govinfo:USCOURTS-mdd-1_26-cv-01436-0

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MARYLAND 
 
 * 
PROSYNC TECHNOLOGY GROUP, LLC, * 
 * 
Plaintiff, * 
 * 
v. * Civil Case No.: SAG-26-1436 
 * 
TIM MILLER, * 
 * 
 * 
Defendant. * 
 * 
* * * * * * * * * * * * * 
 
MEMORANDUM OPINION 
ProSync Technology Group, LLC (“ProSync ”) filed this action against its former 
employee, Tim Miller (“Defendant”), asserting various claims regarding his alleged 
misappropriation of trade secrets and confidential information along with breach of his 
employment agreement. ECF 1. ProSync has moved for a Preliminary Injunction , seeking to 
enforce the employment agreement’s terms and prevent use of any of the disputed information. 
ECF 3. The motion is fully briefed, ECF 23, 26, 27, and this Court held an evidentiary hearing on 
May 20, 2026. Following the hearing, this Court requested and has reviewed briefing from 
ProSync and Defendant, who now appears in a self -represented capacity. ECF 32 –35. For the 
reasons explained below, ProSync’s Motion will be granted in part and denied in part. 
I. FACTUAL BACKGROUND 
 Defendant began working for ProSync in June of 2020 and was responsible for its business 
development division. ECF 31 at 57–58. ProSync is a Services -Disabled Veteran-Owned Small 
Business (“SDVOSB”), a category permitting it to compete for certain set-aside government 
contracts as the prime contractor. Id. at 72. On June 19, 2020, Defendant and ProSync entered into 

2 
 
an employment agreement containing non-compete and non-solicitation provisions, in addition to 
provisions mandating protection and return of ProSync’s proprietary information (“the June 
Agreement”). ECF 3-2. 
 At the hearing, Defendant presented screenshot evidence of an other agreement he signed 
on July 9, 2020 (“the July Agreement”) . Exh. 12. That screenshot shows that the agreement , 
entitled “Agreement of New Employee Regarding Confidentiality, Proprietary Interests, Conflicts 
of Interests and Non-Solicitation of Customers and Employees,” was signed by Defendant but not 
executed by ProSync. Id. ProSync has introduced evidence, via declaration, that the July 
Agreement is the agreement used for lower-level employees and ProSync did not countersign it, 
because they did not intend that agreement to apply to Defendant in his high- level management 
position. ECF 33-4 ¶ 4. 
 Defendant also provided a “term sheet” he and ProSync executed in 2022. ECF 23-2. That 
term sheet lists various changes to Defendant’s compensation and benefits and states at the bottom 
“*specific terms and conditions to follow in October 2022.” Id. Defendant adduces no evidence of 
other changes or amendments to the June Agreement. 
 During Defendant’s employment, ProSync began to pursue a government contract for 
Integrated Product Support Services (“IPSS”). ECF 31 at 74. The contract had a small business 
set-aside, meaning that any designated small business could bid to be the prime contractor. Id. at 
75. In support of ProSync’s proposal, Defendant had assembled a team of two subcontractors. Id. 
at 77. One was a company named ORBIS, which does integrated product support services for the 
Navy and has a rare specialty called obsolescence. Id. at 77–78. The Teaming Agreement between 
ProSync and ORBIS guaranteed ORBIS between 20 and 25 percent of the total contract value if 
ProSync won the contract. Id. at 79. 

3 
 
 In September, 2025, the president of ORBIS, Charlie Grabenstein, introduced Defendant 
to Mannie Humphreys, the CEO of ODME Solutions, a Woman- Owned Small Business 
(“WOSB”). Id. at 73, 165. ODME is headquartered in Florida , and Defendant had limited 
knowledge of it. Id. at 165. Initial discussions went nowhere. Id. 
 In January, 2026, after some management changes at ProSync following its acquisition of 
Jaguar Defense, ProSync provided Defendant with a new Employment Agreement with a 
significant reduction in his compensation. Id. at 59–60, 165–66. Shortly thereafter, Humphreys 
“pinged” Defendant to ask whether he might be interested in another discussion, and he flew to 
Florida for a meeting. Id. at 166. A few weeks later (around January 18 or 19), Humphreys sent 
Defendant an offer letter, which he signed and returned on January 22, 2026. Id. at 167. 
 That same day, Defendant used a USB drive to download the contents of his ProSync 
computer. Id. at 172. He avers that his goal was to preserve certain personal files residing on his 
ProSync computer in the easiest possible manner. Id. 
 Upon arrival at ODME, Defendant learned that, sometime in the previous year, ODME had 
responded to the IPSS “Sources S ought.”1 Id. at 169. Shortly after Defendant start ed work at 
ODME, ORBIS asked ProSync to be released from its Teaming Agreement relating to the IPSS 
project. Id. at 91–93. As justification, ORBIS told ProSync that it no longer wanted to subcontract 
and wished only to pursue contracts as the prime contractor. Id. ProSync agreed to release ORBIS 
from the Teaming Agreement , hoping to preserve a good professional relationship with ORBIS 
because of its unique expertise. Id. at 94–95. A couple of weeks later, however, ProSync obtained 
 
1 From the testimony at the hearing, it appears that an entity’s participation in “Sources Sought” 
might impact the eventual Request for Proposal and the customer’s determination about whether 
there should be any set-asides in the contract. For example, ODME’s participation might have 
led to a set-aside for WOSBs. 

4 
 
an email, accidentally sent to Defendant’s ProSync email address instead of his ODME email , 
attaching a proposed Teaming Agreement between ODME and ORBIS for the IPSS contract. Id. 
at 96–98. The draft agreement promised ORBIS a “minimum of 25 percent” of the contract value, 
a higher percentage than that ProSync had promised. Id. at 98. 
ODME ultimately did not respond to the IPSS proposal and is not in the running to win the 
contract. Id. at 103. However, ProSync was unable to find another provider to fill the role ORBIS 
played as a subcontractor. Id. at 103–05. ProSync’s response to the IPSS proposal was therefore 
weaker than it would have been with the ORBIS Teaming Agreement in place. Id. at 105. The 
IPSS contract has not yet been awarded. Id. 
 Additionally, Philip Dominguez worked as a consultant for ProSync supporting the IPSS 
opportunity. Id. at 100, 103. After Defendant left ProSync, Dominguez stopped responding to 
ProSync’s employees and became employed by ODME. Id. at 100, 103, 150, 153. 
 Following Defendant’s move to ODME, he continued to provide some professional 
assistance to ProSync employees. Id. at 176–79. He has also introduced evidence that his wife, 
who was terminated from ProSync on April 2, 2026, retained administrative privileges for 
ProSync’s LinkedIn as of May 18, 2026. Id. at 179–80. 
 After learning of Defendant’s actions with ORBIS and the IPSS opportunity, ProSync 
investigated and discovered Defendant’s downloading of the files on his computer. Following 
negotiations with Defendant’s then-counsel, a forensic examiner, Edward Snyder, performed an 
evaluation of the USB drive containing the download. Id. at 22 –23. Snyder determined that 
Defendant had downloaded approximately 50 GB (just over 22,000 documents) of ProSync-related 
data on January 22, 2026. Id. at 27. The USB drive was not encrypted, password protected, or 
otherwise secured. Id. at 28. And the ProSync -related data included Controlled Unclassified 

5 
 
Information (“CUI”). Id. at 36–38. As a result of the mishandling of that data, ProSync has had to 
report the situation to appropriate government agencies. Id. at 124–25. Defendant also downloaded 
information relating to at least two proprietary tools, CVKeys and Rocket AI. Id. at 108–112. 
Additionally, Defendant downloaded a March 8, 2022 proposal ProSync made to the Naval 
Surface Warfare Center. Id. at 113–18. All of those items have significant economic value to 
ProSync and would be very valuable to a direct competitor. Id. 
II. LEGAL STANDARD 
A preliminary injunction is warranted when the movant demonstrates four factors: (1) that 
the movant is likely to succeed on the merits, (2) that the movant will likely suffer irreparable harm 
in the absence of preliminary relief, (3) that the balance of equities favors preliminary relief, and 
(4) that injunctive relief is in the public interest. League of Women Voters of N.C. v. North 
Carolina, 769 F.3d 224, 236 (4th Cir. 2014) (citing Winter v. Natural Res. Def. Council, Inc., 555 
U.S. 7, 20 (2008)); Wilson v. Williams , Civ. No. 9:19-cv-01369-RMG, 2019 WL 4942102, at *1 
(D.S.C. Oct. 8, 2019). The movant must establish all four elements in order to prevail. Pashby v. 
Delia, 709 F.3d 307, 320–21 (4th Cir. 2013). Ultimately, the decision to issue a preliminary 
injunction is committed to the trial court’s discretion. Id. at 319. 
A preliminary injunction affords ‘“an extraordinary and drastic remedy’ prior to trial.” 
Ultimate Outdoor Movies, LLC v. FunFlicks, LLC , Civ. No.: SAG-18-2315, 2019 WL 2642838, 
at *6 (D. Md. June 27, 2019) (quoting Munaf v. Green, 553 U.S. 674, 689–90 (2008)); see also 
MicroStrategy, Inc. v. Motorola, Inc., 245 F.3d 335, 339 (4th Cir. 2001) (stating preliminary 
injunctive relief is an “extraordinary remed[y] involving the exercise of very far-reaching power 
[that is] to be granted only sparingly and in limited circumstances.”) (quoting Direx Israel, Ltd. v. 
Breakthrough Med. Corp., 952 F.2d 802, 816 (4th Cir. 1991
)). Since preliminary injunctions are 

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intended to preserve the status quo during the pendency of litigation, injunctions that “alter rather 
than preserve the status quo” are particularly disfavored. Mountain Valley Pipeline, LLC v. 6.56 
Acres of Land, 915 F.3d 197, 216 n.8 (4th Cir. 2019). Courts should grant such “mandatory” 
preliminary injunctions only when “the applicant’s right to relief [is] indisputably clear.” Id. 
III. ANALYSIS 
A. Likelihood of Success on the Merits 
To obtain preliminary injunctive relief, ProSync bears the burden to show that it is likely 
to succeed on at least one of its claims. See, e.g., Stinnie v. Holcomb, 355 F. Supp. 3d 514, 527 
(W.D. Va. 2018). To establish misappropriation of a trade secret under federal law and Maryland 
state law, ProSync must demonstrate that the documents at issue are trade secrets, and that 
Defendant misappropriated those trade secrets. See 18 U.S.C. §§ 1836(b)(1), 1839(3), (5); Md. 
Code Ann., Com. Law §§ 11-1201(c), (e), 11-1202(a). ProSync has shown a likelihood of success 
on both elements. 
First, ProSync has shown a likelihood of success in establishing that at least some of the 
documents at issue are trade secrets. “[A]ll forms and types of financial, business, scientific, 
technical, economic, or engineering information,” regardless of whether it is tangible or intangible, 
or how the information is stored, memorialized, or maintained, can qualify for protection as a 
“trade secret” under the federal Defend Trade Secrets Act (“DTSA”). 18 U.S.C. § 1839(3). 
However, such information only becomes a trade secret if (1) the owner of the trade secret takes 
“reasonable measures to keep such information secret,” and (2) the information “derives 
independent economic value . . . from not being generally known to, and not being readily 
ascertainable through proper means by, another person who can obtain economic value from the 
disclosure or use of the information.” Id. § 1839(3)(A)–(B). 

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Similarly, the Maryland Uniform Trade Secrets Act (“MUTSA”) defines a “[t]rade secret” 
as any information that the owner “[d]erives independent economic value, actual or potential, from 
not being generally known to, and not being readily ascertainable by proper means by, other 
persons who can obtain economic value from its discl osure or use,” and takes reasonable efforts 
to maintain its secrecy. Md. Code Ann., Com. Law § 11- 1201(e). To determine whether 
information is a trade secret, Maryland courts assess: (1) the extent to which the information is 
known outside of plaintiff’s business; (2) the extent to which it is known by employees and others 
involved in plaintiff’s business; (3) the extent of measures taken by plaintiff to guard the secrecy 
of the information; (4) the value of the information to plaintiff and competitors; (5) the amount, 
effort, or money expended by plaintiff in developing the information; and (6) the ease or difficulty 
with which the information could be acquired or duplicated by others. AirFacts, Inc. v. de 
Amezaga, 909 F.3d 84, 95 (4th Cir. 2018) (citing Restatement (First) of Torts § 757 cmt. b); see 
also Ultimate Outdoor Movies, LLC v. FunFlicks, LLC , Civ. No.: SAG -18-2315, 2019 WL 
2233535, at *17 (D. Md. May 23, 2019) (quoting Allan M. Dworkin, D.D.S., P.A. v. Blumenthal, 
77 Md. App. 774, 781–82 (1989)). 
As relevant here, the Defend Trade Secrets Act provides that a trade secret can be 
misappropriated when a person either (1) acquires a trade secret while knowing, or having reason 
to know, that the trade secret was acquired by improper means, 18 U.S.C. § 1839(5)(A), or (2) 
uses or discloses the trade secret after acquiring it through improper means, id. § 1839(5)(B)(i). 
Maryland defines misappropriation in “substantially the same manner.” Md. Physician’s Edge, 
LLC v. Behram, No. DKC-17-2756, 2019 WL 4573417, at *5 (D. Md. Sept. 20, 2019). Compare 
Md. Code Ann., Com. Law § 11- 1201(c) with 18 U.S.C. § 1839(5). Thus, a claim for 
misappropriation lies “simply by demonstrating that the defendant acquired [the] trade secret by 

8 
 
improper means, even if the plaintiff cannot show use of that trade secret.” Sys. 4, Inc. v. Landis 
& Gyr, Inc., 8 F. App’x 196, 200 (4th Cir. 2001) (interpreting the MUTSA). The DTSA further 
provides that the “improper means” of acquiring a trade secret “includes theft, bribery, 
misrepresentation, breach or inducement of a breach of a duty to maintain secrecy, or espionage 
through electronic or other means.” 18 U.S.C. § 1839(6)(A). The MUTSA’s definition mirrors the 
DTSA’s definition. Compare id. with Md. Code Ann., Com. Law § 11-1201(b). 
The information Defendant downloaded and retained includes ProSync’s marketing plans, 
business projections, product information and specifications, government debriefs, and 
confidential personnel information. ECF 31 at 108–120, 126. As described at the hearing, ProSync 
operates in the highly competitive realm of government contracting, and this information is only 
shared privately with potential customers in the bidding process. Because of the volume of records 
downloaded, ProSync did not identify with great specificity all of the trade secrets it alleges to be 
misappropriated. But at least some of the records relate to ProSync’s proprietary inventions, such 
as CVKeys or Rocket AI, that have substantial economic value to ProSync, are not shared publicly, 
and would be valuable to its competitors. T his information conveys a competitive advantage to 
ProSync and would do the same for another company competing for some of the same government 
contracts. Id. at 116-18. The evidence at the hearing indicates that ProSync required its senior 
executives to sign agreements to guard the confidentiality of such information and limited access 
to many of those materials to a need -to-know basis.
2 ProSync has therefore established that , at 
 
2 ProSync provided some testimony about its office security measures, but little concrete 
information about its computer security measures. ECF 31 at 63–64. ProSync’s witness could not 
even specify what security measures protected Defendant’s work laptop (which, Defendant 
submits, was also his personal computer) . Id. at 14, 63–64. This Court therefore does not rely on 
ProSync’s computer security measures in analyzing its protection efforts. But it is not persuaded 
that insufficient computer security jeopardized the information, either. 

9 
 
least as to those proprietary programs, the information in question derives independent economic 
value from not being publicly known and that it took reasonable measures to keep the information 
contained within the company and secret from the public. 
Defendant contests whether he “misappropriated” the trade secrets, arguing that he simply 
downloaded the contents of his work drive in an effort to “save time” in transferring his personal 
items he had saved on his work computer. He tries to bolster that argument by showing that, on 
several occasions after his departure, he maintained a degree of loyalty to the company and even 
assisted ProSync employees with job tasks. But, in this context, “ misappropriation” does not 
require malevolent intent. The June Employment Agreement prohibited Defendant from taking 
“Proprietary Information” when he left the company. Id. at 142–143. And m isappropriation lies 
“simply by demonstrating that the defendant acquired [the] trade secret by improper means.” Sys. 
4, Inc., 8 F. App’x at 200. There is no dispute here that, whatever his motivation, Defendant 
downloaded vast amounts of ProSync’s information onto a USB drive and took it with him when 
he ended his employment. ProSync has established a likelihood of success that it can prove 
misappropriation of trade secrets and, by the same token, breach of the provisions of the 
Employment Agreement regarding return of company property. 
ProSync also has established a likelihood of success on the merits as to its claims pertaining 
to breach of the non- competition and non- solicitation p rovisions of Defendant’s June 2020 
Employment Agreement. The evidence at the hearing established that both parties executed the 
June Agreement. Defendant also introduced evidence, in the form of screenshots, that he signed a 
separate “Agreement of New Employee Regarding Confidentiality, Proprietary Interests, Conflicts 
of Interests and Non-Solicitation of Customers and Employees” three weeks later, on July 9, 2020. 
Exh. 12. But the screenshot exhibit did not show that ProSync ever executed the July Agreement, 

10 
 
and ProSync has provided evidence that it did not. ECF 33-4. Thus, the evidence before this Court 
indicates a likelihood that the June Agreement remains operative and its provisions control. 
In response to the non-compete allegations, Defendant contends, in his briefing and at the 
hearing, that ODME is not a direct competitor of ProSync. He alleges that ODME is a WOSB, not 
a SDVOSB like ProSync, and that ODME focuses on engineering services while ProSync’s 
specialty is security and intelligence services. ECF 23 at 2. Those distinctions may prove accurate. 
But Defendant’s contention that the companies are not direct competitors is undermined by the 
fact that, at least as to the IPSS bid around the time of Defendant’s departure, ODME and ProSync 
participated in the initial stages to pursue the contract, both seeking exclusive use of ORBIS’s 
expertise to bolster their proposals. Both are able to compete for contracts designated for Small 
Businesses or contracts that are full and open. While there are some distinctions, then, there is a 
likelihood based on the evidence presently before this Court that ProSync will succeed on the 
merits of its claim that ODME, at least in part, is a Restricted Business operating in the Restricted 
Area as defined by the June Agreement. 
Further, ProSync offers some evidence that Defendant himself engaged in directly 
competitive activity. Specifically, Defendant’s personal involvement in the proposed teaming 
arrangement between ORBIS and ODME on the IPSS opportunity suggests direct competition, not 
simply having been hired at a company that, unbeknownst to Defendant, previously participated 
in the early stages of the same contracting process. 
This Court concludes, then, that ProSync has met its burden to establish a likelihood of 
success on the merits of its trade secrets and breach of contract claims , even in the context of the 
mandatory injunction it requests. 
 

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B. Irreparable Harm 
 Generally, “irreparable injury is suffered when monetary damages are difficult to ascertain 
or are inadequate.” Coreas v. Bounds , 451 F. Supp. 3d 407, 428 (D. Md. 2020) (quoting Multi-
Channel TV Cable Co. v. Charlottesville Quality Cable Operating Co., 22 F.3d 546, 551 (4th Cir. 
1994), abrogated on other grounds by Winter, 555 U.S. 7). Moreover, i ssuing a preliminary 
injunction “based only on a possibility of irreparable harm is inconsistent with our characterization 
of injunctive relief as an extraordinary remedy that may only be awarded upon a ‘clear showing’ 
that the plaintiff is entitled to relief. ” Di Biase v. SPX Corp., 872 F.3d 224, 230 (4th Cir. 2017) 
(quoting Winter, 555 U.S. at 22). 
Conversely, “when the failure to grant preliminary relief creates the possibility of 
permanent loss of customers to a competitor or the loss of goodwill, the irreparable injury prong 
is satisfied.” Multi-Channel TV Cable Co., 22 F.3d at 552. As this Court has recognized, once trade 
secrets are used by a competitor, the competitive advantage is permanently lost. See Brightview 
Grp., LP v. Teeters, 441 F. Supp. 3d 115, 141 (D. Md. 2020). Nevertheless , the Maryland Court 
of Appeals has denounced the issuance of injunctions under the “inevitable disclosure” theory of 
irreparable harm. See LeJeune v. Coin Acceptors, Inc., 381 Md. 288, 322-23 (2004). That is, 
ProSync cannot obtain injunctive relief under the MUTSA merely because, by the nature of 
working in a competing venture, Defendant will “inevitably be required to use or disclose 
[ProSync’s] trade secrets in order to perform [his] new job.” Id. at 317 (citation omitted). 
 Here, the evidentiary record supports a finding of irreparable injury. ProSync has already 
suffered impact to its IPSS bid from what appears to be competitive activity by Defendant in 
working with ORBIS at ODME. Defendant’s retention of and ability to access ProSync’s trade 
secrets and confidential information create the possibility of permanent loss of competitive 

12 
 
advantage and contracts to ODME. Moreover, his retention of CUI and other protected government 
information that had been in ProSync’s custody creates the likely loss of goodwill with its 
government customers. Thus, absent preliminary injunctive relief, ProSync will suffer irreparable 
injury. 
C. Balance of the Equities and Public Interest 
The final two factors for issuing preliminary injunctive relief also weigh in ProSync’s 
favor. First, the balance of the equities favors ProSync . ProSync faces the prospect of suffering 
irreparable harm through the continued disclosure of its trade secrets, through Defendant’s 
possession of information its government clients deemed “CUI,” and through Defendant’ s 
wrongful utilization of ProSync’s confidential and proprietary information to bolster the business 
of his new employer, which heavily favors injunctive relief. See, e.g., E.I. DuPont de Nemours & 
Co. v. Kolon Indus., Inc. , 894 F. Supp. 2d 691, 708 (E.D. Va. 2012) (“[T]he continued use of a 
purloined trade secret is a harm of significant measure that warrants injunctive relief.”), va cated 
on other grounds , 564 F. App’x 710, 715 (4th Cir. 2014) (remanding for a new trial due to an 
erroneous ruling on a pretrial motion in limine). 
Defendant, meanwhile, ha s produced no evidence of any harm that he will suffer if the 
Court enjoins him from maintaining or using ProSync’s information during the pendency of the 
litigation. If Defendant truly ha s no intent to use ProSync trade secret or proprietary information 
to compete going forward (as he insists) , then enjoining his further use of that information (or 
requiring, in some instances, its return or deletion) will not cause him any harm. The balance of 
the equities, then, lies with ProSync. 
 Finally, the public interest favors the protection of trade secrets, and the prevention of 
unfair business practices. See NaturaLawn of Am., Inc. v. West Grp., LLC , 484 F. Supp. 2d 392, 

13 
 
404 (D. Md. 2007) (noting that it is in the public interest “to validate . . . the proprietary nature of 
trade secrets”). While the public certainly has an interest in promoting free market competition in 
a capitalist economy, that interest is not protected unless the legal system “prevent[s] unethical 
business behavior” and stops market participants from driving “another competitor out of business 
by unfairly misappropriating trade secrets” and other confidential business information. See 
Advanced Instructional Sys., Inc. v. Competentum USA, Ltd., No. 1:15CV858, 2015 WL 7575925, 
at *6 (M.D.N.C. Nov. 25, 2015) (citations omitted); see also GAI Audio of N.Y., Inc. v. Columbia 
Broad. Sys., Inc., 27 Md. App. 172, 192 (1975). 
In sum, ProSync has demonstrated a likelihood of success in establishing that Defendant 
has violated the Defend Trade Secrets Act and the Maryland Uniform Trade Secrets Act , in 
addition to the competition, solicitation, and return of property provisions of his June Agreement. 
ProSync has also demonstrated that it is likely to suffer immediate, irreparable harm without 
preliminary injunctive relief. Because the balance of the equities favors Pro Sync, and issuing a 
preliminary injunction is in the public interest, the Court will grant ProSync ’s request for a 
preliminary injunction. 
D. Scope of Relief Ordered 
Finally, this Court must analyze the scope of the relief ProSync requests. ProSync’s 
proposed order, ECF 33- 5, contains six substantive paragraphs. Paragraph one seeks to prohibit 
Defendant, until October 17, 2026
3, from taking any action to participate in sixteen particular 
business opportunities. The first ten of the listed business opportunities were part of the January 
 
3 The parties agreed to a temporary injunction on April 17, 2026, which has been in effect since. 
The October 17, 2026 date represents the six-month window prescribed in the June Agreement. 
Of course, as this is a preliminary injunction, should this litigation conclude sooner or other 
circumstances warrant, the date is subject to revision. 

14 
 
2026 PowerUp slides prepared by Defendant for discussion at ProSync. See ProSync Hrg. Exh. 5. 
Thus, it is within the scope of the non- competition clause to prohibit Defendant from work on 
those opportunities, which constitute Restricted Business. This Court cannot find any evidence in 
the record relating to the other six opportunities and therefore declines to include them specifically 
in the preliminary injunction order. Of course, if Defendant’s involvement in those opportunities 
would be barred by the Non-Competition clause, he cannot engage in the activity under the June 
Agreement. 
The second paragraph largely tracks the language of the non-competition clause in the June 
Agreement, prohibiting Defendant, until October 17, 2026, from performing certain services for 
any business that competes with ProSync within Arizona, Pennsylvania, Maryland, Virginia, and 
the District of Columbia. This Court will amend the language to make clear that Defendant is not 
prohibited from employment at ODME, but the services he provides must be unrelated to the 
Restricted Business ProSync performs. See ECF 3-2 ¶ 8 (permitting employment with a company 
engaged in the Restricted Business “where the Employee’s service for such company does not 
relate to the Restricted Business.”) 
The third paragraph again prohibits Defendant, until October 17, 2026, from soliciting or 
providing competing services to any current customers of ProSync (as defined in the order) or any 
persons for whom ProSync had taken specific action to prepare or submit a proposal within six 
months of Defendant’s separation. This Court will align the language with that in the June 
Agreement by making it read “within six months preceding Defendant’s separation from 
ProSync.” 
This Court will order the fourth paragraph as written, which states “Defendant shall not, 
directly or indirectly, retain, access, disclose, transmit, share, use, or otherwise exploit for his own 

15 
 
benefit or for the benefit of any third party any proprietary, confidential, or trade secret information 
belonging to ProSync, including but not limited to the information that Defendant copied to a drive 
on January 22, 2026.” 
The fifth and sixth paragraphs relate to the proposed effectuation of paragraph four, but 
this Court will limit the relief requested in certain ways. First, with respect to the Macintosh 
computer and the sons’ personal computers, Mr. Snyder’s initial review should be limited to 
ascertaining whether the USB drive was ever plugged in to those devices. If not, the inspection 
should cease, and those computers should be returned to Defendant. Second, with respect to the 
HP personal computer (and any other computer in which the USB drive was inserted) , this Court 
is concerned about allowing Mr. Snyder to search for and remove “all ProSync -related 
information” from the device. Defendant worked for ProSync for several years and is likely to 
have resumes and other legitimate documentation relating to ProS ync that is not proprietary or 
confidential. His spouse, who also shares the computer, also worked for ProSync. And Defendant 
is presently self-represented in this Court and will presumably have ProSync-related information 
concerning his defense. 
With the exception of a few identified items, ProSync has not provided this Court with a 
comprehensive list of trade secret or other proprietary information that this Court could readily 
order returned to avoid the overbreadth issue described above . And this Court is unwilling to 
delegate to Mr. Snyder the duty of determining what information is a trade secret or proprietary to 
ProSync. This Court believes, therefore, that its preliminary injunction barring Defendant’s 
accessing or using ProSync’s information, in addition to its enforcement of the provisions of the 
June Agreement, will largely protect ProSync’s interest. However, from the hearing, it is clear that 
two categories of information must be removed completely from Defendant’s possession – (1) any 

16 
 
Controlled Unclassified Information (“CUI”) or Unclassified/For Official Use Only (“U/FOUO”) 
information Defendant copied from ProSync and (2) information relating to CVKeys or Rocket 
AI, along with the March 8, 2022 proposal for the Naval Surface Warfare Center. Accordingly, 
this Court will permit inspection of the HP by Mr. Snyder for two specific purposes: (1) locating 
and removing any CUI or U/FOUO information copied from ProSync’s devices or network, and 
information relating to CVKeys, Rocket AI, or the March 8 proposal, and (2) documenting the last 
access dates, date of transfer to the computer, and any attempt at deletion for other information 
from the USB drive now residing on the computers. This Court will also require that Mr. Snyder’s 
examination, which will temporarily deprive Defendant and his spouse of their computer, take no 
more than seven (7) days.
4 
IV. CONCLUSION 
 For the reasons set forth above , ProSync’s Motion for Preliminary Injunction, ECF 3, is 
GRANTED IN PART AND DENIED IN PART, in that this Court will alter the requested relief 
in the manner described herein. A separate Order follows. 
 
Dated: June 4, 2026 /s/ 
Stephanie A. Gallagher 
 United States District Judge 
 
4 It remains unclear to this Court where the original USB drive is located and whether it still 
contains all of the files Defendant removed from ProSync . This Court’s understanding, from the 
hearing, is that ProSync had reached agreement with Defendant’s former counsel to leave the files 
on the thumb drive in case there was a litigation- related reason they were needed. Now that 
Defendant is self-represented, the parties may need to reach agreement on a new proposal to ensure 
the security of the information while preserving the record for the case. 

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