17. On or about August 9, 2010, DAVID W. KENT, the defendant, entered into an employment agreement with Company-1 (the "Employment Agreement"), agreeing to continue to serve as President of Website-1 after the acquisition. As part of the Employment Agreement, KENT agreed to not participate in any business that competes with Website-1 while employed by Company-1. KENT also agreed to refrain from competing with Company-1 if he left Company-1, until the expiration of the latter of three years after the signing of the Employment Agreement, or two years after leaving the employ of Company-1 (the "Non-Compete Period.")18. In or around September 2011, DAVID W. KENT, the defendant, left Website-1. In or about October 2013, shortly after the earliest possible expiration of the Non-Compete Period, DAVID W. KENT, the defendant, announced that he had founded Oilpro.com ("Oilpro"), which also provides networking service to professionals working in the oil and gas industry. Oilpro is headquartered in Houston, Texas.
a. On or about February 26, 2014, an individual who had created a member profile with Website-1 ("Member-1") contacted Website-1's customer support line. Member-1 stated, in sum and substance, that Member-1 had received an email solicitation from Oilpro to use Oilpro's services even though Member-1 had never provided any information in the past to Oilpro.b. An internal review of Website-1's computer systems revealed no evidence that any employee of Oilpro had viewed Member-1's profile using an account created through Website-1.c. To determine if the Members Database was being accessed improperly, employees of Company-1 created two fictitious member accounts and populated them with names and email addresses that were only available through Website-1's Members Database.As further explained in the Complaint, on April 14, 2014, the fictitious member accounts received an email from an Oilpro employee soliciting a membership on Oilpro. In tracking down how the Oilpro employee obtained the contact information, it was discovered that on October 17, 2013, about 100,000 HTTP requests were submitted to the Member Database through the use of what was identified as a Get Resume Command, which was crafted to exploit a piece of source code unique to Website-1 and known only to a few individuals, including Kent. This was but the first round of identified hacking.