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Thomas & Betts Corp. v. Leger11/24/2004
Respondent Thomas & Betts Corporation (T&B;, a manufacturer of waste-oil furnaces, brought an action against appellant Ronald Leger, one of its distributors, alleging tortious interference with prospective and existing contracts, defamation, deceptive trade practices, breach of contract, unjust enrichment, unfair competition, consumer fraud, and fraud and misrepresentation. T&B;later amended its complaint to add Janet Leger, Ronald Leger's wife, and Independent Waste Oil Furnaces, Inc. (IWOF), the Legers' newly created distributing company, as defendants. T&B;also added claims for trademark dilution and infringement, fraudulent conveyance, and punitive damages. The claims against the Legers and their company arose primarily out of Ronald Leger's sales and service of T&B;furnaces following his termination as a distributor.
After two years of litigation, two orders compelling discovery, and three contempt orders for failure to comply with an ex parte temporary restraining order, the district court entered a default judgment against the Legers and IWOF in the amount of $578,230.48. The court later vacated the judgment against Janet Leger and the company for lack of personal jurisdiction. Ronald Leger now appeals from the default judgment and from the denial of his motion to vacate the judgment, arguing that (1) as a discovery sanction, the default judgment is neither fair nor related to the particular claims at issue in the orders compelling discovery; (2) the evidence is insufficient to establish a prima facie case of liability or damages on any of T&B;s claims; (3) the judgment should be vacated as void under Minn. R. Civ. P. 60.02(d) because he was denied his due-process right to cross-examine T&B;s witnesses and to provide input into the proposed findings of fact and conclusions of law; (4) the judgment should be vacated under Minn. R. Civ. P. 60.02(f) for " ny other reason justifying relief" from the judgment; and (5) the district court's grant of permanent injunctive relief is illegal because the court did not make adequate findings or set forth its reasons for granting injunctive relief. By notice of review, T&B;argues that the district court abused its discretion by (1) vacating the default judgment against Janet Leger and IWOF and (2) refusing to award T&B;damages on its trademark-infringement and trademark-dilution claims.
FACTS
Thomas & Betts is a Memphis-based corporation that manufactures waste-oil furnaces under the REZNOR trademark. T&B;sells its furnaces through a network of authorized distributors who, in addition to selling, are required to make warranty repairs, for which they are later compensated by T&B;
Ronald Leger (Leger), the sole proprietor of Independent Distributing, became a T&B;distributor in 1997. Leger signed a Distributor Contract Stocking Plan, under which he agreed to (1) sell Reznor waste-oil furnaces as his "exclusive line" of furnaces, (2) " ctively promote" the sale of Reznor furnaces, (3) service furnaces as required by customers, and (4) refrain from using the T&B;name or any of its trademarks without prior written approval. Leger also signed a service agreement, under which he agreed to restrict his sales to Minnesota (except the northwest portion) and Wisconsin. Specifically, Leger agreed "not to actively promote or market Reznor waste oil heaters in... North Dakota, South Dakota, or Iowa."
In March 2000, Leger ordered 90 new Reznor furnaces worth approximately $240,000. Leger stopped making payments on the furnaces, however, after T&B;refused to honor an approximately $47,000 claim that Leger had submitted for warranty repairs. Leger contended th
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