must make a “substantial investment in the trademark.” Moodie, 889 F.2d at 743. In Moodie, we explained the reason for requiring investment: The rationale behind this holding is that de minimus investment in a trademark is not sufficient for the alleged dealer to be “over the barrel” so as to warrant protection under the WFDL. As the WFDL protects dealers who face inherently superior bargaining power, those dealers with only a de minimus investment in the grantor’s trademark are not implicated. Moodie, 889 F.2d at 743. There, we held that the mere use of business cards did not amount to a “substantial investment,” even though the plaintiff at times printed his own cards. 889 F.2d at 743. See also Foerster, Inc. v. Atlas Metal Parts Co., 105 Wis.2d 17, 20, 313 N.W.2d 60 (Wis.1981) (<HOLDING>). Similarly, in Rakowski, we held that the
holding that probable cause is something more than mere suspicion holding that a factual finding must be supported by more than mere surmise or suspicion holding that even if such claims are cognizable under state law they are preempted in the case of generic drug manufacturers holding that there must be more than the mere use of a calling card identifying a manufacturers representative as an agent for a company before such representatives are dealerships  holding that something more than a mere error of law is required to constitute misconduct