:24 11:3,6,2112:1,2,7,13 13:2314:2,6 15:7,10,1215:15 16:24 17:1117:16,17 24:2325:18,20 28:1135:8,9,9,10 36:2136:22,24 37:2,9,1937:23 38:7,14,1538:20,21,22,24,2539:2,4 41:2042:13 44:11 45:546:14 51:2 54:755:20,21 56:13,1456:15 63:19 66:774:24 75:17 87:2190:14 94:21103:22 104:5

122:17 123:13,21125:21 128:5129:14 130:14160:25 185:8,15187:24 190:16

markets 63:6,6,8,8marks 33:8 34:8

84:6 173:19174:11

marriage 191:17martin 29:16mass 19:10,11

58:11,14match 23:8,16

24:12,15 25:24115:22 177:13

material 82:2,595:23 108:23

materials 35:841:25 42:13 46:1449:9 80:13 81:782:9 119:7

mats 41:7matter 16:9

191:18maximize 9:25mayer 2:12mba 7:11,15 8:7mcneil 8:8 10:8mean 11:24 14:24

16:25 18:22 20:838:16 40:20 41:1343:20 48:1,1250:22 53:4 54:158:17 70:6 73:21115:25 174:15,17186:5 187:12189:6

meaning 20:1424:14 52:11 63:1584:18 155:12

meaningful 30:15means 18:10,11,20

19:11,21 20:9,2123:10,21 37:638:5,6,14 39:648:6 62:23 67:971:3 77:17 96:7113:20,24 115:5151:6

meant 40:13 41:246:7 89:20 95:5105:3 112:8150:12 186:6187:3

measurement

25:13measures 77:2mechanism

130:25med 11:20 58:13

58:20 145:1media 3:14 16:18

17:18,20,25 18:718:24 26:4,1452:25 66:8,10,1474:18 87:19 88:1088:22 91:18100:21 102:4,8,13104:5 158:7,21

mediacom 18:1medical 21:1

104:14medicare 58:21medication 11:19

20:2medications 153:3

153:9medicines 153:7meet 66:5 111:3meeting 90:18

91:4,13,23 93:13

[lunch - meeting] Page 18


CRYSTAL FOUCHARD

122:10,25meetings 108:18melding 134:4meltaways 9:17member 51:20

108:15 160:4members 51:14,14

51:15,23 52:7,1052:11 82:12,17

memorized 189:13189:20,22

memorizing

189:16memory 106:23mention 147:25

180:15mentioned 11:22

35:19 36:6 40:1542:3 45:11 58:859:10 82:16 84:20152:25 180:17

mentions 74:18message 24:5

41:20 43:1 46:1074:24

messages 59:5,7messaging 19:18

20:19 26:12 48:1051:2 100:24

messed 90:7messing 122:2met 87:8 92:12

94:1,7,14 186:19187:3

michigan 6:24microscopic

141:17 148:3middle 65:4

151:23 153:10154:16,19 171:9180:2

midsentence

111:21midweek 61:20midwest 192:17

195:1mike 76:5,9,14miller 2:12 3:4,6,8

6:3,3,16 13:1916:1,15 25:1227:21 29:8 31:832:12 33:10 36:1637:17 58:5,760:19 61:13 63:2464:6 65:2,3 66:2067:18 68:23 69:1269:14,19 70:1,1170:20 71:8,1772:18 73:4,875:24 76:23 77:977:18,19 79:10,2180:21 82:4 83:483:12 84:10,19,2585:6,10,14,1795:22 96:3,11,1897:11 101:24102:3 103:25107:5 110:12112:25 113:16131:17 136:2137:1,5 139:2,12139:22 146:20159:1 172:16,21172:24 176:3,17184:19 185:2186:7 190:10,22192:5

million 52:9,1363:12,13,14,15,17126:10,11 127:20130:3,7 185:16,17186:6 188:16,17

millions 186:12mind 19:13 20:7,9

20:22 114:5,7minute 58:5 107:2

166:25mishear 98:1misheard 61:6missed 83:9 108:2missing 125:1misspoke 185:20

186:13misunderstand

97:17mix 18:19 19:1

20:11mobile 23:24 35:7

44:10,11,13,15,1747:12,15,16,17,1947:24 55:5,7

modification

115:18modified 33:20moment 114:22momentum 29:18

30:4 118:18money 90:13

114:11 190:4monitors 36:10,10month 78:15

180:6,13monthly 26:21

39:16 70:5 149:25150:5

monument 35:4morning 6:17

75:11 87:9 122:7182:23

motrin 9:11movie 154:17mpp 101:15

102:17,23 103:18

multiple 13:217:23,25 93:20116:14 133:3151:9 157:16

myriad 12:14

n

n 3:1name 16:21 28:19

29:6 30:5,1431:16 43:3 44:547:2,9 70:2474:25 82:8 89:22108:10 110:4111:7,12,24 112:5112:11,23,24113:10,15 116:11118:7,20 119:12119:16,19,22,24120:2,5,11,21,23121:2,6,17 128:12128:23,25 129:3131:21,23,25132:17,20 137:4148:24 158:14160:7,22,22,23162:4,19,22163:23 164:3,5,8,8167:3 168:23179:12 180:12184:12 192:6193:3,4,15 194:3,4194:21

named 75:12105:4

names 29:14,1730:17,20 115:14119:15 161:10,25162:7 174:10

naming 28:5 108:4109:16 117:8,19119:10

[meeting - naming] Page 19


CRYSTAL FOUCHARD

narrowed 133:5national 12:9

75:20nationally 58:18natural 7:22nbc 45:17,20,22

59:12,14 60:2near 179:5necessarily 135:17

150:8need 9:13 49:5

65:24 66:1,5 86:288:16 113:18

needs 7:25negatively 157:25net 38:22 163:16netted 136:20network 58:18never 69:13 70:18

71:14 89:6,2591:21 94:13,19122:13 135:3142:9,14 149:15167:17 187:13,14

new 2:5,9 9:15,1612:15 14:14 23:730:10 33:9 34:1044:20 50:23 55:974:3 86:25,25125:9,12 151:25151:25 152:2,2174:1 179:13

newer 54:21 55:355:24 56:5 57:22

news 22:24 23:723:14,16 43:10111:2 182:13,13183:9,11

newsletters 51:12newspaper 48:7

48:14 75:1,3

141:4 182:13newspapers 39:20

62:6,8 63:16nine 13:16 151:21non 45:10normal 77:15 89:8

161:7,8normally 93:5north 1:19 2:14

191:12nose 45:7,9,15,16

45:24 46:3,559:11,15,15

noses 45:23 60:1060:13

notarized 192:14notary 191:4

192:25 193:10,18194:15,23 195:23

note 192:12notes 85:1notice 3:10 16:6

88:15november 31:23

32:20 128:19132:6,24 170:14

novo 117:2,2novorx 117:2novos 117:2npp 20:18 95:5number 4:2 5:2

10:1,2 34:6 37:1337:16 38:2 52:352:11 61:15,1762:2,9 63:3,1067:10 69:11,1278:14 117:9,12,16147:16 148:25162:2 176:20177:6,9 192:7,13

numbering 90:8171:5

numbers 5:461:14 72:13 76:2578:4 123:11124:16 126:13135:5 139:18140:16 146:2171:6 177:24188:11 189:10,13189:14,21,24190:2,20 194:7

nursing 22:2423:7,14,16

nuts 35:21

o

object 25:8 28:1529:2 32:10 33:637:14 47:8 63:2169:16 71:12 72:2372:24 73:7 76:1577:14 79:9,16,2380:7 82:1 83:284:7 96:18 101:24103:25 107:5112:25 131:17136:2 137:1139:22 159:1176:3,17 184:19

objecting 96:10objection 70:16

84:12,12 95:2296:3,11 97:11102:3 110:12113:16 137:5139:2,12 172:16172:21,24

objective 19:3objectives 94:23

103:2,3

obtain 39:18obtained 157:20obtaining 12:25obviously 153:14occasion 166:22occasionally 141:3oconor 28:17

29:23 105:21106:14 108:22110:14,18,19,22

october 27:11105:9 127:25128:17 129:21178:21

offer 12:10,2413:9 14:17 21:2022:2 35:14 43:2456:19

offered 11:2312:16 21:17 103:6

offering 20:10offers 39:9,10,11

61:3office 1:1offices 2:7official 193:15

194:21offset 38:18,20

54:14oftentimes 41:17oh 27:13 141:19

154:21 163:19177:16 178:8

ohio 192:2okay 9:3 11:6 15:6

15:22 17:23 19:522:25 24:3 27:1427:20 30:2 32:441:23 49:12 55:559:1 61:4 62:964:18 65:19 75:7

[narrowed - okay] Page 20


CRYSTAL FOUCHARD

76:4 77:4,23 78:278:24 79:22 83:2184:20 85:6,9 86:286:3 87:13 89:489:11,17,24 90:3,792:1 93:24 94:1296:9,14 97:498:20 102:10109:12 110:17112:9 113:20114:18 115:5,12116:25 117:24118:9 119:22120:8,16 122:10122:19 126:12130:1 133:22138:14 141:22146:4 147:1149:17 150:12154:25 155:18162:24 163:3,12169:16 170:8171:8 173:4 176:7178:8 179:17185:5,18,21188:16

oldest 108:1olig 29:5,23

109:13,14,18110:3,5,15,18,20110:21 111:6

once 52:12 61:1885:23 86:4,6116:17 131:21186:13

oncology 11:1712:6,14 21:5,8,1021:20 22:24 23:623:14,16 101:13

ones 92:21 114:13183:2

ongoing 78:13online 19:22 20:15

35:25 39:8 40:4,741:13,14,19 42:2,948:19 53:5,10,1154:17,20 69:1574:8 78:15 146:2

opening 147:6operating 129:15

129:19,24 130:2,6operations 25:20

128:8 159:7179:10 180:11

opinion 84:5,9113:3,6,7,13,14169:5,6,7,9

opportunity 20:473:12,15 100:11111:3

opposed 50:18opposer 1:5 2:2

6:8,10opposition 1:4optical 65:25 66:1optimization 50:2

50:10optimizing 50:11option 44:3 111:4

111:9 136:6,23139:21 140:3,8,10

options 29:6 117:8117:19 136:6,19137:18 138:21

oral 36:11 174:25orally 169:9order 100:4

134:24 162:6176:11

ordered 31:19,2032:24 175:1

ordering 168:4,8orders 162:12organization 12:1

15:11organizations

45:10original 132:19otc 144:21outcome 191:18outline 5:8outreach 78:13outside 80:8,9,15owned 19:20

158:10ownership 160:4

173:19 174:11

p

p.m. 190:25packages 153:13pad 52:3page 4:2,12,15,18

5:2,9 18:17,1820:25 22:8,9,14,1622:23 48:9 64:1064:18,23 65:1,1965:20 66:24,2567:22,24 68:4,9,1369:3,8 70:2,3,1570:22 71:16,19,2472:6,7,10 90:492:1,11,25 93:1893:19,20 95:4,797:14 99:12 101:7101:7,21 103:20104:9,11 117:6,8117:10,11,15,16117:24 118:21119:2 122:1,6,7,13123:18 124:14141:4,5,6 142:7,12142:14,16,20

143:3 144:18147:3,5,6,18148:14,16,20,23149:12,14,19150:20,22 152:5153:14 154:4,7,7,7155:19 156:2,8,11156:14,16,17,22157:2,11,14,17,22158:9,14,17159:12,14,16171:7,7,9 173:3174:7 177:7 179:5179:5,15,16 180:2180:4 182:6,7,7188:5 190:19192:13,15 194:7195:3

pages 66:14 90:191:16 92:8,1093:21 116:11,13141:2,16,23167:23 180:7

paid 26:14 40:1940:21,25 43:5,653:25 57:18

pain 10:23 11:1735:19 36:7

pandora 46:25181:11

paper 185:14186:2

papers 48:3167:18

parade 48:1,2,4,22paragraph 110:25parallel 132:24parent 34:12,14part 8:8 16:24

18:1 25:1 30:6,1634:14 44:3 45:9

[okay - part] Page 21


CRYSTAL FOUCHARD

58:21 76:11 77:2184:14 100:14105:1 109:15112:5,11,14,23113:10 116:17117:5 118:7,13,15119:7,9 120:10121:7 123:15130:10 133:15136:8 142:11,19143:9 154:13163:22 164:12168:11,14 175:12187:25 194:9

participate 38:1946:2

participating

125:12 160:16particular 8:23

40:9 102:16 104:4111:4 122:18187:14

particularly 84:15parties 40:15

43:21,22 47:18,2049:3,7 52:25191:11,16

partner 18:1,545:25 49:3 59:1460:10 100:25101:5

partners 8:1915:19 17:21 46:247:10 66:2 83:16100:23

partnership 12:917:19 34:19,2045:7,8,16 51:1059:12,13 75:2081:15

partnerships

34:17 45:4,10,1359:21

party 25:6,10 44:145:14 53:6,1576:12 83:18 96:15131:2 169:25

patent 1:1path 69:15patience 190:24patient 43:1 99:16

99:22patients 11:18

12:18 13:11 84:23152:19

pay 40:15 41:2043:9 47:17 100:6100:8,19 144:24145:1

payor 15:11,14,1915:19 35:10

payors 84:24pays 58:22people 13:14,16

19:21 23:15 24:424:8 28:24 29:129:13 43:24 47:2350:7 67:1,10 72:672:8,9,11 73:5,573:13,25 76:7105:22,22 135:12146:1,9 149:3154:13 157:25

people's 39:1pepcid 9:10percent 23:8,16

24:12 79:6 184:4184:16

percentage 78:2179:3 184:3

performance 75:6period 52:13peripherally 83:7

83:10person 28:22 32:9

80:2,3 99:20110:7,9,10 157:1160:6 161:7162:22,24 164:7172:19

person's 160:7personal 35:20

37:15 52:10 61:2261:24 81:13123:14 127:4,6,12154:7 185:9,23186:16 190:14

personalized

19:17personally 22:5

84:1 94:25 95:14121:5 123:11134:19 180:23181:4,6 193:11194:15

perspective 53:2175:15,17 84:16

pfizer 10:3pfp 48:1,5,10,22pharma 19:20pharmaceutical

144:15,17 145:7145:10 155:20176:1,15

pharmaceuticals

12:23 13:4 21:21144:4,5,10 145:13145:18 152:8,11152:24 153:15,18153:21 174:25175:1,15

pharmacies 13:714:20 81:10,1183:6,14

pharmacists 12:17152:17

pharmacy 1:3 2:26:8,10 11:13,15,2212:4 13:8,8,1114:14,17 35:1641:6,8 80:1681:19,25 82:2,783:16 84:22 87:187:2 106:18144:16 152:13153:25 171:15,23172:1,2 173:23174:4,23 175:14175:22 176:10179:19 192:6193:3 194:3

phone 44:13 47:1352:3 93:6 97:19182:3 192:3

photo 36:2 57:11153:14 155:8,12155:13,14

photocopy 140:23photos 95:8

154:14 155:5157:12

phrase 111:19112:1,3,22 113:9118:25

physical 35:1107:23

physically 167:14pick 74:11picture 57:9 97:16

141:18 155:2piece 14:21 22:20

33:9

[part - piece] Page 22


CRYSTAL FOUCHARD

pile 122:3piles 122:2pin 52:3 149:22pins 151:9pinterest 4:12

43:8 66:13 69:2,869:24 70:3 91:21149:19 150:4,8,9150:20 153:20,24156:6,8,11,16158:23

place 10:13 30:1144:23 47:2 130:25

placed 48:3 101:2placement 25:10

43:9places 80:19placing 67:25plan 3:14 16:18

17:11,14 25:1487:19 88:10,2294:22 175:3,16

plans 17:18platform 53:17

154:8play 189:2plaza 2:13please 27:19 65:1

85:24,25 88:1290:3 94:11 123:18134:9 140:14146:25 148:12149:17 156:20192:11,11

plus 33:21,23 34:3121:18 149:25150:5 163:8,18,21164:2

point 29:11 33:1186:25 97:9 111:11111:23 134:8

157:13points 43:24 51:22pop 182:9pops 114:7popular 125:6portion 12:1 14:23

14:24 95:24 104:4188:15

portions 103:3portray 143:12position 8:22,23possibilities

116:23possibility 138:16

138:18post 69:22 154:14

155:5,10,10,12postcard 42:24posted 156:1poster 41:6posters 41:6 80:15posting 154:18posts 156:7 157:3

157:14,16potential 120:20potentially 125:14powerpoint 115:6

115:17,20pr 18:8 75:14precise 166:15preliminary 30:7preparation 77:22

87:11 88:5,9,20,2589:1 90:11,17120:9

prepare 85:2,1387:6 94:2,8

preparing 85:1093:14

prescribers 25:21

prescription 24:1958:22 74:11,1580:16,17 144:14153:7,9

prescriptions

13:12 35:17 74:774:8,10 79:18,2080:22 176:12

presence 19:2324:19

present 191:11presentation

115:6,17presented 21:16

136:6president 13:22

106:17 107:2press 47:25 48:11

48:12,22 52:19,23pressure 36:10presumably 147:9presume 120:17pretty 46:16 98:22

101:8 164:23previous 89:16,19

108:6previously 5:9

72:20prilosec 144:19primarily 29:23

110:13primary 109:15prime 14:9,12,13

14:16,22 15:8,1317:3 21:12,18,2022:2 23:1,5 26:2527:6 28:6,20 29:529:11 30:6 31:433:4,7,17,22 34:134:4,8,20 84:3,1384:14,16,21,22

86:17,24 87:595:10,20 103:15104:3,6,12,16106:19,24 109:14109:15 110:9,14111:7,19 112:1,22113:9 117:22118:10,19,23119:1,6,18 121:17121:21 127:24129:13 130:14,20130:25 132:19134:1,18 135:18135:18,20,22,25137:9,12,25138:10,16 140:11143:20,24 147:14147:17 148:10149:8,14 150:17150:22 155:23156:1,8,11,14,18158:11,13,17159:24 162:5163:4,17 166:17170:23 171:1173:9 175:8,11,18177:22 179:10180:20,24 181:1,7181:12,21 182:10

prime's 29:1686:20 146:16

print 3:22 9:1411:1 12:12 20:121:1,2,9,9,24 22:626:8,20,22 35:1142:12 46:18 50:1350:14,16 56:161:1 93:21 102:25103:1,5,19 104:10104:14 146:5148:3

[pile - print] Page 23


CRYSTAL FOUCHARD

printed 39:8,1562:5,6 80:13 93:993:15 98:13142:15

printout 4:7,10,2170:2 92:2,10,2493:19 147:3148:13 149:18154:4 157:19,21

printouts 91:1893:11

prior 87:23 88:190:2 91:13 108:11159:3 172:7186:17,19 187:2,3

priorities 111:3private 120:15privileged 120:17

169:14probably 8:23

19:22 54:21 59:489:14 142:24

problem 139:15186:13

procedure 193:5194:5

proceedings

190:25process 29:1,13

30:11,12,16,2581:11 117:5168:12,13,14

produce 121:13produced 61:18

69:13,17 70:1871:15 73:1 120:16121:15,19 169:14169:15

producing 121:16product 9:2,15,22

42:16,17,19 50:9

143:23 144:1,2145:4

production 42:1042:11 192:15,17192:22

products 8:8 9:1610:4,6,9 35:18,2435:24 36:1,551:21 57:13 65:565:11,14 73:1379:15,17,19 81:1681:18,20 130:22144:17 145:7,10145:14 182:4

professional 15:18professionals

13:24 14:3profit 45:10program 3:23

12:15 51:20,2552:21,22 54:675:19 82:14152:17

programming

40:5,9 58:1959:17 60:3 95:11

programs 175:14175:22

progress 81:12promo 54:10

57:23promote 14:21

53:1 55:9promotional 54:13

58:2promotions 51:22

64:17 130:22properties 45:22proposed 21:9protect 128:23

protecting 57:12protection 57:13provide 20:1

73:15 101:6176:14

provider 3:1315:11,14,17 16:1816:24 18:2 23:1725:4 35:9 66:487:19 88:10,2299:17 100:3,6,8181:23

providers 23:1265:23 84:24 103:6175:2

providing 153:4176:10

provision 175:1proximity 170:12prudential 2:13public 52:16,17

56:12 191:4193:10,18 194:15194:23 195:23

publications 26:23publicity 184:11

184:13publicly 69:14published 26:21

178:15,17,18pulled 56:24pumphrey 30:1,3

160:3 168:6172:14

purchase 50:860:11,13 73:13

purpose 20:1221:14 64:15 67:2369:7 73:10 174:24

purposes 123:5143:19

pursuing 30:22160:21

put 17:11,18 29:640:23 48:8 55:2574:23 78:16 96:2297:6,7 98:8 100:4100:11 116:25142:6 158:14166:10

putting 40:17151:20

q

q're 5:7quarter 184:10question 69:9

77:15 79:11 89:1196:19 101:25102:18 104:1107:6 113:1,18114:23 120:24123:9 131:18136:3 137:2,24139:23 143:13163:7 190:11

questionnaire

77:25 78:19questions 6:19

78:18 85:18,22,2494:17 127:14180:18 186:7

quite 114:13quote 111:18

r

r 191:1r&d 9:16radio 11:1 18:25

35:11 42:7 47:1181:2,6,8 188:17188:18

[printed - radio] Page 24


CRYSTAL FOUCHARD

raine 13:21raising 59:17ran 61:18,23,25

63:7range 36:6 37:16

52:18 62:22123:16 124:23188:22

ratio 135:1,4rationalization

9:24reaching 19:10reacting 74:23read 69:19,21

95:14 105:25106:4,6,11 110:25112:20 177:11,12193:5,6,12 194:5,6194:17

reader 35:3 80:10reading 76:16

111:8 148:5 152:7173:19 192:19

really 14:19,2144:17,17 56:2,2098:4 112:7 141:10155:7 175:24188:23 189:3

reason 19:1232:21 64:1 72:12109:2 126:14131:10 143:8165:3 166:23185:18 192:14194:8 195:3

reasonable 123:10189:5

reasonably 37:1338:2,11 185:10,25

reasons 71:1372:25 137:15

165:20recall 27:8 91:8,10

91:12 93:15 106:2108:11 115:7116:2,14,15 119:7121:11,20,24123:16 135:8136:1,13 138:25139:25 140:13141:6 161:21162:7,23 163:11163:13,19,20,22163:24,25 164:1,7166:24 177:5,24183:2

receipt 192:18receive 6:25 7:5

98:12 121:5 165:4received 32:14

115:9receiving 91:10

105:8,10recipient 28:2

104:25 121:9recipients 76:19recollect 95:3

105:8 121:16140:15

recollection

140:11 162:9recommend

112:10,21recommendation

27:6 29:7 108:14109:16 131:25132:25

recommending

113:8record 24:22 25:1

26:8,18 61:11,1269:20 99:13,18,22

99:23 100:1,12,12100:14,15 101:3191:9 194:9

records 32:2357:16

recross 3:7 186:9red 45:7,9,15,16

45:23,24 46:3,559:11,15,15 60:1060:13 64:19 67:468:5 72:1 117:25118:1 134:1

redacted 109:2,3redirect 3:6,8

185:1 190:9reduce 139:17reduced 137:20reed 81:6 82:21refer 18:23 39:13

41:4 151:21reference 31:12,13

34:16 48:13 58:2060:9 61:16 62:362:10 63:4,1165:20 104:3,8143:2,4 167:25171:10 173:9192:7 193:2 194:2

referenced 25:2329:21 121:22177:3 193:11194:15

references 19:920:18

referencing 37:7118:24 144:20

referred 5:9 61:686:23,24 99:12

referring 21:222:11 23:24 49:1852:15 146:13

157:15 158:7166:3 168:2

refill 74:8,15reflected 29:16

56:13refresh 106:23regarded 120:17registered 171:19

172:5,10 179:2180:2

regularly 17:1830:11

regulation 62:21reimbursement

175:22relate 82:6 140:17

152:14 155:19,22158:10

related 7:24 8:610:5,24 34:1149:5 55:7 68:273:19,20 151:9152:8,10,16 153:3153:15,17 160:22172:1 174:18191:15

relates 146:16152:13 153:21,24190:5

relations 52:16,1756:8,12

relationship

146:14relative 134:15,25

136:12,14relatively 50:23

55:9 75:18 95:24relayed 150:3releases 52:19,23relevant 17:13

21:17 30:15 40:24

[raine - relevant] Page 25


CRYSTAL FOUCHARD

43:10 46:10 69:23103:7 135:1

reliance 6:1183:22,24 84:2,18131:3,8 147:14171:10,22 172:10172:11 173:15,17174:4 177:3179:19

relief 36:8 45:17rely 171:23 172:12

174:5 179:20190:18

remain 19:13remarketing

50:21,23 56:3,4remember 105:10

115:1,15,16,19116:1 117:3118:11 119:5,14119:15,16 140:7,8160:7,9 165:6177:9 180:18184:3

remove 33:20 34:3removed 33:23

65:18 109:2,4repeat 65:1 143:14repeated 117:16rephrase 77:18

85:25 109:23report 3:16 13:15

13:20 32:16,2251:8 78:17 87:20174:7 183:15

reported 1:22184:9

reporter 16:2,1631:9 36:17 60:2064:7 66:21 67:1968:24 70:12 71:9

72:19 77:10 191:3193:7

repository 67:25represent 36:22

36:23 38:23 48:4102:14 115:12155:3

representation

49:8 104:10 122:8122:18

representations

155:18representative

17:12 63:5 151:15151:16,18

represented 24:250:18 101:13103:5 130:15153:13

representing

24:25 26:22 41:1543:6 55:14 61:192:10 157:10,23

represents 34:1834:19 38:24 50:20103:18 148:8150:6 169:25

reputation 184:12request 32:25

194:9,11requested 32:9,18

168:7requesting 168:21

174:21required 192:25requirements

62:13requires 62:21research 7:20,24

7:25,25 48:15,1648:17,17,18 55:11

55:13,14,15,2056:11 76:13

researcher 76:12resolution 28:19

29:21resource 28:18resources 14:6

15:1,3respect 70:16

71:14 87:2 109:21110:2 130:21148:6 167:2 172:9179:18 184:12

respects 101:20respond 49:11response 78:18responsibilities

8:17 9:12,23 10:6responsibility

11:20 94:25result 32:3 46:3

55:19results 78:25

169:3retail 8:19 10:22

13:3,5 14:1915:13 35:18 67:6

retailmenot 43:2244:2

returned 192:18revenues 80:25reverse 188:17review 27:6 30:17

32:6,8,18 33:1185:1 87:10 169:23192:12 193:1194:1

reviewed 26:9,18181:23

reviewing 30:19

reviews 33:25reward 51:23 52:1

82:16,19rewards 51:14,16

51:18,19,20,2552:5,7,9 82:12

rick 16:21,22 17:2right 11:13 13:16

19:3 31:13 42:1858:3 67:4 72:391:1 92:9 93:395:14 96:2 98:1798:21 100:10,24106:7 107:1109:10 111:15112:16 113:5,10113:15 117:11,12119:3 122:25125:7,18 127:2,3128:13 129:16131:12 139:11142:17 145:15146:5,9 149:24154:16,23,23155:1 160:7 165:1170:16 171:3,17173:16 174:13178:9,23 179:7180:3 182:15184:22 185:11186:18 187:13188:2,10,12,19189:5,15,18,25

ring 106:23 184:4rite 81:9,11 82:22roberts 59:24role 7:21 8:16,18

9:8 10:20,2113:15 37:18 63:2283:5 160:24 161:9

[relevant - role] Page 26


CRYSTAL FOUCHARD

room 41:7 80:1685:14

rop 48:1,11roto 3:23 39:5,7

39:18,19,23,2541:23 53:3,5,5,1053:11 56:17 61:164:12,15 90:22

roughly 132:6180:6

row 37:1 39:4rows 36:23 54:16royalties 51:7rpr 1:23 191:25rubber 89:14rules 193:5 194:5run 47:25 48:11

48:12,21 100:1,2100:19 102:12,22129:19

running 63:13runs 10:25rx 3:17 6:11 83:22

83:24 84:2 131:3131:8 133:10,12134:4 144:21147:14 167:3170:17 171:10,22172:10,11 173:6173:15,17 174:4179:19

s

s 116:18 192:15194:8,8 195:3

salaries 39:1sale 42:17sales 10:1 23:13,13

25:20,21 81:1130:22 155:20184:7

save 114:18savings 35:6 39:13

80:14saw 77:21 88:19

88:23 89:6,15,2089:25 90:10 91:691:24,24 92:1093:25 94:7 112:14115:7,21 116:17118:3 122:6,8,13128:18 167:17169:3 181:22187:14 190:13

saying 19:12 20:162:6 63:7 97:3105:20 111:7,23112:21 113:8124:17 140:6189:5

says 18:9 24:1125:19 31:13 37:838:5 39:14 65:1767:5,6 68:10 70:570:25 72:3 99:16105:5 106:4 108:3108:21 111:2,9,18112:3,3,10 117:7117:11,24 118:9141:9 142:16144:23 149:25151:5,5,23 157:14157:17 167:25170:3 171:7,15,17171:18,19,22172:4 173:5,15,18173:22 174:3,22175:13 178:1,6,24179:15

schaefer 2:13 6:56:5

school 7:12scope 10:7scott 76:5scramble 162:14screen 23:25 24:25

93:6,6,6 97:2099:20

screenshot 156:21157:7,7

script 64:19 68:572:1

scroll 147:11157:4,4,15

scrolled 157:8seal 193:15 194:21search 3:16 30:7,8

30:22,23 31:3,1931:20 32:3,22,2434:1 40:19,21,2241:1 50:1,3,6,7,966:4 87:19 89:13118:3 128:18132:13 162:2,10162:13,14,17,17162:18,20,23,25163:9,14,23 167:2168:5,7,10,14,21169:1,4,8,21,22,24169:25 170:1,8,11170:13,13,19172:8 173:5,12174:18

searched 31:233:2,9 118:4147:7 163:4 164:2

searches 30:2440:25 44:2 162:7164:6 169:17,18169:20 170:5

searching 19:2240:23 50:4 68:1

seasonally 101:10seasons 152:4second 18:17

22:19 23:6 41:1859:6,6 92:1 152:5157:13 186:8

section 48:6101:15 102:23103:5 157:11,12

sections 102:24see 16:6,19 20:18

21:8,25 22:1823:6,19 24:1131:12,14,18 37:137:10,24 38:842:15,18 46:447:12 49:20 57:1064:18 65:4 70:2480:3,6 85:1 88:889:17,24 90:16,1790:20 91:4,2293:5,13 94:195:11 97:21 99:1899:21,22,25 109:6119:22 120:2121:4 122:7124:14 142:4144:18 146:3,8147:6 150:1 155:1157:13,16,17163:14 167:20171:9,12,13,14,16171:17,20,22,25172:3 176:23178:17,24 179:3,6183:21 184:9

seeing 91:12 93:15101:22,22 115:19141:7

seek 7:8

[room - seek] Page 27


CRYSTAL FOUCHARD

seen 27:22 32:437:16 50:25 77:1277:16,20 88:3,1789:21 90:25 91:292:8 93:2,9,1194:4,9,13,19105:13 120:8122:17 142:10,14143:6 144:10147:23 149:15151:1 156:16174:7 176:20180:23 181:4,20181:24 182:1,9187:13

selected 34:5118:7 132:18,19137:14 165:14,18

selection 26:2529:10,12 30:2589:22 120:11132:25 159:23165:15

sell 62:17 79:14,1579:17,19 144:3

sells 143:24semi 175:4semicolon 175:12send 28:13 42:23

98:11 165:3sending 46:8 51:3senior 11:5,7,12

13:15 37:18 63:19190:15

sense 61:25sent 24:9 28:7,17

28:20 39:24 76:898:8 122:22

sentence 111:12111:14

sentences 111:6,17seo 49:25 50:1separate 48:9

55:17 56:11159:19 162:18

separating 82:21september 18:14

18:15 129:21178:2,3,9,13

sequential 20:19serial 1:6series 104:23serlin 16:22,22serve 51:1served 25:3service 12:16,20

65:21services 13:10

15:4 35:14,1636:2 79:8 82:7142:5 144:16171:23 172:11174:4,13,23,23175:14 176:11,13176:15 178:1179:19

set 103:1 191:7,20shampoo 35:21share 73:16shared 30:4sharing 74:22sheet 123:3,5,7

192:13 194:7,10194:18 195:1

shelf 42:15,19sheridan 2:8shop 53:3 56:17shoplocal 53:6shopping 80:20short 58:6 85:16

90:23 91:17 184:8

184:25shortened 89:25shorthand 191:3shots 58:12 144:14show 8:20 22:14

22:15 43:10 44:144:3,12 50:551:15,24 54:570:2 72:6,9 76:2080:12 92:2 125:5143:12 146:1155:15

showed 172:9174:10 187:4,8

showing 21:322:23 25:2 26:554:9 58:18 69:10143:17 148:16

shown 16:10 33:3105:9 129:7 144:5147:10 148:18152:25 154:17155:19 192:16

shows 21:6 31:1831:20 39:25 40:2441:15 50:17 54:459:21 65:23 80:1097:18 102:20118:21,22,23119:2 141:13151:4,11 157:11167:7 177:25180:2,3

sic 127:8,15side 12:19 22:15

29:5 83:19 116:25152:19 153:1,2,4

sides 173:16sign 33:21,23 34:3

49:19 81:5 121:18

signage 8:21 11:135:5 41:2,4,5,9,1080:14

signature 191:24192:14

signed 193:13194:18

significant 96:12131:15

significantly 95:1996:2,6,10 97:4134:17

signing 157:20192:19

signs 35:4 80:11similar 54:2

115:13 173:19174:11 177:16

similarly 124:10simple 116:10simplicity 34:3simpson 2:4,4,4

6:9,9sincerely 192:21single 143:1,23

165:7sir 192:10site 13:8 47:23

67:13 73:3,6,698:11

sitting 133:22176:8

situation 56:1695:9

six 41:18size 95:19 134:15

134:25 135:1136:12,14,17137:10,13,20,21137:22,25 138:19139:1,8,15,16

[seen - size] Page 28


CRYSTAL FOUCHARD

140:9sizes 135:2 142:13skin 57:12 58:13

152:20skip 56:1skipping 40:12

179:25sku 9:24skus 10:2,2slightest 190:6slightly 97:9small 95:24 98:22

138:10 142:11,19152:14

smaller 118:9139:10,11

snapshot 3:22social 43:5,6,7,8

66:8,10,14 91:17158:7,21

sold 35:25 79:8solutions 153:4

192:1 195:1somebody 24:1

44:2 50:4,2553:18 68:1 74:2298:8 101:2 157:22

somebody's 99:1100:11

someone's 99:7157:1

sorry 54:8 81:24122:2 127:25129:22 138:12178:4

sort 51:23 62:20112:6 125:6152:13

sorts 36:12 94:17154:7

sounds 107:1116:16

source 187:22space 46:4 57:7speak 19:17

102:17speaking 35:13special 61:20

174:24speciality 179:19

192:6 193:3 194:3specialized 13:10specially 12:18

152:18specialty 1:3 2:2

6:8,10 11:15,2212:4,23 13:3,1014:14,16,19 15:2,515:12 83:6,13,1687:1,2,3 106:18145:13,17 153:25171:15,22 172:1172:11 173:22174:4,22 175:15176:1,10,15

specific 19:2542:16 49:4 52:2166:5 86:19,2289:10,12 90:1291:8 94:5,10,23100:25 102:17103:6 136:13183:2 188:6,8,10188:11 189:12,13

specifically 12:613:10 22:23 30:187:16 102:23103:10,13,16,20106:2,10 115:8,11116:24 118:18,25121:16,20,24

129:9 135:4152:24 162:25177:6,9

speculation 84:8113:16 131:18172:16,21

spend 3:20 37:2038:25 66:7 123:14123:20 130:6,17185:15 188:4,14188:15,16,17189:19 190:16

spending 126:25129:7

spent 36:21 38:1790:13 104:13122:5 124:3,5,7,9124:11,12 126:24127:8,9,18 130:2130:10,11 188:24190:4

spoke 135:3spokesperson 57:4sponsor 49:15sponsored 49:16sponsoring 49:6spot 42:12 59:6,6spotify 181:10spots 58:12,13square 44:18,19

44:20 45:2stack 27:17 167:17stacks 27:14stages 164:5stakeholders 34:9

84:17,20,21,23stamped 18:18

20:23stand 13:7 19:19

39:12 127:20

standard 20:16standpoint 50:24

74:24 98:13,14135:16 136:18137:17

stands 18:6 24:2148:11 50:1 150:13

stapled 91:3,6star 24:11start 6:18 10:15

33:18 85:10 88:1391:11 102:11128:2 145:25

started 9:3 10:1766:12 85:4 86:10126:3 128:7129:10,14 179:10180:11,11 186:22

starting 88:14,1891:20

starts 76:14 126:7state 26:12 62:13

62:20 191:4193:10 194:15

statement 193:13193:14 194:19,19

states 1:1 62:14,1562:17 79:25,25

stating 113:19station 49:19status 108:13

128:25 129:1171:18,18 172:4

stay 11:18stayed 86:13stearns 59:24steering 108:7,9

108:12stenographically

1:22

[size - stenographically] Page 29


CRYSTAL FOUCHARD

step 24:3,5steps 29:20stetson 1:19 2:14

191:13stock 183:16stood 108:7stopping 111:21store 8:21 11:1

15:2 35:1,2539:15 41:5,8 45:145:23 46:4,18,1950:13,14,16,1756:1 80:3,10,12,1481:8 146:11

storefront 80:15stores 12:11,16

13:5 35:2,5 39:1039:12,20,23 40:150:15 62:5,15,1863:9,18 66:379:18,18,22,2480:8,19 81:4,4,6,981:10,12,13,16,1881:21 82:20,22,23

strategic 34:17strategy 18:19

19:2,2,6,8,15103:2,4

streaming 46:2346:24 47:1,254:24 125:4181:14

street 2:5strike 31:19

145:25 159:18181:4

string 28:13104:19 105:17

study 49:9 78:1182:22

stuff 101:19subject 108:3,23

108:25subjective 96:12

113:21submission 143:11submitted 172:2

177:21,22submitting 132:3

132:7subscribe 68:8

149:4subscribed 193:10

194:14 195:21subscribers 68:11

148:25 175:3,16subsequent 24:2

29:25 34:2 50:1251:1 106:11111:17 141:2

subsequently

28:21 30:8 33:20subset 61:2 148:22substance 177:14

177:16substantially 97:1

97:5,12 134:17138:18

substituted 92:20subtract 163:8suggest 125:24suite 1:19 2:14

191:13 192:2summary 26:1

36:20 102:7summer 57:5

58:13 152:3sun 57:6,10sunday 48:3 141:4superior 192:1

supplier 38:1946:2

supplies 36:9supply 123:2,4

187:18support 11:16

12:4,8 14:1415:12 17:3,1626:15 87:1 129:12129:14

supporting 10:21189:4,7

supports 15:8supposed 143:12

170:20sure 11:25 13:1

26:3 40:24 42:2150:14,19 51:952:15 54:15 58:167:3 70:7 90:2591:21,24 114:23115:10 129:14140:9 141:12143:13 150:5,14153:12 154:19159:22 163:2,6,11170:11 175:19,23

surname 164:13surprised 166:19

166:21survey 48:20

78:15 182:17susan 45:12swartz 2:4switch 144:21sworn 6:2,14

191:8 193:10,13194:14,18 195:21

symbol 155:2163:18,21

syndicated 7:25synonym 114:12synonymous

166:4synonyms 114:6

114:10system 13:9 66:2

t

t 191:1,1tactics 12:7 20:19tag 42:18tagline 112:6tags 42:14,15,20take 12:21 29:20

50:7 58:5 68:385:6 165:17171:11

taken 57:9 58:685:16 146:23157:8 184:25

takes 24:1talk 12:4 19:2 53:1

53:16 57:11talked 26:6 82:11

112:17 134:15142:1

talking 53:2058:21 59:11,2583:15 134:11144:16 145:3,20160:21 162:19166:2,11,13

tamara 2:12 6:3192:5

tammy 87:8tap 141:9,12,19tapped 141:11target 25:16,17,21targeted 23:7 46:9

103:6

[step - targeted] Page 30


CRYSTAL FOUCHARD

team 7:24 12:614:21 15:7,12,1515:15 16:24 17:1718:2 25:21 83:16133:12 134:22138:22 140:1,3160:3

team's 14:18teams 15:15technology 24:8

50:24 54:21 55:356:5 125:9

telethon 59:17television 58:23

59:2,20tell 19:5 20:24

39:6 40:5 85:2588:16 98:6,19103:20,24 115:21115:22 116:4126:25 127:2,11135:11 152:12,14153:12 159:15162:15 165:12,22166:10 184:4187:9,10 189:23

teplitzky 76:5term 24:16 38:16

49:2 50:15 104:20terminology 126:6terms 10:25 15:17

26:17 38:22 74:10103:2 133:7,7,16136:12 150:9152:7 157:15166:7 168:12176:11 184:15188:11,14 189:10

terrestrial 46:25testified 6:14

24:15 56:2 64:13

65:11 66:6 78:3131:5 147:2148:13 159:11167:1 185:6,23186:3,3 190:19

testify 16:9 97:25185:14

testimony 1:123:11 16:6 98:499:9 108:11 125:2159:4 191:9,9193:6,7 194:6,9,12

testing 12:9,1136:9 75:20

thank 6:17 27:2085:9 97:2 146:19190:23

thanks 27:19108:22

thanksgiving

61:21thing 142:18

150:11 153:11155:15 161:20163:20 178:11

things 8:21 26:1836:8,9 40:18 45:650:16 52:18 74:1486:1 101:12156:25 158:21

think 23:25 25:243:15 52:6,1053:6,8 55:2,1356:19,24 57:2159:10 84:25 97:697:15 98:2,2113:21,22,24117:6 118:25119:13 121:11122:3 125:1,5,13126:4 132:9,9

133:4,6 134:16136:4,23 137:11137:16,24 138:25139:21 140:7144:7 148:2 156:5157:10,14 161:13164:22 165:10175:9 185:20186:13

thinking 20:11third 22:21 25:6

25:10 40:15 43:2143:22 44:1 45:1447:18,20 49:3,753:6,15 76:12108:1 110:25131:2 142:16161:6 169:25172:19

thirty 192:18thomas 167:12thorough 173:8thought 87:13

118:24 135:11thousand 127:20

186:5thousands 150:13

186:12three 22:16 37:4

68:17 71:21 95:1195:13 104:9105:16 135:6160:17,18,25

thursday 183:21183:24

tight 114:13time 9:13 27:8

28:10,21 71:1578:19 79:13 88:488:9,19,23 89:1589:20,21 90:10

91:13 101:14105:9,11 114:18129:16 145:12157:4,5 161:20163:8,9 170:12190:24

times 44:18,19,2045:2 61:17,23,25124:25 135:7

tiny 44:17tips 73:25 74:2title 8:10 10:18

16:21 18:9 24:18106:21 107:4,7

titled 25:13titles 152:7tmiller 2:16today 6:18 16:8

87:7 88:14,24,2593:14 133:22143:16 176:8183:17

today's 87:11told 106:22 109:9

165:12 166:16168:18 187:7188:1

tonawanda 2:9tool 51:24tools 54:10 57:23top 16:10 19:13

20:7,9,22 22:1428:1,2 31:12 33:339:4 41:24 65:768:6 69:5 103:18105:3,15 108:4142:17 148:3151:23 154:16,16154:19,23 155:1157:11 170:16173:5 179:4,5

[team - top] Page 31


CRYSTAL FOUCHARD

180:3 183:4topic 108:4 151:10topics 73:16,17,18

73:23total 14:2 38:7

123:13 130:3,6137:22 139:16185:8 189:9

totals 185:24188:18,21 189:5190:12

track 24:7 78:17tracking 5:7 77:1

78:1,4,6,9,20 79:1138:12

trademark 1:1,227:1,7 32:7 34:183:18,21 87:19120:11 129:2132:3,7 133:23168:13 172:8174:18,21 177:2,5177:20

trademarks

172:10trained 12:18

152:18transcribed

191:14 193:7transcript 191:8

192:11,12 193:5193:12 194:5,11194:17

transition 22:1922:21

transitioning

65:16,17transmitted

132:12transplant 21:5

102:11

transplants

101:12treating 146:4treatment 12:19

20:2 101:10152:19 153:2

trends 74:3trial 1:2 3:11,14

3:17,20,23 4:4,74:10,13,16,19,225:4,7,10,11 15:2316:3,12,17 31:5,1036:13,18 60:16,2164:3,8 66:17,2267:15,20 68:20,2570:8,13 71:5,1072:15,20 75:2176:1 77:6,11185:4 190:13

triggered 23:19trouble 97:3true 32:23 55:5

64:1 98:6 110:2175:17 188:13191:9

try 11:18 51:1355:18 76:21 85:25128:22

trying 9:25 55:9135:10 141:5160:24 166:15

turn 23:18 64:2592:1 117:15121:25 123:18124:14 149:17171:6 173:2179:15 188:5

turning 18:1720:23 22:8 24:18

tv 9:14 11:2 18:2535:11 42:7,11

58:10,10,11,12,13180:17,21 188:14188:16,18

twice 135:6 148:25twitter 43:8 66:12

158:3two 2:13 8:23

11:10 15:15,2127:14 50:3 74:176:19 86:23105:16,17 108:4111:6 115:16135:2 138:7162:16,16 167:17169:16,18,20171:14 172:9180:7

tylenol 8:18 9:119:17

type 17:5,7,9,1217:20 24:23 31:2540:9 50:18 59:2477:12,15,17 91:391:18 94:23 95:1999:16 141:16142:22 154:12162:13 182:3

typed 91:3types 9:14,16

12:13 17:15,1821:4 26:6 36:1136:24 40:18 41:843:7,8 48:17,2251:22 53:19 54:657:5 60:2 65:1165:23 73:18 74:474:14 76:13 94:21174:20

typically 19:20typing 52:2

u

u.s. 62:8 81:1uh 86:1ultimate 30:14

119:12,22,24120:2,5,21

ultimately 9:230:9 34:5 108:13118:4,6 133:2164:9

undergrad 6:237:17

underneath 67:5understand 16:8

49:10 50:25 70:673:25 79:11 85:2498:20 101:8 112:4113:6 117:18125:2 138:4 139:6145:17,20 167:1

understanding

16:4 18:19 29:1231:24 32:2 60:2267:9 71:2 81:13113:24 114:2129:17 130:13,18174:19 188:14

understood

173:12unheard 184:17

184:20united 1:1 15:19

79:25university 6:23

7:11unsolicited 74:18updates 108:13upside 123:18upstairs 85:7url 142:24 160:5

161:10 163:5,9,14

[top - url] Page 32


CRYSTAL FOUCHARD

164:9,9,11,14,25166:1,5 172:20

urls 160:4 162:1usage 74:13use 17:23,25 18:3

34:22 36:25 38:1541:4 43:25 44:544:16 48:13 50:1551:24 57:4 71:1272:24 85:14111:18,24 112:1113:14 126:5,6135:9 139:18143:11 151:20175:2 178:2,6,12

uses 18:2 177:17usually 20:14

38:15 39:16 41:449:18 50:17 62:20126:5

utilize 15:3 19:10utilizing 56:6

66:12uv 57:10

v

v 192:6 193:3194:3

vague 79:9 95:2297:11 110:12

valainis 76:4value 184:17variations 134:23

162:3various 9:9,12

10:24 20:16 36:2573:16,16 74:975:14 78:18 80:1987:18 90:14105:21,22 118:17137:15 138:21160:4,5 162:6

164:4,4vehicles 51:11vendor 46:1venture 14:13

28:6,20 86:25110:11 111:19112:2,22 113:10118:10 119:1,6,20

verbally 47:9veritext 192:1,7

195:1veritext.com.

192:17version 39:9 56:20

61:20 89:25115:19,21 117:25142:2,5 146:8

versioning 62:21versions 59:5

62:11,12,12,19,2463:1,2 115:16116:14 117:1,7137:11

versus 59:6vertical 22:15,22vice 13:21video 41:13,14,15

41:17,18,19 44:2454:17,21 67:25154:18 155:3,9

videos 42:9 68:3148:17,19,22155:5 157:12

view 25:4 26:4,1356:15 130:15

viewed 100:16viewer 150:7,10viewers 70:5

149:25 150:6views 70:3

visibility 29:1447:23 122:16123:13 187:24189:12,17

visual 21:6 47:1297:18 104:10136:6 139:9

visually 135:23136:23

visuals 24:2vitamins 10:23

35:20 36:7voit 2:12vs 1:6

w

w 18:18 20:2322:8 23:18 24:1825:13 26:1 44:1664:25 65:19 67:5101:8 117:12,16171:6 179:15

w000927-938 3:14w001828-2214

3:17w002307 4:5w002762 5:5w003012 3:21w003064 3:23w003277-3299 5:8w2007 173:3wade 76:4wait 85:12 116:3waiting 27:20 41:6

80:16waived 192:19walgreen 1:7 2:11

6:4,6 16:9 192:6193:3 194:3

walgreens 3:134:4,6,9,12,15,185:6 8:20 10:14,15

10:17 11:4 13:2414:3,7,9,12,13,1614:22 15:7,8,1316:25 17:1,3,1718:12 21:11,12,1721:18,19,20 22:2,223:1,1,4,5,13 25:726:25 27:5 28:628:20 29:4,11,1930:5,10 31:432:23 33:4,7,16,2234:4,7,12,13,17,2034:21,24 35:14,1435:25 36:3 37:2038:23 39:2,2240:24 41:11,21,2442:3,6,20 43:2,343:12,17,18 44:1,344:5,5,14,21,2445:8 46:11,2047:6,10,14,17,2448:9,23 49:6,12,1649:22 50:11 51:451:4,11,15,19 52:453:12,17,20 54:4,854:8 55:3,15 56:557:2,13,16 58:1059:2 60:6,10,11,1463:8 64:17,1965:8,12,15,17,2266:1,3,7,10,11,1566:24 67:1,5,11,1267:22,23 68:2,5,968:12 69:2,4,770:3,15,21,2471:16,18,23,2472:7,10 73:1174:18,25 75:5,7,1276:10,25,25 78:1078:22 79:4,7,14,1579:15,22,24 80:3,4

[url - walgreens] Page 33


CRYSTAL FOUCHARD

80:9,17,23,25 81:381:4,7,14,16,17,2282:7,8,20,25 84:384:13,14,15 86:786:10,13,17,20,2487:3,5 89:8 93:2094:21 95:10,10,2098:9,10,25 100:1,4100:6,19 103:8,14103:15,15 104:3,6104:11,12,15,16106:18,19,24107:16 110:8,8,10111:19 112:2,22113:10 117:21118:10,19,22119:1,6,18 121:17121:21 122:14,16125:10 126:20127:8,15,24 129:7129:13 130:2,6,14130:19,20,25132:19 134:1,18135:18,19,19,22135:25 136:15137:9,12,21,24138:10,16 140:11140:17 141:4143:16,18,20,24146:16 147:3,8,14147:17 148:7,10148:14,20,22,24149:4,8,14,19,23149:24 150:8,16150:17,22 152:5153:21,24 154:4,8154:9,12 155:23156:1,2,7,8,11,14156:18,21 157:18157:24 158:1,9,10158:11,13,14,17

159:12,24 160:3160:10,12 161:1,4162:4 163:4,17164:18,21 166:7,9166:17 167:7170:23 171:1173:9 175:8,11,18177:21 179:10180:16,20,24181:1,7,12,21182:7,10,12 183:4183:9,11 184:12190:4,16

walgreens.com

4:21 53:22 65:2273:2,23 79:19164:25 166:7,8

walgreens.com.

35:6 39:21 73:1479:20 159:13164:24

walking 180:1want 20:9 50:5

85:3,10 96:9125:4 128:11144:9 146:22149:21 150:14154:10 165:8

wanting 34:7watch 41:18

141:17,19 154:24watching 182:6way 23:11 26:17

35:11 49:10 136:4137:22 147:20150:23 155:7,19158:10 161:6171:2 182:1 188:9191:17

ways 13:2 18:2339:17 55:14 60:8

wba 110:14we've 60:1 158:21

166:4 190:5web 92:25 140:23

147:5 159:12,24166:16 182:6,7,7

webmd 49:4website 22:13 23:7

50:8 53:22 57:1573:10 93:3,11,1599:16 159:19166:5,8,12,23

websites 20:16wednesday 183:20

183:22,25wednesday's

183:18week 39:24 40:1

52:12 59:19 61:1862:8,11,25 63:2,1464:17 75:18 90:1192:9,12 102:12183:9,15,16186:19

weekly 39:8,19weeks 45:19wellness 10:22

35:18,24 36:565:14 74:5 81:1781:20

went 6:23 8:7 58:9129:7 130:7 147:7168:20

whatsoever

146:15 149:8whereof 191:20wide 52:17 138:7williams 29:16

115:7williamsville 2:5

willing 99:8 124:2win 114:11withdraw 73:9witness 3:2 6:1,13

13:18 25:9 28:1629:3 32:11 33:737:15 47:9 61:963:22 69:22 71:1371:16 73:2 76:1679:17,24 80:882:2 83:3,11 84:984:13 95:23 96:496:11,12,20 97:12102:4 104:2 107:7110:13 113:2131:19 136:4137:6 172:17,25176:4,18 184:20191:6,10,20 192:8192:11 193:1,4,11194:1,4,15

witness’ 192:14woman 141:25won 75:8,18word 34:14 96:6

104:19 108:25112:17 113:25114:2,4 116:19119:20 145:3149:12,23 177:17182:20

words 86:2 95:1596:16 113:23125:3 136:24,25137:7 162:11,15162:16,16 170:16

work 8:7 13:2428:11,25 29:2539:2 107:9 110:17132:14,22,23133:1 141:10

[walgreens - work] Page 34


CRYSTAL FOUCHARD

164:19 167:10,10worked 9:9,9 10:3

29:3 86:16 109:15110:13,19 160:9160:10,10,12

working 7:23 8:188:19 9:10,15,2310:13 27:5 30:1745:13 89:22 94:20132:2 134:22160:2 161:14,17164:6 168:13

works 176:5wp 162:5 166:11wpp 18:1,4 40:16wright 106:14,16

106:17 107:10108:3,21 109:21109:22,25 110:6110:11,22

write 155:7 169:5169:6

writes 105:5writing 110:21

155:8 169:11written 24:19

95:18,25 120:19142:19

wrong 59:12 61:797:15 139:14149:21

wrote 61:6 113:11ws 149:23

x

x 3:1

y

yeah 10:7 29:2449:14 62:20 114:7116:3,14 125:8132:8 134:2

142:13 157:10169:19 183:25184:15

year 7:5 8:12 9:518:11,13,14,1527:12 37:5,9,22,2338:4 54:18,2557:16 58:11,1359:3,8,9,23 61:2368:15 80:23 81:1123:14,21 125:25126:3,5,6,9 127:7127:14,24,25128:1,19 129:11129:16,19,24130:1,1,5 151:25152:2 185:7,15,21185:22

years 8:24 10:1411:10 36:23,2537:4 55:16 56:960:1 68:18 71:21125:1,15,15 179:9180:10 186:3188:25

yep 67:7yesterday 92:3yielded 78:14york 2:5,9 44:20

174:1youtube 4:9 41:16

41:17 67:22,2468:1,9,13 91:20148:14,22 149:5149:11,14 158:23

z

zyrtec 10:4

[work - zyrtec] Page 35


Federal Rules of Civil Procedure

Rule 30

(e) Review By the Witness; Changes.

(1) Review; Statement of Changes. On request by the

deponent or a party before the deposition is

completed, the deponent must be allowed 30 days

after being notified by the officer that the

transcript or recording is available in which:

(A) to review the transcript or recording; and

(B) if there are changes in form or substance, to

sign a statement listing the changes and the

reasons for making them.

(2) Changes Indicated in the Officer's Certificate.

The officer must note in the certificate prescribed

by Rule 30(f)(1) whether a review was requested

and, if so, must attach any changes the deponent

makes during the 30-day period.

DISCLAIMER: THE FOREGOING FEDERAL PROCEDURE RULES

ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY.

THE ABOVE RULES ARE CURRENT AS OF APRIL 1,

2019. PLEASE REFER TO THE APPLICABLE FEDERAL RULES

OF CIVIL PROCEDURE FOR UP-TO-DATE INFORMATION.

VERITEXT LEGAL SOLUTIONS

COMPANY CERTIFICATE AND DISCLOSURE STATEMENT

Veritext Legal Solutions represents that the

foregoing transcript is a true, correct and complete

transcript of the colloquies, questions and answers

as submitted by the court reporter. Veritext Legal

Solutions further represents that the attached

exhibits, if any, are true, correct and complete

documents as submitted by the court reporter and/or

attorneys in relation to this deposition and that

the documents were processed in accordance with

our litigation support and production standards.

Veritext Legal Solutions is committed to maintaining

the confidentiality of client and witness information,

in accordance with the regulations promulgated under

the Health Insurance Portability and Accountability

Act (HIPAA), as amended with respect to protected

health information and the Gramm-Leach-Bliley Act, as

amended, with respect to Personally Identifiable

Information (PII). Physical transcripts and exhibits

are managed under strict facility and personnel access

controls. Electronic files of documents are stored

in encrypted form and are transmitted in an encrypted

fashion to authenticated parties who are permitted to

access the material. Our data is hosted in a Tier 4

SSAE 16 certified facility.

Veritext Legal Solutions complies with all federal and

State regulations with respect to the provision of

court reporting services, and maintains its neutrality

and independence regardless of relationship or the

financial outcome of any litigation. Veritext requires

adherence to the foregoing professional and ethical

standards from all of its subcontractors in their

independent contractor agreements.

Inquiries about Veritext Legal Solutions'

confidentiality and security policies and practices

should be directed to Veritext's Client Services

Associates indicated on the cover of this document or

at www.veritext.com.

Applicant’s Trial Exhibit No. 66 to

Testimony Deposition of Crystal Fouchard on Behalf of Applicant

January 10, 2020

Opposition No. 91236453

Specialty Pharmacy Management v. Walgreen Co.

IN THE UNITED STATES PATENT AND TRADEMARK OFFICEBEFORE THE TRADEMARK TRIAL AND APPEAL BOARD

SPECIALTY PHARMACY MANAGEMENT, LLC,

Opposer,

v.

WALGREEN CO.,

Applicant.

Opposition No.: 91236453Serial No. 87/353,224

NOTICE OF TESTIMONY DEPOSITION

PLEASE TAKE NOTICE that, pursuant to 37 C.F.R. §2.123 and TBMP § 703.01, the

testimony upon oral examination, shall be taken of:

DEPONENT:

PLACE:

Crystal Fouchard, Senior Director Brand MarketingWalgreen Co.200 Wilmot Road, 2nd Floor, MS #2243Deerfield, IL 60015

Leydig, Voit & Mayer, Ltd.Two Prudential Plaza180 N. Stetson, Suite 4900Chicago, Illinois 60601

DATE: January 10, 2020

TIME: 9:30 a.m.

Such testimony will be taken upon oral examination before a stenographer authorized to

administer oaths and used as evidence to support that there is no likelihood of confusion.

Specialty Pharmacy Management, LLC v.Walgreen Co. Opposition No. 91236453

Applicant's Trial Exhibit 66

1

Date: December 16, 2019 /Tamara A. Miller/Tamara A. MillerLaura M. SchaeferLEYDIG, VOIT & MAYER, LTD.Two Prudential Plaza, Suite 4900180 N. Stetson Ave.Chicago, Illinois 60601-6731(312) [email protected]@leydig.com

Attorneys for Applicant

2

CERTIFICATE OF SERVICE

I hereby certify that on December 16, 2019 a copy of this NOTICE OF TESTIMONY

DEPOSITION was served via email, by agreement, on Opposer's attorney of record as of this

date:

Ellen S. SimpsonSimpson & Simpson PLLC5555 Main StreetWilliamsville, NY 14221United States

[email protected]@idealawyers.com

/Laura M. Schaefer/

3

TRADE SECRET / COMMERCIALLY SENSITIVE



January 10, 2020



CONFIDENTIAL

HIGHLY CONFIDENTIAL



January 10, 2020



CONFIDENTIAL



January 10, 2020



e.

j Sun essentials

with cardWonderful Pistac osor Almonds 7 or 8 o

with card 24 -PackDasani Water 16.9 oz. ea.Limit 4. No limits in NM.Plus deposit or CRVwhere required.

S5 Register Rewardsat checkout when you spend $20 or moreon participating products. Good on yournext in store purchase.*'

uArn.roat(ess

with cardon same brand

/O CosmeticsOff Maybelline, CoverGirl,

Revlon and more!

See page 6 for more details.

buy 1 get 1

with card Aveenoor Neutrogena SunCare Select varieties.

with card Arm & HammerLaundry Detergent43.75 or 50 oz. or 17 or 21 pk.

with cardHousehold Products Scott Bath Tissue,12 rolls LiquidLaundry Detergent:All, 94.5 oz. Purex,128 or 150 oz.

§Pricing, promotions and selection may vary by location and en'Walgreens.com. *01 equalor lesser price ',Coupon available at Walgreens,coralCoupons, Card and online manufacturer zoupoa required for pricing. MYalgreens wit donate 1% of participating products' retail sales madeV1,18-12/31/20 to Vitamin Angels. **Only available on in-store purchases. Limit 1 Register Reward coupon per customer per offer. See couponfor terms. restrictions and expiration. Purchase requirement must be met in a single transaction, before taxes and after discounts, store credit andredemption dollars are applied. 00Coupo,l amiable at Walgrcens.com/Coupons. Card and online coupon required for pricing. =$Balance' Rewardsrequired Message and Data rates may apply. Coupons available en select products.

SALE PRICES GOOD IN STORE & ONLINE§ Sun., July 8 thru Sat., July 14, 2018

buy 1 get 1

ONLINE COUPON

or 5.99 ea.

with $2 oft Walgreensonline coupon on 300

TEXT2CLIP-text SODA to 41456t.

12 -Pack Coca-Colaor Pepsi ProductsPlus deposit or CRVwhere required.

Aveena.. protect

hydrate'

-

with card Nescafe InstantCoffee Taster's Choice, 7 oz.4.99 with cardClasico, 7 oz.

FREE*with cardFinesta NutritionVitaminsand SupplementsSelect varieties.

Ei1ü1FE('l ASCO'

ovitaChange

Urea:

BIOTIN6LUCOSAàIIICCHONDR0I711

..nr s.r.r..

DEALS of theWEEK

lSiüttIeS

2/$ with card Mars, Dove,Skittles or Starburst

or 79c ea. Candy 1.35 to 2.17 oz.Select varieties.

ONLINE COUPON

99, th card

OR

490with card &

50. off coupon0

PalmoliveDish Liquid10 oz.

While supplies last.

BANDAID "eciä

with card First Aid

0/OProducts SelectJohnson & Johnson

Off Band-Aid, Aveeno,Neosporin, Polysporin,Cortizone-10,Benadryl or Curad.

/t.e.01(4,, Trusted since 1901"

Specialty Pharmacy Management, LL53Walgreen Co. Opposition No. 9123


/1002307

Add paperlesscoupons to your

Balance Rewardsaccount

Learn moreTap to watch

Available in the Walgreens App!

Download on the

App StoreGET RON

Google Play

2/$3 with card Gatorade28 oz. Plus deposit

or 2.39 ea. or CRV where required.

2/s with card BaiAntioxidant Infusion

or 1.79 ea. Drinks 18 oz. Plusdeposit or CRVwhere required.

bai

8-:'

2/$ with card10 -Pack Capri Sun

or 2.49 ea. 6 oz. ea.

Breakfast bargains

99 with cardFolgers Coffee22.6 to 30.5 oz.

2/$ Specialwith cardK

orKellogKashgi's

or 2.79 ea. Cereal 11.2 to 14 oz.Select varieties.

599

b.,e l'IKáputts'

to>

with card Starbucks CoffeeK -Cups, 10 pk. or Ground,12 oz. Select varieties.

199 with card General MillsCereal 11.5 to 13 oz.Select varieties.

499with cardNice!' 100°ó /V[ NON[Y

Pure Honey {

or MapleSyrup8 to 24 oz

with card PeanutButter or Jelly Skippy

or 2.79 ea. Peanut Butter, 16.3 oz. Welch's Concord Grape Jelly, 30 oz.

2/$

pi Coupon offer expires 07/14/2018

2/250with cardSimply Juice or Drink11.5 oz.Limit 4. No limits in NM.Plus deposit or CRVwhere required.

IIII11IIIIIIIIIo

2/450with cardGood2Grow AppleJuice or Fruit Punch6 oz. Limit 4.No limits in NM.Plus deposit or CRVwhere required.

oIIII,IM!IIII1IIIIIIIIII

149 with card Snacks Kellogg's, Austin, Cheez-lt, Nabisco or PepperidgeFarm Goldfish, 2.2 to 6.5 oz or 6 pk. Select varieties.

Y

Oiipql ,

r` A .r r.`rv, a

® LAmPooNEgeit s a,

va Coupon offer expires 07/14/2018

r_ r1

8


2175with cardSnappleTea or Drink 16 oz.Limit 4. No limits inNM. Plus depositor CRV where required.

oII1I!!!!!!IIIIIIII,III,911II1

2/$or 4.99 ea. 7 with card

Oscar Mayer Bacon1 lb.

Coupon offer expires 07/14/2018

4/$5with cardBumble BeeSolid WhiteAlbacore Tuna5 oz. Limit 4.No limits in NM.

II,U11,1IIIIIIIIIII

2

9.12.17.19.20.23 2<, 2y, 28

V1002309

r,.

talenbA --

Mediterranean Mil'r,NEPIrT (47321-'

Cold savingv$2/$2$7

or 3.99 ea.

with card Edy's or Dreyer'sIce Cream 1.5 qt.Brands vary by store.

/ TowithcardFrozen TreatsHalo Top Ice Cream, 1 pint

or 4.99 ea. Talenti Gelato or Sorbetto, 1 pint

+

_. t. 0 : P`'

0T°o

Calentl 360

T320

or 5.29 ea.

with cardDiGiorno Pizza12 in.Rising Crust.

21$7or 3.99 ea.

iwwwwing vi

with card White CastleBurgers 6 pk.

6

leneglp

9white meat/pentsünfetOsti''we

Cheeseburgers

4/$4or 1.59 ea.

Theater Pack CandyItems shown, plus more! 79 with card Trident

eor Dentyne Gum14 or 16 pieces.Select varieties.

with card M&M'sSharing Size,

or 3.99 ea. 8 to 10.7 oz.Select varieties.

2/$3 with card CandyItems shown,

or 1.69 ea. plus more!

' HAItI130GOLD -BEARS

KalCoupon offer expires 07/14/2018

5Oeffwith cardKinder JoyChocolate Egg.7 oz. Limit 4.No limits in NM.

.liiiidiilplOV 7


1offwith cardMentos Gum45 or 50 pieces.Limit 4.No limits in NM.


2/55with card Candyor Gum Tootsie RollPops or Midgees,9.4 to 12 oz. CharmsBlow Pops, 10.4 oz. Dubble Bubble Gum, 16 oz.Limit 4. No I mits in NM.

o 1111,1,111.1111,11 5


2/54with card WelÇI'cWelch's Fruit Snacks10 pk. Limit 6.No limits NM.

0011,M1 I0111N7ii 2

8.12.17.18.20. 23. 24, 28.28

piRefill your prescriptions in seconds. Walgreens.com

N402310

599

499

with card Nice!° SelectNuts Whole Cashews,16 oz. Pistachios, 16 oz. Deluxe Mixed Nuts,16 oz. Trail Mix, 26 oz.

with cardKrave or Duke's Jerkyor Smoked Sausages2.7 to 5 oz. Select varieties.


2/350 Nicervii;;;e PíÁ u

with card Nicej°11,

QTableware Cups, --12 pk. Bowls, 24 pk. 1146..,0, Plates, 20 or 40 pk. *owe,.Limit 4. No limits in NM. `

Nicer ik

PAP« MAWS

OIIIIIitIIIIIIIl1,1Ili/I)lIIl

qfir;


50 effSNOYMCN

with cardNice!° Bags Sandwich,50 or 150 pk. Freezer, 15 or 20 ct. Storage, 15 to 25 ct. Limit 4.No limits in NM.

Nice' 4sida

99

2/$or 2.99 ea.

with card Planters Nuts Cashews Halvesor Halves & Pieces, 8 oz. Mixed, 10.3 oz.

with card Frito-Lay Lay's, 7.75 to 8 oz. Cheetos, 7 to 8.5 oz. Smartfood Popcorn,8.5 oz.

ONicej° Bath Tissue9 mega rolls.

or 56 ea.


$1 off Nice'

with card Nicej°Paper Products Paper Towels, 6 rolls Bath Tissue, 6 or 9 mimmimega rolls Limit 4.

NicerNo limits in NM.skóó

o00111111 II 1.111AÌ11102

.__

reward = 5000 bonus pointswhen you spend S15 or moreon participating products." rewards

ONLINE COUPON Gain LaundryDetergent Liquid,

with card 50 or 51 oz. Flings,

OR16 pk.

with card &2 off coupon0

ONLINE COUPON

with card &02 oft coupon0

Laundry Care Bounce FabricSoftener, 80 sheetsDowny: Unstopablesor Fireworks, 9.7 oz. Liquid Fabric

to 64 oz.

e ra SoBath Tissue12 mega rolls.

with card &a1 off coupon0

MEGA rwdi

Soft

ONLINE COUPON

with card &s2 off coupon0

499with card

s3 off onlinecoupon on 20

Tide LaundryDetergent Liquid,37 or 40 oz. Pods,12 or 16 pk.

Swifter Dusters,5 pk. Refill Cloths,12 or 16 pk.

Febreze Spray, 27 oz. Cascade DishwasherDetergent, 45 to 75 oz.or Action Pacs,10 to 12 pk.

499 card

-OR-399with card &

e1 off coupon0

Paper Products Bounty Paper Towels, 4 rolls Charmin Bath Tissue,4 mega or 12 giant rolls

4 ttGoad on next purchase. Purchase requirement must he met in a single transaction, before taxes and after discounts, store credit and redemption dollars are appliedDue to state and federal laws. points cannot be earned or redeemed on some items. Complete details at Walgreens.com/oaiance. ',Coupon available at Walgreens.comfCoupons Card and online manufacturer coupon required for pricing.

9. tI.17. 19.20.23.2

K1x12311

buy 1 get 1 with card Wexford' School Supplies Notebooks, Composition

FREE*

Books, Binders, Junior Legal Pads or Backpacks. Select varieties.

with card Paper Mateeor Sharpie Pens,

Mechanical Pencilsor Highlighters.Select varieties.

599

8 1,1 ,.

SparKl

with card Paper Products Angel Soft Bath Tissue,6 mega rolls SparklePaper Towels, 8 rolls Quilted Northern BathTissue, 12 rolls

COUPON SAVINGS

with card &s2 off coupon

in most Sunday paperst

Persil LaundryDetergent Liquid,40 oz. Power -Caps,16 or 18 pk.

with card Wexford'Highlighter or 2 -Pocket

or 29c ea. Folder Select varieties.

2/$5 with card Lysol Neutra Air, 10 oz.

or 2.59 ea. Select Cleaners,24 or 28 oz. Wipes, 35 pk.

egirair

89ewith card

buy 3 get 1

FREEcoupon

in most Sunday paperst

RenuzitGel Air Freshener7 oz.

0/with card Belkin Electronics and Accessories0 Items shown, plus more!

off

rIx tw<cow-. <"..0 u.ru.r a.<.c.0 c rnw.w<-rw-.a.cr.xc

iDURACELL

dineDURACELL

10 YEARS

Readyin aboutan hour

4x6 Prints 100 print min.Enter promo code: MY100PIX1Excludes instant, collage and prints from tilos.

Postersf1111.11111.1.1 Stationeryand Enlargements Enter promo code: JULYCARD254Enter promo code: LIVLARGEI Select products not available on the app. DesignsExcludes instant prints. may vary between kiosk, website and mobile app.

mixitr,wm.M.euYl...Wucrrrwra.sw

Eneigizei

mixitmaewmrw<..awurnow.nwrwowNra..

EnergizerHearing Aid Batteries16 or 24 pk.Select varieties.

FREEsame daypick upt'

30.ff°Canvas Printsand CustomFloating FramesEnter promo code: 30DECOR%

Passport and ID Photos - Ready in minutes!Pictures taken and printed while in store.

'ins during regular Iah hours

*Of equal or lesser once tOnly available on mstere purchases htiol to be combined with any other offer Photo promo codes must be entered at time of order placement. hAvaiiable for same day pickup at select locations See associate for detail tVaiid in store. Donne or on the mobile appttGood on next purchase Purchase requirement must be met in a single transaction. before taxes and after discounts, store credit and redemption dollarsare applied. Due to slate and federal laws points cannot be earned or redeemed on some items. Complete details at V/atgreens coos/Balance

05002312

Print photosfrom your phone

in a few easy steps

Learn moreTap to watch

ride aAvailable in the Walgreens App!

asal Download on the

App StoreGET IT ON

Google Play

1M02313

buy 1 get 1 with card

50Sal

0A Clean & Clearor Neutrogena Skin

On Care Select varieties.

Owith card Select

offDesignerFragrances

Items shown, plusmore!

buy 1 get 1

50 °A)off*

with card

SI off coupononline or in mostSunday papers('

Biore or JergensGlow Skin Care

It\ANC.t.mttim:1;

JERGENS

Biore

buy 1 with cardget 1sOelaleycrvianri2eres.

off°LAW

oiAyEYES

C 419, C11

buy 1 get 1

50 °A)off*

with card

s2 off couponirr most Sunday paperst

0 LAY1G:A.

-7

Garnier Skin CareExcludes Sheet Masks.

ce,Risueri,SKJNACTNE

MizellorCleansingWale,

buy i get 1 with card Hawaiian%Tropic or Banana Boat

off twin packs, lip, sticksSun Care Excludes

and trial or travel sizes.

HAWN.%TroPic

Sheer TOIICh

Man"simplyprotect

KS

Tropic.

$5 Register Re

withcos

on sa

MAYBELLLU2 Neutrogena. KJYX REVIDN R I

buy 2 get 3rd

FREEmix & match

oral care

01r=

r ri ;me iLsIE N SSTfT I V le IYE X ,

Includes toothbrushes, toothpaste,whitening kits, interdental, oral analgesics

& mouthwash. Offer good in store andonline at Walgreens.com/oralcare now thru

7/28/18 with card

21,to.re.:

buy 1get 1mix & match ba

to

DoveMEN'+CARE

k

nc u s oam an yw-atsoaps, oils, powders and hand saniti

Walgreens.com/bathandsho

beauty enthusiasts get 5000 points for every $50 spent on*Of elmr or lesser price ttGood on next purCba se. Purchase requirement must be met in a single transaction, before tares and al ter discounts, store credit and redemption dollars are applied. Due to state and federal laws. points cannot be earned or redeemed on some items. Compete details at Walgreens.corrulialance top paced,hair accessoriesineeds, shampoos, conditioneis st.,:ers and Ire -alines Sutect to availability. #Card required for pramolional peding. Third item free, of equal c, lesser pee. ExciudesSonisare powe toothbrushes. refit heads. trialftravel saes ard all clearance dens 01 equal or lesser price Balance' Rewards card required foe promotionand baby cual care ixadtets The qualifying beauty spend total is calculated before taxes and shipping. and al ter discounts, redemption dotais and store credithave been applied. Complete detads at waigreens comibeaulyenthusiast nManufacturer coupon available in most Sunday papers or at Walgreens.com/Coupons. Ordollars are applied

N.002314

p at checkout when you spendivra s S20 or more on participating products.Good on your next in store purchase»'

get 1

CYO

off*cardeticse brand

COVERGIRLT RUC Lé ND

FIMMEL...NM ON

Na;tural Bronzereo.1 , n,enol

Urcr,ante

M E L ilime>, COVE RG I R L L'OREAL plus morcown,1011000 1,Brands

bath, bar soaps, liquid and foam hand_ers. Offer good in store and online ater,now thru7/281,18with card

rlrllr1.r . .,.,,r,,,,Includes all hair color. Offer good in store

and online at Walgreens.com/haircolornow thru 7/28/18 with card

beauty and personal care"

:t t

33 rewarc- 3000 bonus point

buy 1 get 1

50%offwith card Hair CareAussie. Head & Shoulders,Herbal Essences or Pantene.Select varieties.

ONLINE COUPON

2/$10or 5.49 ca. with card

OR

21$8with card &

s2 off couponon 20

Dove or TresemmeHair CareSelect varieties.

COUPON SAVINGS

or 4.49 ca. with cardOR


on 2 e most Sunday paperst

20offwith card ConairHair AppliancesSelect varieties.

Dore

3k",°

llE'addshoulders, PANTENE

MEN21

Oa Si.«mitred rature

white grapefruit& mosa mint

SMAYIn0

f M*NPOo1M6

.

2/$or 3.99 ea. 7

with card

52 off couponin mast Sunday paperst

Gamier WholeBlends Shampooor Conditioner12.5 oz.Select varieties.

DeAL

BOOST IT

VOLUME

INJECT

MOUSSE

Mktti

2/$7or 3.99 ea. with card

OR

2/$3with card &

s4 out couponon 2 in must

Sunday paperst

+$1 off coupon

online or in store*

L'Oreal Elvive HairCare Shampooor Conditioner, 12.6 oz. Select Stylers5.99 with card Shampooor Conditioner, 25.4 oz. Select Treatments

Gamier Fructis HairCare Select varieties.

walgreens.com/beautyenthusiastiss coupons to card at Walgreens.comtcigms. tOS`/ available on instore purchases ,Coupon aaadable at Walgreens con/Coupons Card and ovine rnaulacturer coupon required for pricing. **Or equal or lesser puce Ra'ancet Rewards card required for promotional pricing. Excludes men's hair color, tndittarel saes. hair apyances,al pricxtg. Subiect to availab:..ty lGood on next purchase Every qualtyirxg purchase adds up to the S50 spend requirement A qualifying beauty purchase includes products from the cloning categories fragrances, cosmetic skin caee, hair care. oral care and groomag products Excludes prescriptions. baby hair care. baby skin care71y available on instore purchases dttnly available on instore purchases Limit 1 Register Reward coupon per customer per offer See coupon for terms. restrictions and expiration Purchase requirement must be met in a single transaction, before taxesand after discounts. store credit and redemption

Ní)02375

Over $70 in coupon savings belowpi Coupon offer expires 07/142018

699with cardNeutrogenaNaturals Skin CareCleansers or Scrubs.Excludes wipes.Limit 3. No limits in NM.

11 I111111111M1111111119

pi Coupon offer expires 07/142018

250with cardNeutrogena SingleUse MasksLimit 3.No limits in NM.

a II I11111111 IIIIIIII!I!!11!11117


$3offwith cardCoppertone or Bainde Soleil Sun CareLimit 3. No limits in NM.

01111111111IIIIIIIIIIII11111115


$4offwith cardL'Oréal Skin CareRevitalift or Age PerfectMoisturizers.Excludes trial size.Limit 3. No limits in NM.

6aIl II Il Il Il II Ill IIIlIIIIII I

LUREAL 1

tnnvaws

KaiCoupon offer expires 07/14/2018

$2offwith cardAveeno Daily Moisturizingand Positively RadiantSkin Care ExcludesDaily Moisture, 2.5 oz.Limit 3. No limits in NM.

oll Ilbbb9!q iiiiiiiiii pp

Aveerió.

zaiCoupon offer expires 07/14/2018

1offwith cardBan Roll On Deodorant3.5 oz. or 2 pk.Limit 3. No limits in NM.

olII11111111IulI1IlIIIIIIIIl,


3500ffwith cardGillette DisposableRazors 2 to 12 pk.Limit 3. No limits in NM.

a1111111111111gIIlllll!13 llll

8

2


2offwith cardSchick, Edgeor SkintimateShave Cream or Gel6 to 8 oz. Limit 3.No limits in NM.

0 O 11111111I11111IIIIIIIIIIIll9

ga Coupon offer expires 07/14/2018

$3offwith cardNo7 CosmeticsLimit 3.No limits in NM.

o II II1111! Il!tHI ll!ll I ll I III 3

t_

vziCoupon offer expires 07/142018

$5ffwith cardNo7 Skin CareLimit 3.No limits in NM.

II 11111111 IIIIIIIIIIllIl 11III

H _ _

r

ONLY ATWALGREENS

PI Coupon offer expires 07/142018

$5offwith cardJohnson & JohnsonFirst Aid Kit140 pieces.Limit 3. No limits in NM.

111111IlIIIIIIIIIII11II) II8

kaiCoupon offer expires 07/14/2018

$100with cardCrest or Oral -B Vitality Floss Actionor Dual Clean Toothbrush Brush Heads, 3 pk. 3D Whitestrips,14 to 42 pk. Excludes Vivid and NoticeablyWhite. Limit 3. No limits in NM.

0-0Oil11III II III I II III III4 I IIl o


1offwith cardShea Moisture Skinor Bath CareExcludes Bar Soap.Limit 3. No limits in NM.

COIII 11II 11 IIIIIII11II11II I

il8


YiaK7$2offwith cardFeminine Care Stayfree Pads, 28 to 48 pk. Playtex Tampons, 32 to 48 pk. Carefree Pantiliners, 92 to 120 pk.Limit 3. No limits in NM.

o II 1111111111gIIlIIIIII!11III 5


2offwith cardNeilmed Sinus ReliefLimit 3. No limits in NM.

011111111111I IIIIII! III!11!II II 6

RNODES

I


ÛP4

OGig

UP4

25offwith cardUP4 Supplementsor Probiotics Ultra,30 ct. Women's, 60 ct.Limit 3. No limits in NM.

0111111111 IIIIIIIIIIIIIIII B

. a .

N902318

buy 1 get 1

ofu*with card

SK%,1 rewarc.0^pn honor


OR

2/$7with card

56 off on2cou&pon°

+3 rewarc

- 3000 bonus pointhen you spend ' 1

yei . .

Gillette, Secret or OldSpice Deodorantor Shave NeedsSelect varieties.

Schick DisposableRazors 3 to 12 pk.Select varieties.

HCOUPON SAVINGS

5/

599card-OR

399with card &

$2 off couponin most Sunday paperst

B/C

Bic DisposableRazors 2 to 10 pk.Select varieties.

= 5000 bonus pointswhen you spend Sts or morereward

x'.., produn, .r rewards

swaddlifi

COUPON SAVINGS

2/S18or 12.99 ca. with card

OR2$15with card &

53 off couponon 2 in most Sunday paperst

Pampers JumboPack Diapersor Training Pants18 to 35 pk.

3/S6 or 3.49 ea.with cardPampers Wipes 56or 72 pk. Select varie, 'e

511111111

TAM PAXrodbnc.ONLINE COUPON


OR


ci 2°

'File Care Tampax Pearlor Radiant Tempo,32 to 42 pk. Always:Select Pads.22 to 46 pk. Pantiliners,

148, or 62. pk.

COUPON SAVINGS

299w card

OR

99ewith card &

$2 off couponin most Sunday paperst

Mitchumor Lady MitchumDeodorant

buy 1 get 1 with card Eye or Ear CareWalgreens. Select varieties.5/0O off

LubricantEye Drops Eye Itch

Relief,oe..In. r ....ow... L....A,.M...-** t.. uv.

*Of equal or lesser price. tOnly avalable on in-store purchases. =Clip paperless coupons to card al Walgreens.com Coupons. ttGood on nextpurchase Purchase requirement must be met in a single transaction. before taxes and alter dscounts. store credit and redemption dollarsare applied. Due to state and federal laws. points cannot be earned or redeemed on some items Complete details at Walgreens comrttalance°Coupon available at Walgreens.com/Coupons Card and online manufacturer coupon required for pricing

buy 1 get 1

50OO

off*with card

33 off coupononline or in storet

05 off couponin most Sunday paperst

ru rift F.

Multi -PurposeSolutionFor SonContact Loose,

Dr. Scholl's InsolesSelect varieties.

HOMEOPATHIC

EarAcher"Drops

LU MtF YT"Redness Reliever Eye Drops

1399with cardLumify Eye Drops2.5 ml.

AufcH.wM

Soothe

_k9. -7f11 ,toacooH

COUPON SAVINGS .......»

699with card &

52 off coupononline or in store#

r30.rue..._...._

Bausch + Lomb EyeCare Select Soothe,Renu or Biotrue.

GEL DROPS

buy 1 get 1

50O/O

off*with card

coupon savingsin most Sunday paperst

buy 1 get 1

50:/f°f.with cardNeo-SynephrineNasal Spray, Chapstickor Campho-PheniqueCold Sore TreatmentSelect varieties.

Refresh Eye CareSelect varieties.

Canapho-Pheraique

-.--a ---

Carr:¡dro.{ñfnÌralMj

Refill your prescriptions in seconds. Walgreens.com

N.002317

,4

-

¡OS

Find care nowFor common illnesses andmore-online or in person.

See services

Digestive Care Walgreens. Select Omeprazole, Esomeprazole, OmeprazoleMagnesium, Wal -Zan° Anti-Diarrheal or Smooth LAX'.

Allergy Relief Walgreens.Select varieties.

FLUTICASONE

PROPIONATE

NASAL SPRAY, USPr . s

Well

Levocetirizine24 -Hour Allergy

buy 1 get 1 A O,

with card

7Llzl,rr:

MAIUMUMStRirrGIN --WaI-Zalri 150mum 1wlnw.ls,.r/ Lce DIM

. r.... ....._. .-e... .-..........144,TAeliiS

DIDeS(Si

All WalgreensSmoking Cessation

yrNicotineGum

Anti-DiarrhealLoperam:ao HCI: rnr,

Digestive Care Walgreens.Select Probiotics.

Probioticwv.LacWeeraw 10v..1mw OG.. ...:...r

+.we....+...r....r-....«.,

OV V off"mix & match

NicotineTransdermalSystem Patch

Vitamins and Supplements Walgreens.Select varieties.

,;RILL OIL VEGAProbiotic

Nome.,

Pain Relief Walgreens. Select varieties.

WellZf1tGjEwss

IbuprofenIbuprofen TabletsUSP. 200 mg / Pam Reliever /Fever Reducer (NSAID)

looTMLET4

GLUCOSAMINECHONDROIIIN

Mar>.erd1

CHTCrtIC COATEDed Dos,

Aspirin 81

All DayPain Relief

Nr7Ltryrcr,r i

N.p>.. SatNuen T.E41s. ile mqPen nw....I iw.r Red.n.. INutlef

1999with cardAllergy Relief XYZAL Nasacort, 120 sprays Afrrow.:irº Xyzal, 35 ct. \.. Allegra, 24 or 30 ct. C-3Select varieties. ;_

with cardFlonase Original Allergy Relief120 sprays.26.99 with cardFlonase Sensimist Allergy Relief120 sprays.

1999with cardClaritin Children'sAllergy Relief20 or 30 ct. or 8 oz.

1899with card &

St off coupononline or in storet

Zyrtec AllergyRelief SelectAdult, 24 to 30 ct.

899with cardt

s1 off coupononline or in storet

Advil Pain Relief 80 or 100 ct. PM, 40 ct.

buy 1 get 1

with card

s1 offonline coupono

62 rewar-'000 bonus points

NEW

l:aL=Zz`Zfluil

....tea..

Zzzquil Sleep Aids Select varieties.

$5offwith cardTheraworx ReliefFoam 7.1 oz.

buy 1 get 1

50°4),.with cardPain Relief Select Bayer,50 to 200 ct.Aleve: Select40 to 200 ct. Direct TherapyTENS Deviceor RefillGel Pad. 2 pk.

.r..-rs..rRr...NuuNQ.r,r+

srre.

e... .,.,,UL

10 *Of equal or lesser price °Coupon available at Walgreens conr.'Coupons Card and online manufacturer coupon required for pricing tap paperless coupons to card at Vialgreers.com/Couporu. ttGoad on next purchase Purchaserequirement must be met in a single transaction. beforetaxes and after discounts, store credit and redemption dollars are applied Due to state and federal laws. points cannotbeearned or redeemed on some items Complete details at Walgreens com/Balance

1e.002319

Refill prescriptionsand check refill status

in seconds

IIMLearn moreTap to watch

Available in the Walgreens App!

at Download on theApp Store

et, GET IT ON

Google Play

50

buy 1 get 1

0%off'with cardAll Certainty'Walgreens.

buy 1 get 1

0ofoff"

i

I

Q? CcrtuintVundauwa ra

Men & Ovaron

30 _

with card WalgreensHome Health CareSelect varieites.

buy 1 get 1

50%off*with card

+S3 off coupon

online or in mostSunday papers('

M.:':. c ^

SILVER',nc ttA:aY

Nmrt,>L

MelatoninSLEEP

kale.

Centrum Vitaminsand SupplementsSelect varieties.

buy 1 get 1 with card One A Day

0/Oor Natrol Vitaminsand Supplements

Off Select varieties.

ONLINE COUPON

1199 card

OR

899with card &

s3 off coupon°

reward`

Always Discreet Pads, 28 to 66 pk. Underwear, 9 to 19 pk.

EMITXMIZEIwith card 1199

less coupon fonline or in sturo Lless coupononline or in most eSunday papers'

final cost

699TENA Pads, 28 to 39 pk. Underwear, 12 to 16 pk.

'1 get 1

rewa r

Mmes t atines

24i"Yix

buy 1 get 1

50%off*with card

S3 off couponin most Sunday paperst

Glucernaor EnsureNutritionalShakes,4 or 6 pk.

buy 1 get 1

FREwith card Foster Grant

* Reader Glassesand Accessories

d =10,000 bonus pointswhen you spend S30 or moreon participating products.tr rewards

rfOR1 ReliefMpltí"5Ym

1)13r/f1r.1 ,'! U$

MAXfMUMSTRENGTH

0/O with card Digestive CareTurns, 32 to 150 ct. Lactaid, 32 ct. Zantac, 24 or 30 ct.off Imodium, 8 oz. or 18 ct. Pepcid AC or Complete, 25 or 30 ct.

with card Digestive with card MetamucilCare Miralax, 26.9 oz. 89.w 160 ct. Packets,4 on Adult Align, 24 or 28 ct.

i44 pk. Powder,

Prilosec OTC, 42 ct. 57 or 114 doses

42.,.,, Y..1{if(KUrryJ 1-JirlY.Of «gala lesser erice. 'Manufacturer cameo amate n most Sunday papers or at Walgreemscanicoupas. Ony, wanable en n s!ae prrcease5. *C0,90;1.3,13* atWaeprems.co?cCapoes. Card and °time r. amdactan coupon rewired for pricing. *Cbp paperless capons to ere at Walgreens corn/Coopers. ',Goad on next perchasePurchase requirement must be met n e sere transaction. before lanes and a=lter discounts. store credit and redemption Crzes are and ed. Due to state and tratti tan,Y.poets cannot be earned or redeemed on acre items. Complete details at Walgreens canlistance tOnly available on instatepurchases.

It's timeto savewith Medicare

Part D

Once you enroll,we'll help you save with

copays as low as $0 onselect plans, and 100 points

on prescriptions.*

Talk to ourpharmacist today

Z?Icz,erteefis.Trusted since 1901

'S0 copays apply to Tier 1 generics on select plans.Points good on next purchase. Points onprescriptions and other pharmacy transactionslimited to 50.000 per calendar year and cannot beearned in AR, NJ or NY. Only prescriptons pickedup in store are eligible to earn points. Completedetails at Walgreens.com/Balance.

Balance° Rewardsand AARP membership

cards arebetter together.

.., lai: ,SI .M ,rw, hut.. eri

RPLink your membership cards or accounts

to receive exclusive benefits.Walgreens.com/AARPcar

Refill your prescriptions in seconds. Get the app today.

NÁ02321

299 with card All LaundryDetergent Liquid,46.5 or 50 oz. Powercoreor Mighty Pacs, 18 or 22 pk.

á11l:JircL:233

n.

COUPON SAVINGS

with Si off coupononline or in store$

I;ldd

Paper Products Viva Paper Towels, 6 rolls Cottonelle:Bath Tissue, 12 rolls Wipes, 168 sheets

2/$ withFiber card

One or Natureor 2.99 ea. Valley Snacks 5 or 6 pk.

Select varieties.

FNANATUREVALIEy

CRUhChY..+.- r

.:; r, .. :.

'J. . rr

buy 2 get 3rd

FREEwith card

mix & match oral careIncludes toothbrushes, toothpaste, whitening kits,interdental, oral analgesics and mouthwash. 01 fargood In store and online at Walgroons.com/oralcarenow thru 7/28/18 with card

Schwaelmlrt

5.22.aa..: ! f!'ÚLULTIMEwr. MfN

buy 1 get 1

FRE

110

DEGTóxFY-

=BEM

_.GARNIGF- . . _...

with card* Blue Diamond Almonds

5 or 6 oz.

DIAMÓÑD;VVkole Natur

IGOURMET

..1i

cia,3XMORE

OrmelInstant Pain Relief

SEVERE7.er4rMi Grew .a./Ass

7RIPLEMEDKATED

buy 1 get 1

off.'with card

mix & match hair colorIncludes all hair color. Offer good in stir'and online at Waigreens.com/halrcolnrnow thru 7/28/18 with card

2/$or 3.99 ea.6

with card

Si reward1000 bonus points

ti

Hershey's Minis,Pouch or CanisterCandy 5.9 to 12 oz.Select varieties.

Euccu

v.- Kisses.cc= ;.

Gotvitamins.Change

lives:v Mimi-.onpol.

B-12buy 1 get 1

10.,

FREE*with cardNature's Bounty or Osteo Bi -FlexVitamins and SupplementsSelect varieties.

Gotvitamins.Changelives:

onpno)sm

buy 1 get 1

FREE'

r ola tun 'Mar1r

D, 2000u

rama..,

with card Nature MadeVitamins and SupplementsSelect varieties.

Wrretdr

Co() 10

3/$3with card 2 -Liter SodaPepsi, 7 Up, Dr Pepper,

or 2.19 ea.A&W, Sunkist or CanadaDry. Limit 3. No limits in

CRVwhere required.

499with card

34 mail -inrebate on 2t

Barefoot Wine750 ml.

19.99with cardTito'sHandmadeVodka 750 ml.

22.99with cardJamesonIrish Whiskey750 ml.

with card12 -PackBud Light,Budweiser,Miller or CoorsFamily of Products12 oz. bottles or cans.

Prices may vary by state. Alcoholic beverages available at select Walgreens locations. Plus deposit or CRV where required.

with card

$4 mail -inrebates

12 -Pack Heineken12 oz. bottles or cansor Stella Artois 11.2 oz.bottles or 11 oz. cans.

e

Hein

W Refill your prescriptions in seconds.* Walgreens.com 'See Walgreens .com for details .

beard neared f:' peonetenal preng Thad doh*, el galaltsset pike. Erzlides Saricare power toothbrushes refs teads.lriat,Rrarel sin andal dew =Ilan *Ol e: al e, lesser price. lCrp papp eSS CO, pan bcud a< walg ears wmtopcns **Of equal a lesser price. Batiste Rewards cud reared to personae' pricing. Elrbudes ilea's tar co*, trianrarel sºes, hair aearar es, baitaaasaiebteeds, shampoos, costilie rs,

st fiie's and treat-rts- Subject to availability "Geed on slut pudelas. Neese regluer eri rest be net in a simple transitlos, Wee tares and after Moults store aedl and redenlptioe dotes are illicit. Due to saxanti federal lairs, pants cocerot be eared a reeee^ed on some items. Claapiete detats al Wsgreens.coes d ee. AIYa.'geess will donate tla of participating products'rtd sales Wade to rttt-12ß1120101' m., met¡Relafelampretateser.Seebanlateers.eadsiorrsaeenlistBabated'rredWcx:!ara Must buy4a mare 750mi Wend Wee. reb essarelagenccard.

Percin promote,. and selectan may vary by location and on Wallruns can Balance' Rewards card required for sale pncmg Sale paces may not be available at as stores Inctudmg R%Press Mammiesand pharmary.onrr sxationsi. be bawled to your eat newspaper dstroz, n. and only white supplies last funded quantity refers and items r SI normaay avaiable al your lvalçrecn store do net quakly tor rainchecks or subsStulrons. Sale prices (Aimed for de dates ruled on the front page unless utherwae specified m the ad or m the cam Reels reserved to W YK M quantites on ad items. Purchase of excessquantities Ibeyvnd normal household usage) oe advertised items 'snot permitted Coupons muse he presented et the tme of purchase but Photo promo codes arnt be entered at lame of order placement Ilenemay not be exactly as pictured Items adrenrsed with Reg ter Rewards* a rebates are subtect to conditions and Omits estabiehed by the manufacturer See coupon or rebate tam for setae We reserve theright to correct typeurapir c or photographic errors For the toca ron nearest you, cad exude .SItEEIIS 1500.925.473311041 free a tad Walgreens.cmVFrndAStore. 02018 Walgieen Co. All rights reserved.

18

(Xliteead, Trusted since 1901

1'.002322

í S.CO

EXCLUSIV FFE.RSw SS a

000s of products you'll only find online. FREE 1 - 3 day shipping at $35+ or FREE Ship to Store.

FSA

"ACUVLIE20%

/ ..,s, offAll Contacts

SHOP NOW >

20 off/ 20 offNova Transport Chairs

Heat up your look

25% offbeauty & personal care*Use online code HEATUP

Shop nowJ

regular encase items only.'

20 offStander Mobility Aids

SHOP NOW) SHOP NOW) SHOP NOW >

Kansan Wheelchairs

20 %off

Juvo Rollators

SHOP NOW )



January 10, 2020



in O Search

Master of Legal Studies - Online Master's from WashU - Bachelor's required. No GRE/LSAT requirement An

WalgreensRetail Deerfield, IL 338,453 followers

Trusted since 1901.

+ Follow

Home

About

Life

Jobs

People

Ads

HI)011t

Life

Jobs

People

Ads

Life

Jobs

People

Ads

Life

Visit website tr

OImages

PWalgreens333,53 fo r. ers04 0)

Happy New Year to all of our team members - and a special shoutout to the team

at our flagship store in Times Square. who know tomorrow night will be the onetime it's OK to drop the ball. See how they ring in *NYE in the middle of ...see more

Documents Videos

0 0 fit 345.8 Comments

like Q Comment Fÿ Share

Stay one step ahead

See exclusive Premium insights on 450ko companies

Upgrade to Premium

PWalgreens333453 fo' owers>w®

Top e.

+ Follow ...

+ Follow ...

Did you miss Pink Sunday at Walgreens yesterday? No worries! Claudia Fiorello,beauty consultant with Walgreens shows us the ins and outs of this season's topbeauty box from Soap and Glory. Originally 140, this set is on sale this err ..see store

1 person from your company was hired here

See all 90,769 employees on Linkedln 9

Highlights

Explore hashtag #walgreens

Etable,794 folcwers

11,144 recently posted jobs

PSpecialist Anti -Money LaunderinDeerfield. IL US

Customer Service AssociateCrest Hill It. US

411.142 more jobs

An experience of a lifetime.

Front retail

managementto corporatesupport

center andpharmacy to distribution, we haveinternship opportunities to match yourcareer goals. For 10 weeks you'll buildyour professional network gain hands-onexperience, a...

Show more v

Affiliated pages

Walgreens Boots

AlliancePharmaceuticals79.535 followers

Duane ReadeRetail

7.913 followers

+ Follow

+ Follow

Ad

Istest jobs and ^dusny ^evilrxpiore relel

with Wal

FOIIOW

Si

ems t_VS H hhHeabh.

+ Followh...

pany alumnus

Wert + FollowRetail

29 school alumni

^"""' t FollowHospital & health...

company alumnus

in

I Home

About

Life

Jobs

People

Ads

Life

Jobs

People

Ads

Life

Jobs

People

Ads

https://www.Iinkedin.com/company/walgreens/Internet I x¡tlate r 11.0.1/ /6 I.7/1

What do you do when you'reintroducing a new holidaytoy line at Walgreens?

00 aWalgreens Toys Expert Panel: Over the Moon & Rainbow Dreams

O oe, '19 'tcnment 933.4, es,

Like El Comment (*Share

to

O e Yri ' cc,rnents

Like Q Comment F> Share

PWatgr ens338.453 fo' avers1w®

#2019 was a big year for us at Walgreens. From exciting technology innovations (canyou say drones?) to new strategic partnerships to health -promoting initiatives, teammembers across the country made an impact on our customers and corn ...see nto'e

+ Follow

Top 10 Walgreens Moments of 20191 Walgreens Newsroom

-e vs.,..s greens car,

OerJ.3'3ccm ents

Like Q Consolent 4, Share

Walgreens

?ment i Shareisiike.33.3-5.3 ro mers

+ Follow ...

'It's more than a Walgreens. It's more than their Walgreens. They're a truecommunity location that everybody recognizes.' Find out how store managerStephanie Collins is inspiring her team members to take care of their con ..see mcre

, .

'We're more than Just a store'

O o LJ

al Like Q Comment 4> Share

fe the first to comment on this

Similar pages

lecvstt

CVS Health + FonowHospital & Heaitn...

w 1 company alumnus

WalmartReta,

29 school alumni

TargetRet.

44 school alumni

Show more v

iron CVS HealthHeaäts.

Hcsp :al 3i I -ea tt ..

.l.

t

+ Follow

+ Follow

+ Follow

1 company alumnus

WalmartRes.

4, 29 school alumni

TargetRetal

4/ 44 school alumni

Show more v

+ Follow

+ Follow

t_vs Hearin + FollowHasp,lal .°. Hea tn...

1 company alumnus

WalmartRetan.

óc-' 29 school alumni

TargetRetar

C" 44 school alumni

Show more v

9:46:31 AM 1/6/2020

Windows 10 I ntrr¡triee I ISC 2019 64 hit liuikl 11/61

+ Follow

+ Follow

eig Massaging



January 10, 2020



= QYouTube

Home

eTrending

Subscriptions

pLibrary

Search

Trusted since 1901''

Waigreens48.3K subscribers

HOME

Created playlists

How We Care

VIEW FULL PLAYLIST

Uploads PLAY ALL

VIDEOS

Beauty

PLAYLISTS

VIEW FULL PLAYLIST

COMMUNITY CHANNELS

Holiday Retail

VIEW FULL PLAYLIST

... IP...

SUBSCRIBE

ABOUT

Holiday Beauty

VIEW FULL PLAYLIST

Q

ürrur<i

ehucFh+lla,yscnry

0:28

t' '.$1 '4.'67..

u .rieHwGysro.y -

#TrueHolidayStory with Neiland David - Gift On The Fly

236 views 2 weeks agoCC

#TrueHolidayStory with Neiland David - Menu Wrapping

182 views 2 weeks ago

CC

#TrueHolidayStory with Neiland David - Juggling


CC

#TrueHolidayStory with Neiland David - The Cold


CC

Specialty Pharmacy Management, LLC v.

Walgreen Co. Opposition No. 91236453


9:11:30 PM 1/9/2020 https://www.youtube.com/user/walgreens



January 10, 2020



See anything you don't like? Lets edit your home feed!

IMP- we",.Q Search for Shrimp Recipes

AleCaenwMwm....wwi

111

C1

My9

'es

r ekto_Walgreens10m+ monthly viewers

www.walgreens.com

'p! ==_

^^ +1,

i.

Not now Edit my home feedJ

am... ®

gg$

s

0 jp ...

Follow

"We believe in working, not waiting; in laughing, notweeping; in boosting, not knocking and in thepleasure of selling products." - Charles Walgreen

Activity Community Shop

50 Boards

Feel More Like You MI New Year New Bea...12 Pins 10 Pins

11111111111

Cold & Flu Care9 Pins

1012MIMPI

heaimemp bleerIneme

11.11M111.rWimp

Fall Beauty23 Pins

Specialty Pharmacy Management, LLC v.Walgreen Co. Opposition No. 91236453Applicant's Trial Exhibit 74

1 ;..., ! n !'r-1"r17-",,

1.7

Holiday Beauty 201814 Pins Follow

es yoursun care 101

Su.pnssngaces you need

esun care 101

Surpnsingfacts you need

1:3 Summer Beauty, Ski... 1121222 Pins

i

Holiday Photo Card...261 Pins

Follow Walgreens Fall Beauty89 Pins

FollowGrad Gifting66 Pins

9:13:29 PM 1/9/2020 https://www.pinterest.com/walgreens/boards/



January 10, 2020



Pringles

Q__3 !_.

walgreens 1,319 posts 294k followers 46 following

Follow

Log In Sign Up

Walgreens

We champion the health and well-being of every community in America. Trusted since

1901. A Member of Walgreens Boots Alliance.

Suncare RND Heroes

OSTS

4111 Mat pet

probably meet my Soulmate in a walgreens

IGTV

-1^'`;3

Specialty Pharmacy Management, LLC v.Walgreen Co. Opposition No. 91236453Applicant's Trial Exhibit 75

TAGGED

G H

\*// r'sJ

;!h ,.. mp t..e (l't n i m' r... , t' 1'0

P

enorm.* imamL rv^I..M.n u

It's not last minute until you find yourself at aWalgreens at 9pm on the 24th looking for stockingstuffers.

Suggested

X

walgreens

Ui U4(1911[1.

S

cvspharmacy

X , I.walmart

X

Otarget e

X

See All

jcpej

Log In to Instagram

Log in to see photos and videos from friends and discover other accounts you'll love.

7:48:15 PM 1/9/2020 https://www.instagrarn.coni/walgreens/?hl-en

Log In



January 10, 2020



Walgreens e,1Pt'atQ;ze2iïs

Home

About

Photos

Locations

Weekly Ad

Videos

Posts

Community

Events

Jobs

Create a Page

Trusted since 1901

sir Like 4 Share g' Suggest Edits

Photos

Null.

i'II probably meet my Soulmate in a walgreens

nr hMa Mweu

r+r I.w., nunute urea you find yoursed at aWalgreens at 9pm on the 24th looking for stocking.fattens

ht

Mt think my dad got n>) mom the worst g.tt in the h.storyof toed (hits

s

Videos

lA

See All

Use App

WalgreensCompany

Send Message

Community See All

Ear 4.472,488 people like this

4,228,900 people follow this

About

ww w.walgreens.com

Company

See All

0 Page Transparency See More

Facebook is showing information to help you betterunderstand the purpose of a Page. See actions taken bythe people who manage and post content.

\Z1 Page created - August 20. 2009

People

4,472,488 likes

2,018,652 visits

Related Pages

* Macy's.rnocyrs Retai; Compas,

t` WalmartO' Retaif Company

OTargetORetar Company

CVS Pharmacy_

r,Family Dollar0

Specialty Pharmacy Management, LLC v.Walgreen Co. Opposition No. 91236453


Neil & David Prese t #Tpie ..

ff

('1./ CC' (/)(t('i 11 * 201

Posts

lAJ.lrrrsnwo-

See All

See more of Walgreens on Facebook

Log In o

r Retail Company

See Vcre

Pages Liked by This Page

Coca-Cola

COVERGIRL

Create New Account

7:46:')0 PM 1/9/2020 Irti ps://www.facebook.conl/VValcir eons/



January 10, 2020



BOGO FREE & BOGO 50% off vitamins

Wzé9teead. Search by keyword or Item Q Your account . I Find a t

Rx Refills Find Care Contact Lenses Shop Photo Weekly Ad & Coupons Balance Rewards

Start the year fresh

BOGO FREE &BOGO 50% offon thousands of vitamins& supplements*

Shop now

Top deals up to 50% offShop now

Shop by Category

.4ClNl!E :^-w ,

Contact Lenses Beauty

4.»

_OMATIIRÜS BOJNi

Biotin10,000..4

2123

Up to 60% off clearanceShop now >

Personal Care

611U1<N - IOMI!.

PreserYisions rme,al surmmo,.

AREDS 2 e,r)

25% off all contactsGet code.

4

TYLENOLaeaa><nu=E.,., Merrell

Medicines &Treatments

Specialty Pharmacy Management, LLC v.

Walgreen Co. Opposition No. 91236453


FREE 1-2 day shipping at $35+ or FREE Ship to Storer

Share the best of 2019

50% offPrints, Posters

o

4

Order prints

60% off select Wall DécorCreate now

30% off Photo GiftsCreate now

60% off Photo CardsCreate now

OrderPrints

1Saved Upload Your Photo

Projects Photos Photos Cards

FREE Same Day Pickup on Prints, Photo Books and more e

Save up to eachMedicare Part Dprescriptionwhen Walgreens is your Preferred Pharmacy

Get startedJ

Stay on track with your RxLet us show you how

Update insurance info in asnap

Get the Wakgreens App

Cough, cold & flu reliefShop now

RefillPrescription

(111-..9

BBB

u_QPrescription Drug Appointment Pharmacy

Status Info Scheduler Chat

FREE shipping on all prescription refills if

- a

7,redi4!

Pick up anddrop off Fed Expackages atWalgreensLearn more >

Get exclusive offersSign up to receive weekly deals,valuable health information andmore.

Email Ac Sign up

+Ways to Live Well

Manage familyprescriptions

Create a Photo Gift

See what's on sale

Top Brands

Join BalanceRewardsThe more points you earn, thebigger your reward.

Joinnow

Schedule yourimmunizations

Meet your local pharmacist

Order contact lenses

Every one countsDonate 25c and provideHo-changrnp vit nns to r,

a child for , n snot year.

Find a store

Get our free mobileappRefill prescriptions, printphotos, clip coupons andmore.

ÁppStoZ GoogcVly

STop SearchesContacts

Acuvue Oasys

Nol

L'OREAL'

iMove past painOur pharmacists arc specialty trainedto heei you manage your pan.

Learn more >

Find a Walgreens nearyouSearch your nearest 24 -hour store,drive-thru pharmacy, photo lab andmore.

9 Zip C Search

Mucinex

Makeup

Flonase

PAres N°7 Advil

Enter email for weekly deals Sign up

Customer ServiceShipping

Returns

Product Recalls

Fraud Information

Contact Us

Website Accessibility

Site Map

Help

Balance® RewardsOffers

Program Details

BR for healthy choices

FAQs

Terms and Conditions

Contact Us

Walgreens StoresFind a Store

Weekly Ad

Savings & Deals

Sweepstakes & Promotions

Special Email Offers

Healthcare Clinic

Flu Shots

Photo Blog

Paperless Coupons

Walgreens MobileAPI Program

Accessibility Notice

Company InformationHARP®

Careers

Company Info

Disability Inclusion

Diversity & Inclusion

Investor Relations

Newsroom

Walgreens Logos

Sell Your Pharmacy

Social Responsibility

Califomia Transparency Act

Modem Slavery and Human Trafficking

Affiliate Program

Suppliers

Do Not Sell My Personal Information

Notice of Privacy Practices I Terms of Use I Online Privacy & Security

© Copyright 2020 Walgreen Co. 200 Wilmot Rd. Deerfield IL All rights reserved.

AllianceRx Walgreens PHome Delivery Pharmacy

Specialty Pharmacy

Business SolutionsCenter for Health & Wellbeing I

Respiratory Services

Walgreens Boots Allfan(

View all products by:As Seen on TV I Baby. Kids & Toys I Beauty I Contact Lenses I Diet & Fitness I Grocery

Home Medical Supplies & Equipment I Household I Medicines & Treatments I Natural & OrganicPersonal Care I Seasonal I Sexual Wellness I Vitamins & Supplements I Walgreens BrandTop Walgreens Searches Shop by Brand

Top photo products:Photo Prints. Posters and Enlargements I Photo Cards I Canvas & Dècor J Photo Books

Photo Calendars I Photo Gifts I Same Day Pickup Shop All Products

Restrictions apply. See WaIgreens.com/Offerdetails for more information.

t Restrictions apply. Free shipping details I Ship to Store details I Walgreens return policy

PRICING PROMISE: Walgreens will honor the lowest price posted on the sales floor for in-store ptime limitations on the sales floor, intemet advertised prices excluded as intemet price may differ fr

7:50:11 PM 1/9/2020 https://www.walgreens.com/

HIGHLY CONFIDENTIAL



January 10, 2020



CONFIDENTIAL

ESTTA Tracking number: ESTTA1112734 02/06/2021

Documents

Transcript of ESTTA Tracking number: ESTTA1112734 02/06/2021