Counts
Counts
| Count | Claim | Asserted by | Against | Elements | Facts | Evidence | Witnesses | Gaps |
|---|---|---|---|---|---|---|---|---|
| 1 | Breach of Contract | Meridian Analytics, Inc. | Halvorsen Data Partners, LLC | 2 / 4 supported | 15 | 18 | 7 | 1 open |
| 2 | Misappropriation of Trade Secrets (Defend Trade Secrets Act, 18 U.S.C. § 1836) | Meridian Analytics, Inc. | Halvorsen Data Partners, LLC; Tobias Kane; Rennick Ventures, LLC | 2 / 5 supported | 14 | 12 | 5 | 3 open |
| 3 | Breach of Fiduciary Duty | Meridian Analytics, Inc. | Tobias Kane | 1 / 4 supported | 10 | 9 | 3 | — |
| 4 | Fraudulent Misrepresentation | Meridian Analytics, Inc. | Halvorsen Data Partners, LLC; Tobias Kane | 1 / 5 supported | 9 | 11 | 5 | 1 open |
| 5 | Tortious Interference with Business Relationships | Meridian Analytics, Inc. | Tobias Kane; Rennick Ventures, LLC | 2 / 4 supported | 7 | 11 | 7 | — |
| 6 | Unjust Enrichment Pleaded in the alternative to Count 1 | Meridian Analytics, Inc. | Halvorsen Data Partners, LLC; Rennick Ventures, LLC | 0 / 3 supported | 4 | 4 | 3 | 2 open |
| 7 | Accounting | Meridian Analytics, Inc. | Halvorsen Data Partners, LLC | 2 / 3 supported | 6 | 12 | 3 | — |
One Workspace per Count.Eleven Tabs, One Claim.
Open a count and everything the record holds for it is in one place: the claim as pleaded, its elements, the allegations, evidence, witnesses, publications, damages, questions, gaps, timeline and attorney notes.
Misappropriation of Trade Secrets (Defend Trade Secrets Act, 18 U.S.C. § 1836)
Meridian against Halvorsen, Kane and Rennick for misappropriation of Tempo's forecasting models and training pipeline.
The claim as pleaded
Meridian against Halvorsen, Kane and Rennick for misappropriation of Tempo's forecasting models and training pipeline.
Kane obtained the models through Halvorsen's partner access under a confidentiality obligation and used them to build Cadence at Rennick.
- Asserted by
- Meridian Analytics, Inc.
- Asserted against
- Halvorsen Data Partners, LLC; Tobias Kane; Rennick Ventures, LLC
Proof So Far.What the File Holds, Line by Line.
Elements supported, evidence attached, witnesses linked, facts to prove, pleading paragraphs cited, open gaps and draft testimony to confirm, with how much of the damages has proof. Each line opens the tab where it is added.
A zero means nothing has been linked yet, not that nothing exists.
Elements
Status describes what the record contains, not whether the element is met.
- 1Trade secretSupported
- 2Reasonable measuresPartially supported
- 3Interstate commerceSupported
- 4MisappropriationPartially supported
- 5Damages or unjust enrichmentEvidence needed
Proof so far
- Elements supported
- 2 of 5
- Evidence attached
- 12
- Witnesses linked
- 5
- Facts to prove
- 14
- Pleading paragraphs cited
- 6
- Open gaps
- 3
- Draft testimony to confirm
- 1
Element Status.What the Record Holds, Not Whether It’s Met.
Every element sits in one of five states, each defined by what is linked to it in the record.
No element is ever marked proven. Only counsel moves an element from one state to another.
Element status
Only counsel moves an element from one to another.
- Evidence neededNothing in the vault has been linked to this element yet.
- Partially supportedSome propositions under this element have support; others do not.
- SupportedEvidence and witnesses are linked to every factual proposition under this element.
- ContradictedMaterial in the vault cuts against this element.
- Attorney reviewWaiting on counsel’s assessment.
Each Element, Opened Up.Facts, Evidence, Witnesses, and What’s Missing.
Under every element: the factual propositions beneath it, the documents and witnesses behind them, anything that cuts the other way, and the gaps still open, each with a suggested next step.
4Misappropriation
Defendants acquired the secret by improper means, or used or disclosed it without consent.
Facts supporting this element
- FACT-015Halvorsen’s partner account exported 1,184 model artifacts on September 2, 2025, including the holiday adjustment layer.Corroborated
- FACT-016No approval was requested or given for the September 2, 2025 export.Alleged
- FACT-017The bulk-download alert was suppressed from the same session.Unresolved
- FACT-018A Rennick contractor wrote that he was “porting the Tempo seasonality layer” into Cadence.Corroborated
- FACT-019Rennick renamed tempo_* modules to cad_* on November 21, 2025.Corroborated
- FACT-020Cadence’s holiday layer matches Tempo’s in 214 of 240 weight positions.Alleged
Evidence supporting those facts
- MERIDIAN-000018 Repository access log export — Halvorsen partner account, Aug–Sep 2025
- MERIDIAN-000026 Rennick Slack export — #cadence-models (excerpt)
Witnesses
- Elena Ruiz Supports
- J.M. (Rennick contractor) Supports
Contrary evidence
None recorded.
Missing evidence
- Identify “J.M.” in Rennick’s Slack
The contractor who wrote about porting the seasonality layer is known only by initials.
Suggested: Interrogatory to Rennick for the identity of every contractor on #cadence-models.
- Security alert record for the September 2 export
The log shows the alert suppressed under a different account than the complaint says.
Suggested: Confirm with Ruiz before relying on ¶ 26.
AI analysis Advisory
The access log and the Slack export together support acquisition and use. The pleading’s claim that the alert was suppressed “from the same session” is not what row 9 of the log shows. The code comparison is a draft and cannot yet be relied on.
Attorney assessment
Attorney Assessment.The AI Advises. Counsel Decides.
An agent can assess each element against the record: what supports it, what cuts against it, and what is missing. Its analysis is marked advisory. The attorney’s assessment is the determination.
Every change to an assessment is recorded in the audit log, with the previous value.
Assess each element against the record
Assess each element of count 2 against the record: what supports it, what cuts against it, and what is missing.
Elements agent · 5 elements assessed · advisory