Plaintiffs might try to establish such a draw by submitting an expert opinion and report that there was such a draw. In UMG Recordings, Inc. v. Sinnott, n255 a recent district court case, the court concluded that such a report could meet the reliability requirements of Daubert v. Merrell Dow Pharmaceuticals, Inc. n256 and be helpful to a jury, and therefore be admissible under Federal Rule of Evidence 702. n257 The UMG court held that it is not even necessarily required that the expert quantify the draw. n258