Pleadings
Filed pleadings
| Pleading | Kind | Filed | Paragraphs | Referenced | Source |
|---|---|---|---|---|---|
| Complaint | Complaint | 3 Mar 2026 | 68 | 16 | MERIDIAN-000035 |
| Answer and Affirmative Defenses of Halvorsen Data Partners, LLC | Answer | 21 Apr 2026 | 14 | 0 | MERIDIAN-000036 |
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Complaint
Meridian Analytics, Inc. v. Halvorsen Data Partners, LLC, Tobias Kane, and Rennick Ventures, LLC · filed 3 Mar 2026
Desai resigned from Meridian effective August 29, 2025 and joined Rennick in September 2025 as Head of Machine Learning.
On September 2, 2025, between 3:11 a.m. and 3:41 a.m. UTC, Halvorsen's partner account exported 1,184 model artifacts from Meridian's repository, including Tempo's core weights, feature definitions, training configuration and holiday adjustment layer.
Repository access log for Halvorsen's partner account
No approval for that export was requested or given.
An automated alert raised by the export was suppressed from the same session.
Security alert record for the September 2, 2025 bulk download
On information and belief, the exported artifacts were used to build Rennick's competing product, Cadence.
Admissions and Denials.Their Answer, Read Against Your Complaint.
Each allegation beside the answer’s response: admitted, denied, admitted in part, or lacks knowledge, with the answer’s own words. Where counsel has confirmed the reading, it is marked.
Admissions and denials
Answer and Affirmative Defenses of Halvorsen Data Partners, LLC
- ¶ 10
On March 18, 2024, Meridian and Halvorsen entered into a Reseller and Implementation Agreement (the “Agreement”)…
AdmittedCounselAdmitted that Meridian and Halvorsen entered into the Agreement on March 18, 2024. The Agreement speaks for itself.
- ¶ 24
On September 2, 2025, between 3:11 a.m. and 3:41 a.m. UTC, Halvorsen’s partner account exported 1,184 model artifacts…
Lacks knowledgeHalvorsen lacks knowledge sufficient to form a belief as to the timing or content of any export and therefore denies the allegations of paragraph 24.
- ¶ 37
Halvorsen’s certified revenue report for Q4 2025 stated license fees collected of $340,000 and reported nothing collected from Northstar or Calloway.
Admitted in partCounselAdmitted that the Q4 2025 report reported no license fees from Northstar or Calloway, because none were collected.
- ¶ 39
Those certifications were false. In November and December 2025 Halvorsen invoiced Northstar $210,000 and Calloway $103,750 for continued use of Tempo…
DeniedDenied. The services invoiced in November and December 2025 were consulting services and not license fees.
- ¶ 48
Meridian has performed its obligations under the Agreement.
DeniedDenied. Meridian failed to deliver version 4 of the integration API by January 31, 2025 as required by Section 3.2.
Pleading to Proof.What Stands Behind Every Allegation.
Every material allegation with its count and element, the evidence and witness supporting it, anything contrary, whether its documents can be authenticated and have been produced, and its status. Gaps show as gaps.
Pleading-to-proof matrix
| ¶ | Allegation | Count | Element | Supporting evidence | Supporting witness | Contrary | Authentication | Disclosure | Status |
|---|---|---|---|---|---|---|---|---|---|
| 22 | Kane did not disclose Rennick to Meridian’s board. | 3 | Breach | None | Dana Whitfield | — | — | Not produced | Alleged |
| 23 | Desai resigned effective August 29, 2025 and joined Rennick. | 2 | Misappropriation | MERIDIAN-000024MERIDIAN-000025 | Elena Ruiz | — | 2 of 2 | Produced | Corroborated |
| 24 | Halvorsen’s partner account exported 1,184 model artifacts. | 2 | Misappropriation | MERIDIAN-000018 | Elena Ruiz | — | 1 of 1 | Produced | Corroborated |
| 25 | No approval for that export was requested or given. | 2 | Misappropriation | MERIDIAN-000018 | Elena Ruiz | — | 1 of 1 | Produced | Alleged |
| 26 | An alert raised by the export was suppressed from the same session. | 2 | Misappropriation | MERIDIAN-000018 | None | — | 1 of 1 | Produced | Unresolved |
| 27 | The exported artifacts were used to build Cadence. | 2 | Misappropriation | MERIDIAN-000033 | Hannah Cole | — | 0 of 1 | Not produced | Alleged |
One Paragraph, Opened.From Filed Words to Proof.
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Filed language
Complaint ¶ 24 · stored exactly as filed.
On September 2, 2025, between 3:11 a.m. and 3:41 a.m. UTC, Halvorsen's partner account exported 1,184 model artifacts from Meridian's repository, including Tempo's core weights, feature definitions, training configuration and holiday adjustment layer.
Factual propositions drawn from this paragraph
Counts
Count 2 — Misappropriation of Trade Secrets