Pitts v. Fire Extinguisher Sales & Services of Arkansas LLC

CourtDistrict Court, E.D. Arkansas
DecidedMay 20, 2022
Docket4:21-cv-00075
StatusUnknown

This text of Pitts v. Fire Extinguisher Sales & Services of Arkansas LLC (Pitts v. Fire Extinguisher Sales & Services of Arkansas LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pitts v. Fire Extinguisher Sales & Services of Arkansas LLC, (E.D. Ark. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

RYAN PITTS PLAINTIFF

v. Case No.: 4:21-cv-00075-LPR

FIRE EXTINGUISHER SALES & SERVICES OF ARKANSAS, LLC, and WALTER MYERS SIMPSON DEFENDANTS

FIRE EXTINGUISHER SALES & SERVICES OF ARKANSAS, LLC COUNTER-CLAIMANT

v.

RYAN PITTS COUNTER-DEFENDANT

SUPPLEMENTAL INJUNCTION

This case is about a fired employee (Mr. Pitts) who has more than likely stolen his former employer’s (FESSAR) confidential and proprietary information, and more than likely used such information to gain an unfair advantage while competing with his former employer in violation of a valid Noncompetition Agreement. Much, but not all, of the history of this case is set forth in the Court’s June 11, 2021 Preliminary Injunction Order.1 On October 4, 2021, the Court entered an agreed upon Consent Judgment and Injunction.2 As part of the relief granted to FESSAR in the Consent Judgment, Mr. Pitts agreed to the following conditions: Plaintiff agrees to submit his cell phones, computers, and any other electronic devices, including but not limited to his broken cell phone, his personal cell phone, his RAP phone, and his computer, to a third party retained by FESSAR for forensic examination within thirty (30) days from the date of entry of this Consent

1 Prelim. Inj. Order (Doc. 40); see also Oct. 4, 2021 Hr’g Tr. (Doc. 75). 2 Consent J. & Inj. (Doc. 68). Judgment, with said cell phones, computers, and other electronic devices to be timely returned to Plaintiff subsequent to forensic examination.

Plaintiff agrees that if the above-described forensic examination reveals FESSAR’s proprietary information, or any other documents and information obtained by Plaintiff as the result of his employment with FESSAR, such documentation or information will be promptly deleted from the devices by the party performing the forensic examination.3

The Injunction enjoined Mr. Pitts from, among other things: Using any of the confidential information described in the Noncompetition Agreement. This includes any non-public information of or relating to FESSAR, or otherwise used by FESSAR in connection with its business, including data, information relating to customers, vendors, suppliers, or personnel (and relationships therewith), contracts, customer files and records, employee compensation, marketing plans and strategies, pricing and purchasing policies and procedures, unique business practices, and any other trade secrets (under common law, under the Noncompetition Agreement, or as defined by applicable statute).4

On October 19, 2021, FESSAR engaged Matt Hollister, a forensic technologist for Pivot Legal Services, to conduct a forensic examination of Mr. Pitts’s electronic devices.5 On October 25, 2021, Mr. Hollister received from Mr. Pitts three electronic devices––an iPhone, an Android cell phone, and a Chromebook laptop.6 With respect to the iPhone, Mr. Hollister determined that it had “been reset to its factory setting prior to delivery to Pivot.”7 This factory reset removed “data located locally on the iPhone” and prevented Mr. Hollister from being able to access “iCloud, the Apple cloud storage and cloud computing service.”8 iCloud allows “a user to store data from an Apple device onto a remote

3 Id. at 3. 4 Id. at 4. 5 Ex. 1 (Hollister Aff.) to FESSAR’s Mot. to Compel (Doc. 73-1) ¶¶ 2–3. 6 Id. ¶ 4. 7 Id. ¶ 5. 8 Id. ¶ 6. server.”9 To access this data, login credentials are required.10 Mr. Pitts did not provide such credentials to Mr. Hollister.11 As such, Mr. Hollister was unable to determine whether Mr. Pitts had backed up FESSAR’s proprietary information from the iPhone to iCloud, which could then be downloaded back onto the iPhone by Mr. Pitts after the forensic examination.12 With respect to the Android, Mr. Hollister noted that it “was severely damaged.”13 It had

“multiple impact locations on the front glass, water damage, and the battery had been punctured.”14 Based on his experience, Mr. Hollister believes that the Android was intentionally damaged.15 (Based on the Court’s experience with Mr. Pitts in this case, the Court agrees.) This damage precluded Mr. Hollister from accessing data located on the Android.16 The Android is a Google device, which is capable of remotely storing data in a “cloud based remote storage platform” called Google Drive.17 Access to Google Drive requires Gmail login credentials.18 Mr. Pitts did not provide these credentials to Mr. Hollister.19 Without being able to access Mr. Pitts’s Google Drive, Mr. Hollister cannot say whether Mr. Pitts uploaded FESSAR’s proprietary information from the Android to Google Drive.

9 Id. ¶ 7. 10 Id. 11 Id. 12 Id. 13 Id. ¶ 8. 14 Id. 15 Id. 16 Id. 17 Id. ¶ 9. 18 Id. 19 Id. With respect to the Chromebook––another Google device––it too “had seemingly been reset to its factory settings.”20 Additionally, the Chromebook “runs on a web-based operating system rather than a local operating system.”21 Mr. Hollister cannot determine whether any “data deleted from the Chromebook [remains saved] on a Google Drive without accessing” such Google Drive.22 As mentioned, Gmail login credentials from Mr. Pitts are required to access Google

Drive.23 Mr. Pitts did not provide any login credentials. The whole purpose of the forensic examination was to ensure Mr. Pitts no longer had electronic copies of FESSAR’s proprietary information. Mr. Pitts knew this. In the October 4, 2021 hearing on FESSAR’s Motion for Contempt of the June 11, 2021 Preliminary Injunction Order, Mr. Pitts testified as follows: Q. So my question for you is: Do you have an objection to some third party looking at your stuff to make sure FESSAR’s stuff is gone?

A. Absolutely not.

Q. You don’t have a problem with that?

A. No, sir.24

. . .

A. You know, I would like––I wouldn’t mind for a third party to go back. They can go back and look. If they find something, if they can delete it, it’s fine with me.

I don’t––I don’t really know exactly where all information could be stored. I’m not a computer programmer or anything like that. And I’m sure they can go through much easier––you know, much easier routes to complete the task.25

20 Id. ¶ 11. 21 Id. 22 Id. 23 Id. 24 Oct. 4, 2021 Hr’g Tr. (Doc. 75) at 28:7–12. 25 Id. at 48:16–23. . . .

A. I’m just saying that, based on my level of technological understanding, there could possibly be something somewhere that I don’t––you know, that I haven’t come across yet.26

Given the state of the devices Mr. Pitts provided to FESSAR on October 25, 2021, the forensic examination could not accomplish its clear objective without access to Mr. Pitts’s iCloud and Gmail credentials. On or about October 27 and 28, 2021, FESSAR asked Mr. Pitts to provide both his iCloud and Gmail credentials.27 Mr. Pitts responded by saying that neither the Consent Judgment nor the Injunction required him to provide credentials to the various platforms.28 On November 8, 2021, FESSAR filed a Motion to Compel Compliance with the Consent Judgment and Injunction.29 FESSAR argued that, to give effect to the Consent Judgment and Injunction, Mr. Pitts should be compelled to provide his iCloud and Gmail login credentials.30 FESSAR persuasively explained that limiting the forensic investigation to “local hard drives” (which Mr. Pitts most likely wiped) “would allow Mr. Pitts to circumvent” the Consent Judgment and Injunction by simply storing FESSAR’s proprietary information on the cloud instead of on his devices.31 Mr. Pitts did not timely respond to FESSAR’s Motion.32 The due date for a response was November 25, 2021. On December 9, 2021, Mr. Pitts “called chambers and asked for an extension

26 Id. at 49:6–8. 27 Ex. 4 to FESSAR’s Mot. to Compel (Doc. 73-4) at 9–11. 28 Id.

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Pitts v. Fire Extinguisher Sales & Services of Arkansas LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pitts-v-fire-extinguisher-sales-services-of-arkansas-llc-ared-2022.