Liberty

I.

FACTUAL AND PROCEDURAL

BACKGROUND

The following allegations are taking from Liberty’s first amended complaint. In 2010, Liberty had the idea to gather information about used cars sold at auction, identify those that might have been sold without proper

1 disclosures, and offer legal representation to defrauded buyers. Liberty, who is an attorney, worked with two men, William Robert Sutton (a licensed car dealer) and Larry Maloney (who had computer expertise), to create a company to implement the idea. They began business operations to test the concept, and Liberty accepted as clients purchasers who wanted to sue dealers over the condition of the vehicles they had bought. The three men worked with a law firm in September 2011 to address “specific legal challenges” the proposed business faced “in a systematic way.” (Capitalization omitted.) But, according to the complaint, that same month, Sutton, Maloney, and an attorney with the law firm “misappropriated” Liberty’s business concept. Sutton stole paper files related to Liberty’s plans, operations, and potential clients; and Maloney stole intellectual property, including access to the “massive vehicle databases.” The attorney…