ZipBy USA LLC v. Parzych

CourtCourt of Appeals for the First Circuit
DecidedMarch 20, 2026
Docket24-1586
StatusPublished

This text of ZipBy USA LLC v. Parzych (ZipBy USA LLC v. Parzych) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ZipBy USA LLC v. Parzych, (1st Cir. 2026).

Opinion

United States Court of Appeals For the First Circuit

Nos. 24-1494, 24-1500, 24-1586

ZIPBY USA LLC; TMA GROUP OF COMPANIES LIMITED; TMA CAPITAL AUSTRALIA PTY LTD,

Plaintiffs, Appellees/Cross-Appellants,

v.

GREGORY PARZYCH,

Defendant, Appellant/Cross-Appellee.

APPEALS FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Indira Talwani, U.S. District Judge]

Before

Montecalvo, Kayatta, and Aframe, Circuit Judges.

Kenneth N. Thayer, with whom Daniel Walsh-Rogalski and Conn Kavanaugh Rosenthal Peisch & Ford, LLP were on brief, for appellant/cross-appellee.

John J. Cotter, with whom Brandon R. Dillman, Joshua N. Andrews, and K&L Gates LLP were on brief, for appellees/cross- appellants.

March 19, 2026 KAYATTA, Circuit Judge. Gregory Parzych was serving as

president of a parking technology company called ZipBy USA, LLC,

("ZipBy") when he learned of an opportunity for the company to

acquire his former business, a company called TCS. Parzych

advised ZipBy's owner to turn down the opportunity, and ZipBy's

owner did so. Parzych then attempted to acquire TCS for himself.

When ZipBy and its affiliates1 found out what Parzych was up to,

they fired him. ZipBy also sued Parzych, asserting fiduciary-

duty, contract, trade-secret, trademark-infringement, and false-

designation claims and seeking compensatory and injunctive relief.

After a six-day trial, the jury returned a verdict against Parzych

on all counts. The district court subsequently found that the

evidence could not support the verdict against Parzych on the

trade-secret claims. It otherwise rejected Parzych's challenges

to the verdict, entered a permanent injunction barring Parzych

from acquiring TCS, and awarded ZipBy a portion of its attorneys'

fees incurred in the litigation. Parzych now appeals, and ZipBy

cross appeals the set-aside of its verdict on its trade-secret

claims.

For the reasons explained below, we affirm the judgment

of the district court.

1 Those affiliates are TMA Group of Companies Limited and TMA Capital Australia PTY LTD.

- 2 - I.

We begin with the facts. ZipBy hired Parzych as its

president in 2016. Parzych was no stranger to the world of parking

technology: He previously founded parking company TCS, then sold

it to another company, Q-Free International ("Q-Free"), in 2012.

Over the course of his employment, Parzych entered into three

agreements with Zipby. The first, the Employee Agreement,

included a restrictive covenant under which Parzych agreed not to

"undertake any outside activity . . . that could reasonably give

rise to a conflict of interest or interfere with his duties and

obligations to [ZipBy]," nor to divert business from ZipBy or

interfere with its relationships with any service or product-

providers. The second agreement, the Employee Handbook, required

Parzych to "prevent revealing or divulging" trade secrets or

protected confidential information regarding ZipBy's business

except as "necessary . . . in the performance of [his] duties or

as required by law."

The third agreement, the IP Agreement, forbade Parzych

from using or disclosing "trade secrets, proprietary data and

confidential information" while in ZipBy's employ and thereafter.

The IP Agreement stated that while employed by ZipBy, Parzych was

"expected to devote his energy and skills to the promotion of the

best interests of the Company." It further required Parzych to

safeguard "Confidential Information" that he acquired and

- 3 - prevented him from "us[ing] such Confidential Information in any

way or in any capacity other than as an employee of the Company

and to further the interests of the Company and Related Companies."

It provided that, should Parzych breach or threaten to breach its

provisions, ZipBy could bring suit for injunctive relief and that

"the substantial and irreparable harm" from any such breach was

"impossible to ascertain in advance," but "monetary damages . . .

would be wholly inadequate" as a remedy. Finally, it contained a

fee-shifting provision, which we describe below.

In January 2020, Parzych learned that Q-Free was

considering selling TCS. Parzych informed Anthony Karam, ZipBy's

owner, and Karam asked Parzych to investigate the opportunity.

Parzych requested and received financial information from Q-Free

about TCS. From there, the parties' accounts diverge: ZipBy

claims that Parzych advised Karam not to acquire TCS, while Parzych

claims that he and Karam "both expressed concerns" about the

acquisition. Given the verdict, we must presume that the jury

sided with ZipBy's account. ZipBy's board then voted not to move

forward with the acquisition. Two weeks later, unaware of the

ZipBy board's decision, Q-Free sent Parzych a proposed

nondisclosure agreement between ZipBy and Q-Free in connection

with the possible sale of TCS. Rather than executing the agreement

for ZipBy, Parzych executed it on behalf of a separate shell

company that he owned, MJP Global Technologies. With the

- 4 - financial data previously disclosed by Q-Free in hand, Parzych

began considering whether to re-acquire TCS on his own.

When ZipBy discovered that Parzych was attempting to

purchase TCS himself, it fired him. ZipBy then sued Parzych,

seeking damages and an injunction preventing Parzych from

acquiring TCS for himself.

After a five-day trial, the jury returned a verdict in

ZipBy's favor. It awarded ZipBy $1.5 million in compensatory

damages on claims of breach of fiduciary duty, breach of contract,

and misappropriation of trade secrets, and $1 million in exemplary

damages for misappropriation of trade secrets. Unhappy with this

outcome, Parzych moved for a new trial under Federal Rule of Civil

Procedure 59, a new trial on damages, and judgment as a matter of

law under Federal Rule of Civil Procedure 50(b).

The district court granted Parzych's motion for judgment

as a matter of law in part, holding that the evidence did not

support a finding that Parzych misappropriated trade secrets. The

court struck the $1 million in exemplary damages on that basis.2

Otherwise, it rejected Parzych's challenges.

2 The court left the compensatory damages intact, however, because it found that "evidence as to damages from Parzych's breach of contract and breach of fiduciary duty [was] entirely contiguous with any damages from the alleged trade secrets misappropriation." Parzych does not challenge this determination on appeal.

- 5 - Parzych now appeals, while ZipBy cross appeals,

contending that the district court was wrong to vacate the jury's

verdict that Parzych misappropriated ZipBy's trade secrets.

II.

We begin with Parzych's evidentiary challenges. We

review a district court's decision to admit or exclude evidence

for abuse of discretion. Gen. Elec. Co. v. Joiner, 522 U.S. 136,

141 (1997).

A.

Parzych first contends that the district court erred by

permitting ZipBy's expert witness, William Scally, to testify

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