Partech, Inc. v. Jackson

CourtDistrict Court, S.D. New York
DecidedJanuary 29, 2025
Docket1:24-cv-09381
StatusUnknown

This text of Partech, Inc. v. Jackson (Partech, Inc. v. Jackson) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Partech, Inc. v. Jackson, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------------- X : PARTECH, INC., : : Plaintiff, : 24-CV-9381 (JAV) : -v- : OPINION AND ORDER : MICHAEL JACKSON and QU POS, INC., : : Defendants. : ---------------------------------------------------------------------- X

JEANNETTE A. VARGAS, United States District Judge:

ParTech, Inc. (“PAR” or “Plaintiff”), a New York corporation that offers point- of-sale solutions to restaurant enterprises, alleges that Defendants misappropriated its trade secrets and proprietary information. Plaintiff filed an application for injunctive relief pursuant to Federal Rule of Civil Procedure 65. For the reasons stated below, the application is denied. BACKGROUND A. Factual Allegations PAR is a New York corporation with headquarters in New York that offers an array of software and hardware solutions — encompassing point-of-sale, digital ordering, back-office management, loyalty, and payments — for clients in the hospitality and retail industries. ECF No. 1-1, Ex. A (“Compl.”), ¶¶ 4, 10. Defendant Michael Jackson, a Texas resident, is a former employee of PAR, where he served as a Director of Product Management between June 2022 and November 2024. Id. ¶¶ 5, 14, 29. Jackson signed an Offer of Employment letter from PAR on May 29, 2022. Id. ¶ 15. As part of his employment, Jackson also signed a Non- Disclosure and Non-Solicitation Agreement, Compl., Ex. 1 (the “NDA”), which prohibited Jackson from sharing “PAR’s trade secrets and other non-public

information that PAR treats as confidential, proprietary, or private in nature” outside of PAR, even after his employment by PAR was terminated. Compl., ¶¶ 15, 17-20; NDA § 2. As Director of Product Management, Jackson had access to confidential and proprietary information belonging to PAR, such as marketing, pricing, and sales strategies; product roadmaps; financial performance markers; and product development plans. Compl., ¶ 21; ECF No. 29 (“Ostertag Affirm.”),

¶ 10. Jackson performed his position at PAR on a fully remote basis from Texas, as his Offer of Employment specified, and none of his direct reports or team members resided in New York. Compl., Ex. 1, Offer of Employment Letter § 4; ECF No. 39, Ex. A (“Jackson Dep.”) at 13:1-14:6. Jackson never traveled to New York or visited PAR’s New York office, even when initially interviewing for the position. ECF No. 34 (“Jackson Decl.”) ¶¶ 3, 6(d); Jackson Dep. at 18:3-23. While working at PAR,

Jackson did not knowingly work with customers who were located or headquartered in New York. Jackson Decl., ¶ 6(f); Jackson Dep. at 72:16-73:18. Although he traveled out of state to meet with several customers, his business travels never included New York. Jackson Decl., ¶ 6(f). On May 15, 2023, Jackson received 305 Restricted Stock Units (“RSUs”) under PAR’s Equity Incentive Plan. Compl., ¶ 22; id. Ex. 2 (“RSU Award Agreement”). Pursuant to the terms of the plan and agreement concerning his RSU award, the first one-third of Jackson’s RSUs vested on June 1, 2024. Id. ¶¶ 23-24. According to the terms of the RSU award agreement he signed, Jackson

acknowledged that if he “engage[d] in Injurious Conduct,” he may be required to return or pay the proceeds of any shares acquired on settlement of the RSUs. Id. ¶ 26. Jackson’s May 29, 2022 Offer Letter defines “Injurious Conduct” as including “the unauthorized use or disclosure of any trade secret or confidential information of the Company (or of any client, customer, supplier, or other third party who has a business relationship with the Company) or the violation of any non-competition,

non-disparagement or non-solicitation covenant or assignment of inventions obligation with the company.” Id. ¶ 27; id. Ex. 1 (“Offer Letter”), § 6(a). Jackson gave notice of his intent to leave PAR on November 1, 2024, and his final day as Plaintiff’s employee was on November 15, 2024. Compl., ¶¶ 28-29. Shortly afterwards, Plaintiff learned that Jackson had started employment with Defendant Qu POS, Inc (“Qu”) as a senior director of product management. Id. ¶ 30; Jackson Dep. at 70:23-25. Jackson became an employee of Qu on November

18, 2024, where he continued to work remotely from Texas. Jackson Decl., ¶ 8. Qu, a Delaware corporation with headquarters in Virginia, directly competes with PAR, as it is also a provider of point-of-sale solutions for enterprise customers in the restaurant industry. Compl., ¶ 6; see also Ostertag Affirm., ¶¶ 3-6. Plaintiff alleges that the two companies, at their core, sell the same point-of-sale architecture to their potential customers. Ostertag Affirm., ¶ 5. Notably, point-of- sale is the most “strategically important product” for these companies to offer because it is “the lynchpin of a restaurant’s technology tech stack and a highly viable cross-sell driver for software providers.” Id. Both PAR and Qu target and

compete for the same customer pool of approximately 500 large enterprise restaurant concepts in North America. Id. ¶ 6. Plaintiff argues that each additional customer is hard-earned; significant time and resources must be invested to learn about the customer and tailor the software solution towards it. Id. ¶ 7. Thus, according to Plaintiff, Defendants’ use of PAR’s trade secrets and confidential information could enable Qu to damage PAR’s reputation and steal PAR’s current

and prospective customers. Id. ¶¶ 7-8. Upon Jackson’s departure from PAR, Plaintiff investigated and discovered that Jackson had “downloaded a number of highly sensitive documents to his personal devices” as well as created a “full backup of his PAR provided laptop” that contained PAR’s proprietary and confidential information. Compl., ¶¶ 31-32. Plaintiff alleges that the information “includes PAR’s most sensitive and confidential information” that details its future strategies and plans, its competitive

positioning, and key calculations. Ostertag Affirm., ¶ 9. Plaintiff claims that this kind of information is expensive to develop and tremendously valuable to a competitor seeking to gain insight into PAR’s internal workings, potential strategies, and market positioning. ECF No. 9 (“Plf. Mem.”) at 7; Ostertag Affirm., ¶¶ 13-15, 17. On December 4, 2024, Plaintiff wrote to Jackson, copying Qu’s CEO and notifying Jackson of its concern that Jackson may have taken PAR’s confidential and proprietary information in breach of the agreements he signed. ECF No. 15

(“Defs. Obj.”) at 2. Upon learning of Plaintiff’s concerns, Qu states that it immediately placed Jackson on administrative leave and terminated his access to Qu’s systems and devices. Id. Qu informed Plaintiff of the actions it had taken and noted that Jackson possessed two external hard drives holding PAR documents, which Jackson had agreed to relinquish to a forensic vendor — along with his personal and work laptops — for preservation and analysis. Id.

B. Procedural History On December 6, 2024, Plaintiff filed a Complaint in the Supreme Court in the State of New York, asserting claims for breach of contract, tortious interference with contractual relationship, misappropriation of trade secrets, violation of the Economic Espionage Act, 18 U.S.C. § 1832, unfair competition, and unjust enrichment. Compl., ¶¶ 1, 5. Defendants removed the action to federal court on December 10, 2024, pursuant to 28 U.S.C. § 1441, on the grounds that the cause of

action under the Economic Espionage Act raised a federal question and that the action in its entirety fell within the Court’s diversity jurisdiction. ECF No.

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Partech, Inc. v. Jackson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/partech-inc-v-jackson-nysd-2025.