Case 1:13-cv-04578-RMB-JS Document 212 Filed 01/29/15 Page 63 of 123 PageID: 4246 customers. This definition shall include, but not be limited to, the following systems: franchisees’ SecureTM, ClickIt and/or APIS. means the support guide containing, among other things, “Operations Manuals” required operating standards and procedures for compliance with the 7-Eleven System and 7- Image (as those terms are defined in the Store Franchise Agreement). means the department within Defendant 7- “7-Eleven’s Accounting Department” Eleven, Inc. that deals with, or has control over, accounting. franchisees’ means a physical count of the Inventory, Receipts, Cash Register Fund, “Audits” cash, bank drafts, and supplies of items for which Defendants, individually and/or collectively, earn a commission, pursuant to 7-Eleven’s normal procedures. means the 7-Eleven department and/or team in charge “Profit Assurance Team” of covert mobile surveillance of franchisees. Upon information and belief, “Profit Assurance was a term coined by Mark Stinde, a 7-Eleven employee. Team” Investigations means the team and/or department within 7- “Centralized Team” Eleven tasked with investigating franchisee and facilitating the take back of stores franchisees’ (commonly referred to as “Take-Backs.”) means the Asset Protection “Asset Protection/Loss Prevention Department” and/or Loss Prevention Department within 7-Eleven tasked with monitoring franchisees for allegations of fraud, misreporting, or any other untort conduct. Upon information and belief, these are company-specific terms. Protection means those individuals within the Asset “Asset Investigators” Protection/Loss Prevention Department tasked with conducting investigations of Franchisees.
Case 1:13-cv-04578-RMB-JS Document 212 Filed 01/29/15 Page 63 of 123 PageID: 4246 franchisees’ customers. This definition shall include, but not be limited to, the following systems: SecureTM, ClickIt and/or APIS. “Operations Manuals” means the support guide containing, among other things, required operating standards and procedures for compliance with the 7-Eleven System and 7- Image (as those terms are defined in the Store Franchise Agreement). “7-Eleven’s Accounting Department” means the department within Defendant 7- Eleven, Inc. that deals with, or has control over, franchisees’ accounting. “Audits” means a physical count of the Inventory, Receipts, Cash Register Fund, cash, bank drafts, and supplies of items for which Defendants, individually and/or collectively, earn a commission, pursuant to 7-Eleven’s normal procedures. “Profit Assurance Team” means the 7-Eleven department and/or team in charge of covert mobile surveillance of franchisees. Upon information and belief, “Profit Assurance Team” was a term coined by Mark Stinde, a 7-Eleven employee. “Centralized Investigations Team” means the team and/or department within 7- Eleven tasked with investigating franchisee and facilitating the take back of franchisees’ stores (commonly referred to as “Take-Backs.”) “Asset Protection/Loss Prevention Department” means the Asset Protection and/or Loss Prevention Department within 7-Eleven tasked with monitoring franchisees for allegations of fraud, misreporting, or any other untort conduct. Upon information and belief, these are company-specific terms. “Asset Protection Investigators” means those individuals within the Asset Protection/Loss Prevention Department tasked with conducting investigations of Franchisees.