MARK PATANE, et al. v. NESTLÉ WATERS NORTH AMERICA, INC.

CourtDistrict Court, D. Connecticut
DecidedMarch 28, 2026
Docket3:17-cv-01381
StatusUnknown

This text of MARK PATANE, et al. v. NESTLÉ WATERS NORTH AMERICA, INC. (MARK PATANE, et al. v. NESTLÉ WATERS NORTH AMERICA, INC.) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MARK PATANE, et al. v. NESTLÉ WATERS NORTH AMERICA, INC., (D. Conn. 2026).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT --------------------------------------------------------------- x MARK PATANE, et al., : : Plaintiffs, : MEMORANDUM & : ORDER -against- : : 3:17-CV-1381 (VDO) NESTLÉ WATERS NORTH AMERICA, INC., : : Defendant. : --------------------------------------------------------------- x VERNON D. OLIVER, United States District Judge: Before the Court are Defendant’s motions to preclude, including: (1) the motion to preclude the proffered testimony and opinions of Plaintiffs’ proposed damages expert, Dr. Phillip Johnson, who claims to have used hedonic regression analysis to estimate a differential between the prices consumers paid for Poland Spring (“PS”) bottled water products and the prices they hypothetically would have paid if those bottled water products had been sold with a substitute “purified water” label,1 and (2) the motion to preclude the proffered testimony and opinions of Plaintiffs’ proposed survey expert, Dr. J. Michael Dennis, who designed a consumer preference survey and conjoint survey.2 After considering the parties’ filings,3 and for the reasons discussed below, the Court denies Defendant’s motions to preclude. I. BACKGROUND In this putative class action, the plaintiffs allege that bottled water they purchased from the defendant was not “spring water” as defined by the standards of identity as incorporated

1 ECF No. 735. 2 ECF No. 738. 3 ECF Nos. 735, 736, 737, 750, 751 (Johnson); ECF Nos. 738, 739, 747, 748, 752, 753, 754 (Dennis). into the law of various states. Put more simply, they allege that Nestlé’s “Poland Spring Water” (“PSW”) is not actually “spring water,” despite branding and advertising claiming as much. This action has seen two motions to dismiss and three motions for summary judgment.4 The

third summary judgment motion, the most recent dispositive motion, was resolved by the Court (Meyer, J.) on December 30, 2024. Following transfer of the matter to the undersigned, this Court denied the parties’ cross-motions for reconsideration of Judge Meyer’s December 2024 ruling granting in part and denying in part Defendant’s motion for summary judgment.5 II. LEGAL STANDARD Federal Rule of Evidence 702 provides that a qualified expert “may testify in the form of an opinion” if the proponent of the expert demonstrates to the Court that “(a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the

evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; and (d) the expert’s opinion reflects a reliable application of the principles and methods to the facts of the case.” Fed. R. Evid. 702. District courts perform a “gatekeeping” function in deciding whether an expert’s testimony is admissible under Rule 702, Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579,

597 (1993), one that operates within the “liberal standard of admissibility” embodied by Rule 702. See Nimely v. City of New York, 414 F.3d 381, 395–96 (2d Cir. 2005). In defining the

4 See Patane v. Nestlé Waters N. Am., Inc., 314 F. Supp. 3d 375 (D. Conn. 2018) (Patane I); Patane v. Nestlé Waters N. Am., Inc., 369 F. Supp. 3d 382 (D. Conn. 2019); Patane v. Nestlé Waters N. Am., Inc., 478 F. Supp. 3d 318 (D. Conn. 2020); Patane v. Nestlé Waters N. Am., Inc., 583 F. Supp. 3d 341 (D. Conn. 2022); Patane v. Nestlé Waters N. Am., Inc., 761 F. Supp. 3d 424 (D. Conn. 2024) (Patane V). 5 Patane v. Nestle Waters N. Am., Inc., 786 F. Supp. 3d 474 (D. Conn. 2025) (Patane VI) gatekeeping role of the Court, the Second Circuit has distilled Rule 702’s requirements into three broad criteria: (1) qualifications, (2) reliability, and (3) relevance and assistance to the trier of fact. Id. at 396–97. Put another way, “Rule 702 governs the admissibility of expert

testimony: the expert must be qualified, his testimony must be helpful, and his conclusions must derive from reliable principles and methods.” Structured Asset Sales, LLC v. Sheeran, 120 F.4th 1066, 1077 (2d Cir. 2024). Whether the witness is “qualified by knowledge, skill, experience, training, or education to render his or her opinions as an expert” is a “threshold matter” that courts consider before analyzing the relevance and reliability of the testimony itself. Vale v. United States, 673 F. App’x 114, 116 (2d Cir. 2016) (citing Nimely, 414 F.3d at 396 n.11). A witness is qualified

where he or she has “superior knowledge, education, experience, or skill with the subject matter of the proffered testimony.” United States v. Tin Yat Chin, 371 F.3d 31, 40 (2d Cir. 2004). However, the Second Circuit has indicated that an expert’s knowledge need not be perfectly tailored to the facts of the case. See Stagl v. Delta Air Lines, Inc., 117 F.3d 76, 81– 82 (2d Cir. 1997). “If an expert has educational and experiential qualifications in a general field closely related to the subject matter in question, the court will not exclude the testimony solely on the ground that the witness lacks expertise in the specialized areas that are directly

pertinent.” Tardif v. City of New York, 344 F. Supp. 3d 579, 598 (S.D.N.Y. 2018). If an expert meets the threshold requirement of qualification, the Court then must determine whether the expert’s testimony itself is reliable. In Daubert, the Supreme Court identified several factors that may be considered in assessing reliability: (1) whether a theory or technique “can be (and has been) tested,” (2) “whether the theory or technique has been subjected to peer review and publication,” (3) a technique’s “known or potential rate of error,” and “the existence and maintenance of standards controlling the technique’s operation’” and (4) whether a particular technique or theory has gained “general acceptance” in the relevant scientific community.

Amorgianos v. Nat’l R.R. Passenger Corp., 303 F.3d 256, 265 (2d Cir. 2002) (quoting Daubert, 509 U.S. at 593–94) (internal quotation marks and citations omitted). These factors, however, do not constitute a “definitive checklist or test.” Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137, 150 (1999). Instead, the inquiry is a flexible one and must be “tied to the facts of a particular case” with attention to “the nature of the issue, the expert’s particular expertise, and the subject of his testimony.” Id.; see also Nicholas v. Bratton, 376 F. Supp. 3d 232, 290 (S.D.N.Y. 2019) (stating that “[w]here a proposed expert witness bases his testimony on practical experience rather than scientific analysis . . . courts recognize that [e]xperts of all kinds tie observations to conclusions through . . . general truths derived from . . . specialized experience”) (internal quotation marks and citations omitted). Next, in addition to ensuring that expert testimony is reliable, the Court must decide whether the expert’s testimony is relevant, i.e., whether it will “help the trier of fact.” In re

Mirena IUD Prod. Liab. Litig., 169 F. Supp. 3d 396, 413 (S.D.N.Y. 2016).

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MARK PATANE, et al. v. NESTLÉ WATERS NORTH AMERICA, INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mark-patane-et-al-v-nestle-waters-north-america-inc-ctd-2026.