1. Smith & Wesson Warranty Card Information
178. Ms. Allen use of information taken from Smith
& Wesson warranty card returns to calculate whether the
supply of handguns to a state exceeded so-called
"legitimate demand" was appropriate.
179. Ms. Allen's use of this information was based
on a number of reasonable assumptions, including: that
the purchasers voluntarily returning warranty cards were
representative of Smith & Wesson handgun purchasers;
that the Smith & Wesson handgun purchasers returning
the warranty cards were representative of handgun
purchasers; and that Smith & Wesson handgun
purchasers could be used as a proxy for legitimate
demand.
180. The assumptions made by plaintiff's expert
regarding the Smith & Wesson warranty card returns
were well founded.
181. Ms. Allen's use of the Smith & Wesson
warranty card information along with other evidence in
the case to estimate legitimate demand was a
reliable basis upon which to conclude that any particular
state was "oversupplied" with handguns by defendants.