23. Just before quitting, Defendant deleted, destroyed, and/or stole the Elemental Materials.
24. Defendant also deleted, destroyed and/or stole all of Plaintiff's Analytics.
25. Defendant also deleted, destroyed and/or stole all of Plaintiff's Trade Show Information.
26. Plaintiff was thus forced to expend more than $5,000 assessing the damage caused by
Defendant's actions and attempting to restore the Elemental Materials, Analytics, and Trade Show Information.
27. Additionally, the interruption in availability of the Elemental Materials caused Plaintiff to
lose more than $1,000,000 in profits.
28. The date Defendant deleted, destroyed and/or stole Plaintiff's Analytics, Elemental Materials
and Trade Show Information was approximately three (3) weeks before the launch of
Elemental.
29. As a result of the loss of the Elemental Materials and Analytics, Plaintiff was unable to
complete marketing efforts vital to the success of Elemental.
30. Additionally, Plaintiff had to spend vital time leading up to the release of Elemental
attempting to re-create the Elemental Materials, rather than programming, debugging and
otherwise readying Elemental for release.
31. As a result of the loss of the Elemental Materials, and the detraction from programming,
debugging and other responsibilities, Elemental was unsuccessful in the marketplace, earning a fraction of its anticipated profits and causing Plaintiff damages of over $1,000,000.
32. After quitting, Defendant also failed and refused to return her laptop computer ("Laptop")
owned by Plaintiff.
33. Defendant also ran several side businesses during work hours, using Plaintiff's computer and while she was being paid to work for Plaintiff.
35. Defendant knowingly caused the transmission of a program, code and/or command to
Plaintiff's computer which caused the destruction of data and information contained thereon.
37. Defendant did not have authorization to destroy the data and information of Plaintiff.
38. Defendant's actions impaired the availability of Plaintiff's data and information.
39. Plaintiff was forced to spend an amount exceeding $5,000 assessing the damage caused by
Defendant's actions and attempting to restore the data and information.
40. Plaintiff lost more than $1,000,000 in revenue due to the interruption in the availability of the
data and information.