Contract analysis

I. DEFINITIONS As used in these Interrogatories, the following terms shall have the meanings set forth below: 1. "MERIDIAN FRESH Products" means all household cleaning products — including but not limited to all-purpose spray, glass cleaner, disinfecting wipes, and dish soap — marketed, sold, distributed, offered for sale, or otherwise made available to consumers by Brindoval under or in connection with the mark "MER

II. INSTRUCTIONS The following Instructions apply to each of the Interrogatories set forth below and shall be read in conjunction with the Definitions above:

1. Each Interrogatory is to be answered separately and fully in writing and under oath, in accordance with Rule 33 of the Federal Rules of Civil Procedure. Each answer shall restate the Interrogatory immediately preceding the response.

2. If any Interrogatory cannot be answered in full after the exercise of due diligence, answer to the fullest extent possible, specify the reason for any inability to answer fully, and state whatever information, knowledge, or belief You have concerning the unanswered portion. An Interrogatory shall not be left entirely unanswered merely because an exhaustive answer cannot be provided.

3. If You object to any Interrogatory or any part thereof, state the objection with specificity, including the legal and factual basis therefor. Notwithstanding any objection, You must answer the non-objectionable portion of the Interrogatory to the fullest extent, and the objection shall not serve as a basis for withholding otherwise responsive information.

4. If You claim any privilege (including attorney-client privilege) or work-product protection as a basis for withholding information otherwise responsive to any Interrogatory, You must provide a privilege log in accordance with Rule 26(b)(5)(A) of the Federal Rules of Civil Procedure and Local Civil Rule 26.2, identifying each withheld responsive item with sufficient detail — including the date, author(s), recipient

5. These Interrogatories are continuing in nature pursuant to Rule 26(e) of the Federal Rules of Civil Procedure. If, after serving Your responses, You obtain or become aware of additional information that renders any response incomplete or inaccurate, You are obligated to supplement or amend Your responses in a timely manner.

6. Where an Interrogatory asks You to "describe," provide a narrative response with sufficient factual detail to enable Plaintiff to understand the facts responsive to the Interrogatory, including all relevant dates, the identities of persons involved, and the substance of any relevant Communications or events.

7. The use of the singular form of a word includes the plural, and vice versa. The use of any gender includes all genders. The terms "and" and "or" shall be construed both conjunctively and disjunctively as necessary to bring within the scope of any Interrogatory all responses that might otherwise be construed to be outside its scope. The term "including" means "including but not limited to."

8. Time Period. Unless otherwise specified in a particular Interrogatory, each Interrogatory covers the period from January 1, 2021 through the date of Your verified response.

III. INTERROGATORIES INTERROGATORY NO. 1 — Corporate Identity and Structure Identify Brindoval Home Goods Inc. by providing its full legal name; state and date of incorporation; principal office address (which Plaintiff understands to be 7200 France Avenue South, Suite 300, Edina, Minnesota 55435 — confirm, deny, or clarify); name and address of its registered agent (which Plaintiff understands to be Northland Statut