A sample memorandum of law supporting a Daubert motion and related motions in limine to exclude a survey expert's testimony and evidence related to the survey from a patent litigation trial. This Standard Document contains integrated drafting notes with important explanations and drafting tips. It includes common challenges under Federal Rule of Evidence 702 concerning the survey expert's qualifications, expert disclosures, population definition and sampling methods, questions and structure, and expert analysis. It also includes challenges under Federal Rule of Civil Procedure 37(c) and Federal Rule of Evidence 403.