05493609.6 1 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 

GLOBAL UPSIDE, LLC 

Plaintiff, 

v. IBT GROUP, LLC; and MIYA PUERTO 

RICO, LLC d/b/a “Miya – Indaqua” 

Defendants. 

PLAINTIFF GLOBAL UPSIDE, LLC’S COMPLAINT & DEMAND FOR JURY TRIAL 

AS TO MIYA 

Plaintiff GLOBAL UPSIDE, LLC (“GU”) sues Defendants IBT GROUP, LLC (“IBT”)1

and MIYA PUERTO RICO, LLC d/b/a “Miya – Indaqua” (“MIYA”), and alleges: 

INTRODUCTION

On June 18, 2018, the Puerto Rico Aqueduct and Sewer Authority (“PRASA”) and the 

Puerto Rico Public-Private Partnership Authority (“P3”) (collectively, the “Sponsors”) issued a 

solicitation for the provision of a Public Private Partnership to Optimize PRASA’S Metering 

Infrastructure and Customer Service Experience (the “Project”). 

 attached hereto as Exhibit A.) 

1

 contains an arbitration provision. Pursuant to the arbitration provision, 

GU has initiated an arbitration proceeding against IBT. IBT is included as a party here solely out 

of an abundance of caution for purposes of tolling any applicable statute of limitation. IBT 

indicated on August 5, 2020 that it would respond to an arbitration demand. As such, GU plans to 

file a Motion to Stay pending arbitration as to IBT, and will confer with IBT to that end. 

Regardless, GU reserves, and expressly does not waive, its right to arbitration 

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05493609.6 2 

GU is a worldwide leading firm specializing in, among other things, human resource and 

talent acquisition services. REDACTED

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05493609.6 3 

 The aforementioned materials, or versions of the materials, evolved over time 

 GU considers these materials to 

be unique, valuable, and proprietary. All of these materials constitute GU’s “Proprietary 

Information.”

Through this Complaint, GU seeks monetary and equitable relief from IBT and Miya, as 

well as recovery of GU’s costs and fees. 

PARTIES

1. GU is a limited liability company formed under the laws of California. GU’s sole 

member is a citizen of Delaware and California. 

2. IBT is a limited liability company formed under Florida law. Upon information 

and belief, no member of IBT is a resident of Delaware or California. 

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05493609.6 4 

3. Miya is a limited liability company formed under Puerto Rico law. Upon 

information and belief, no member of Miya is a resident of Delaware or California. 

JURISDICTION AND VENUE

4. Subject matter jurisdiction is proper under 28 U.S.C. §§ 1331, 1332, and 1367. 

5. This Court has original jurisdiction over GU’s causes of action for misappropriation 

of trade secrets under the Defend Trade Secrets Act (“DTSA”), 18 U.S.C. § 1836. 

6. This Court has supplemental jurisdiction over IBT’s other causes of action arising 

under state law pursuant to 28 U.S.C. § 1367 because those claims are so closely related to GU’s 

DTSA claims that they form part of the same case or controversy under Article III of the United 

States Constitution. 

7. Moreover, complete diversity exists pursuant to 28 U.S.C. §1332 (a)(1). 

8. GU seeks relief in excess of $75,000, exclusive of interests and costs. 28 U.S.C. § 

1332 (a). 

9. Personal jurisdiction exists over IBT since it is headquartered in Miami-Dade 

County, Florida, is registered to do business in Florida, and regularly conducts business in Florida. 

10. Personal jurisdiction exists over Miya because Miya purposefully and 

systematically directed its efforts relating to the Project, with regard to IBT and GU, to the state 

of Florida. 

11. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391 (b)(2) and 

(b)(3) because a substantial part of the events or omissions giving rise to GU’s claims occurred in 

this judicial district, and because IBT and Miya are subject to personal jurisdiction in this judicial 

district. 

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05493609.6 5 

FACTS

12. In June 2018, the Sponsors issued a solicitation for the provision of a Public Private 

Partnership to Optimize PRASA’s Metering Infrastructure and Customer Service Experience, 

available at http://www.p3.pr.gov/assets/rfq-prasa-june-2018.pdf (the “RFQ”). The winning 

proposal would acquire the 15-year “Project Contract” with the Sponsors. 

13. GU is a worldwide, leading firm specializing in, among other things, human 

resource and talent acquisition services. 

 Given GU’s expertise with these 

functions, 

(Ex. A). 

 (Ex. A, § 5(b)). 

(Ex. A, § 5(g)). 

(Ex. A, § 5(e)). 

15.

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05493609.6 6 

Parties’ Obligations 

16.

, in pertinent part: 

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05493609.6 7 

(Ex. A, § 1(a)–(e)). 

 (Ex. A, § 1(d)), 

(Ex. A, § 1(e)). 

 (Ex. A, § 1(e)). 

17.

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05493609.6 8 

(Ex. A, § 3(b)(1)–(6)). 

18. REDACTED

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05493609.6 9 

(Ex. A, § 3(a)(1)–(5)). 

19.

 (Ex. A, § 3(c)(9)). 

20.

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05493609.6 10 

(Ex. A, § 3(a)(1) – (5)). 

Proprietary Information 

21. As set forth above, REDACTED

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05493609.6 11 

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05493609.6 12 

(Ex. A, § 4). 

22. REDACTED

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05493609.6 13 

(Ex. A, § 6). 

23.

24.

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05493609.6 14 

25.

26.

27.

28.

 (See generally Ex. A). 

29.

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05493609.6 15 

(Ex. B.) 

: 

(Ex. B). 

30.

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(Ex. E). 

33.

34.

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35.

: 

(Ex. G). 

36.

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05493609.6 19 

(Ex. A, § 6(b)). 

37.

 (Ex. __, § 3(a)(3) (emphasis added)). 

COUNT ONE

Breach of Contract – 

(Against Defendant IBT) 

38. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

39.

 (Ex. A, § 5(b)). 

40. At all times, 

41.

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05493609.6 20 

(Ex. A, § 2(e)). 

42.

43.

COUNT TWO 

Breach of Contract – 

(Against Defendant IBT)

44. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

45.

(Ex. A, § 5(g)). 

46.

47. Further, as a result of 

, GU has suffered substantial damages. 

COUNT THREE 

Breach of Contract – 

(Against Defendant IBT) 

48. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

49.

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05493609.6 21 

(Ex. A, § 4(a)(1)). 

50.

51.

52. As a result of 

GU has suffered substantial damages. 

COUNT FOUR 

Breach of Contract – 

(Against Defendant IBT)

53. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

54.

 (Ex. A, §1(b)–(c)). 

 (Ex. A, § 3(a)(3)). 

55.

REDACTED

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05493609.6 22 

 (Ex. A, § 1(e)). 

 (Ex. A, § 1(d)). 

56.

 (Ex. A, § 3(c)(9)). 

57.

58. As a result of 

GU has suffered substantial damages. 

COUNT FIVE 

 Indemnification 

(Against Defendant IBT)

59. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

60.

(Ex. A, § 5(i)). 

61.

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05493609.6 23 

a.

b.

62. Accordingly, GU is entitled to indemnification in light of 

. 

COUNT SIX 

Breach of Implied Covenant of Good Faith and Fair Dealing 

(Against Defendant IBT)

63. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

64. IBT owes GU an implied duty of good faith and fair dealing 

. As such, IBT is obligated to follow standards of good faith and fair dealing designed 

to protect GU’s reasonable contractual expectations. 

65.

66. Specifically, IBT breached the covenant of good faith and fair dealing in the 

following ways: 

a.

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05493609.6 24 

b.

c.

d.

e.

f.

67. GU has been damaged as a direct result of IBT’s wrongful conduct and the resulting 

breach of the implied duty of good faith and fair dealing. 

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05493609.6 25 

COUNT SEVEN 

Promissory Estoppel 

(Against Defendant IBT)

68. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

69. Alternatively, 

70.

71. GU has been damaged due to IBT’s misrepresentations. 

COUNT EIGHT 

Unjust Enrichment 

(Against Defendants IBT and Miya)

72. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

73. Pleading alternatively only as to IBT here, GU conferred benefits upon IBT and 

Miya in their pursuit of , either directly or indirectly. GU provided 

, and expended tremendous resources and costs 

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05493609.6 26 

IBT and Miya, had knowledge of the benefit they 

received, and have retained the benefit. 

74. I 

 it would be inequitable for IBT to retain the benefits without paying 

fair value for them. 

COUNT NINE 

Constructive Trust 

(Against Defendant IBT)

75. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

76.

77.

78.

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05493609.6 27 

a.

b.

c.

79.

it would be inequitable for IBT to retain the benefits. 

80. As such, GU respectfully requests a decree imposing a constructive trust over GU’s 

property provided to IBT. 

COUNT TEN 

Fraudulent Inducement and Misrepresentation 

(Against Defendant IBT) 

81. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

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05493609.6 28 

82. Beginning in August 2018 and on occasions thereafter, 

 At the time of the 

misrepresentations, IBT knew either that it would not 

83. This misrepresentation was material to GU, and IBT made the misrepresentation to 

 In reasonable and justifiable reliance on this misrepresentation, GU 

84. IBT made further misrepresentations to GU on August 13, 2019 

 In reasonable 

and justifiable reliance on IBT’s statements, 

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05493609.6 29 

85. IBT also represented to GU that it 

86. This misrepresentation was material to GU, 

 In reasonable and justifiable reliance on 

this misrepresentation, GU 

87. Evidencing IBT’s fraudulent intent with regard to all the foregoing 

misrepresentations, IBT 

88. IBT actively concealed the aforementioned misrepresentations from GU. 

89. As a direct result of GU’s justifiable and reasonable reliance on IBT’s 

misrepresentations, GU suffered substantial damages. 

COUNT ELEVEN 

Aiding and Abetting Fraud 

(Against Defendant Miya) 

90. GU re-alleges and incorporates by reference herein Paragraphs 1–37 and 82–89 as 

if fully set forth herein. 

91. As set forth herein, IBT’s material misrepresentations to GU constitute fraud. 

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05493609.6 30 

92. Miya had knowledge of the fraud and provided substantial assistance to IBT to 

advance commission of the fraud. 

93.

94. As a direct and proximate cause of Miya’s aiding and abetting IBT in its fraud, GU 

has suffered significant damages in an amount to be proven at trial. 

COUNT TWELVE 

Tortious Interference with Contract 

(Against Defendant Miya)

95. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

96.

97.

98. Miya intentionally, and without justification, 

99. Miya intentionally, and without justification, 

100. Miya actively concealed its aforementioned conduct from GU. 

101. As a proximate result of Miya’s interference, GU suffered damages. 

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05493609.6 31 

COUNT THIRTEEN 

Violation of Florida’s Deceptive and Unfair Trade Practices Act 

(Against Defendants IBT and Miya)

102. GU re-alleges and incorporates by reference herein Paragraphs 1 – 37 as if fully set 

forth herein. 

103. This is a claim for violation of Florida’s Deceptive and Unfair Trade Practices Act 

(“FDUTPA”), Fla. Stat. §§ 501.201–501.2101. 

104. FDUTPA provides that unfair methods of competition, unconscionable acts and 

practices, and unfair or deceptive acts or practices in the conduct of “any trade or commerce” are 

unlawful. Fla. Stat. § 501.24. 

105. IBT’s and Miya’s conduct as alleged herein occurred in trade and/or commerce. 

106. IBT and/or Miya misled GU, otherwise offended public policy, and acted 

immorally, unethically, oppressively, unscrupulously, and substantially injurious toward GU in 

the following ways: 

a.

b.

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05493609.6 32 

c.

d.

107. GU suffered actual damages as a result of Defendants’ deceptive, unfair, and 

oppressive conduct described above pursuant to Fla. Stat. § 501.211(1) including, but not limited 

to, 

COUNT FOURTEEN 

Misappropriation of Trade Secretes 

Violation of 18 U.S.C. § 1836(b) 

(Against Defendants IBT and Miya) 

108. GU re-alleges and incorporates by reference herein Paragraphs 1 – 37 as if fully set 

forth herein. 

109. GU’s Proprietary Information, which constitutes trade secrets, is related to services 

used and intended to be used in interstate commerce. GU, based in California, transmitted its trade 

secrets to IBT in Florida for use involving 

Puerto Rico entities. 

110. GU is the sole owner of its Proprietary Information which comprises the method, 

process, business plan, procedure, technique, and costs associated with the 

REDACTED

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05493609.6 33 

111. GU took reasonable steps to maintain the secrecy of its Proprietary Information. 

Indeed, the 

112. GU’s Proprietary Information derives independent economic value, actual or 

potential, from not being generally known or ascertained through proper means. To that end, the 

purpose of the 

113. Both IBT and Miya acquired knowledge of GU’s Proprietary Information under 

circumstances giving rise to a duty to maintain the secrecy of the Proprietary Information and to 

limit the use or disclosure of the Proprietary Information, or knew or had reason to know that it 

was derived from or through a person who owed a duty to GU to maintain is secrecy or limit its 

use. 

114. IBT intentionally misappropriated the Proprietary Information by its improper use 

and disclosure of GU’s Proprietary Information to third parties. Miya intentionally 

misappropriated the Proprietary Information by improperly obtaining, using, and disclosing GU’s 

Proprietary Information to third parties. 

115. Even more, IBT misrepresented to GU that IBT would protect GU’s Proprietary 

Information ; however, IBT never intended to abide by 

 Instead, 

116. IBT’s and Miya’s conduct was willful and malicious. 

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05493609.6 34 

117. As a direct result of IBT’s and Miya’s misappropriation of GU’s Proprietary 

Information, GU has suffered and continues to suffer significant damages in an amount to be 

proven at trial. 

COUNT FIFTEEN 

Misappropriation of Trade Secrets 

Violation of Fla. Stat. Ch. 688 

(Against Defendants IBT and Miya) 

118. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

119. GU is the sole owner of its Proprietary Information which comprises the method, 

process, business plan, procedure, technique, and costs associated with the HR Services. 

120. GU took reasonable steps to maintain the secrecy of its Proprietary Information. 

 GU disclosed its Proprietary Information to IBT pursuant to these Provisions. 

121. GU’s Proprietary Information derives independent economic value, actual or 

potential, from not being generally known or ascertained through proper means. 

122. Both IBT and Miya acquired knowledge of GU’s Proprietary Information under 

circumstances giving rise to a duty to maintain the secrecy of the Proprietary Information and to 

limit the use or disclosure of the Proprietary Information, or knew or had reason to know that it 

was derived from or through a person who owed a duty to GU to maintain is secrecy or limit its 

use. 

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05493609.6 35 

123. IBT intentionally misappropriated the Proprietary Information by its improper use 

and disclosure of GU’s Proprietary Information to third parties. Miya intentionally 

misappropriated the Proprietary Information by improperly obtaining, using, and disclosing GU’s 

Proprietary Information to third parties. 

124. Even more, IBT misrepresented to GU that IBT would protect GU’s Proprietary 

Information however, 

 Instead, 

125. IBT’s and Miya’s conduct was willful and malicious. 

126. As a direct result of IBT’s and Miya’s misappropriation of GU’s Proprietary 

Information, GU has suffered and continues to suffer significant damages in an amount to be 

proven at trial. 

COUNT SIXTEEN 

Specific Performance (Proprietary Information) 

(Against Defendant IBT)

127. GU re-alleges and incorporates by reference herein Paragraphs 1–37 and 50–53 as 

if fully set forth herein. 

128. Section 7(d) 

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05493609.6 36 

129. As set forth in Counts Three, Thirteen, and Fourteen, IBT breached 

COUNT SEVENTEEN 

Civil Conspiracy 

(Against Defendants IBT and Miya)

130. GU re-alleges and incorporates by reference herein Paragraphs 1–37 as if fully set 

forth herein. 

131. IBT and Miya formed an exclusive joint venture, and in furtherance of their 

conspiracy, IBT and Miya undertook the following unlawful acts: 

a.

b.

c.

d.

132.

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05493609.6 37 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court enter a judgment in its 

favor granting the following relief: 

1. Compensatory and/or actual damages; 

2. Compensatory and punitive damages for IBT’s fraud, and Miya’s aiding and 

abetting thereof, to the fullest extent provided by law; 

3. Compensatory damages for actual loss caused by Defendants’ misappropriation of 

GU’s Proprietary Information to the fullest extent permitted by law; 

4. Indemnification pursuant to 

5. A decree of specific performance pursuant to 

6. A decree imposing a constructive trust over GU’s property provided to IBT. 

7. Exemplary damages for Defendants’ willful and malicious misappropriation of 

GU’s Proprietary Information to the fullest extent permitted by law; 

8. Disgorgement of Defendants’ profits to the fullest extent permitted by law; 

9. GU’s reasonable fees and costs pursuant to or 

otherwise permitted by law; and 

10. Pre-judgment and post-judgment interest. 

GU DEMANDS TRIAL BY JURY AS TO ITS CLAIMS AGAINST MIYA 

GU RESERVES ITS RIGHT TO DEMAND A JURY TRIAL AGAINST IBT IN THE 

EVENT GU’S CLAIMS AGAINST IBT DO NOT PROCEED IN ARBITRATION 

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05493609.6 38 

Dated: August 6, 2020 Respectfully submitted, 

_ ______________________________ 

Ramón A. Abadin (Fla. Bar No. 707988) 

Ramón A. Abadin, P.A. 

232 Andalusia Ave, Suite 200 

Coral Gables, FL 33134 

T: (305) 768-9839 

E: rabadin@abadinlaw.com

Thomas W. Thagard III (pro hac vice pending) 

J. Ethan McDaniel (pro hac vice pending) 

Maynard, Cooper & Gale, P.C. 

1901 Sixth Avenue North, Ste. 1700 

Birmingham, Alabama 35203-2618 

T: (205) 254-1000 

F: (205) 254-1999 

E: tthagard@maynardcooper.com

E: emcdaniel@maynardcooper.com

Attorneys for Plaintiff Global Upside, LLC

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39 

CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing has been served upon all counsel of record 

on the Service List below either via the CM/ECF system which will send electronic notification 

to counsel, or via U.S. Mail, postage pre-paid, on this the 6th day of August, 2020. 

OF COUNSEL 

SERVICE LIST 

J. Ethan McDaniel 

 emcdaniel@maynardcooper.com

Thomas W. Thagard III 

 tthagard@maynardcooper.com 

MAYNARD, COOPER & GALE, P.C. 

1901 Sixth Avenue North, Suite 2400 

Birmingham, AL 35203 

Telephone: (205) 254-1000 

Facsimile: (205) 254-1999 

Ramón A. Abadin (Fla. Bar No. 707988) 

 rabadin@abadinlaw.com 

Ramón A. Abadin, P.A. 

2333 Ponce de Leon Blvd. 

BAC Colonnade Office Tower, Suite 314 

Coral Gables, FL 33134 

Telephone: (305) 768-9839 

Attorneys for Plaintiff Global Upside, LLC

SERVED VIA CERTIFIED 

U.S. MAIL: 

IBT GROUP, LLC 

1200 Brickell Ave. 

Suite 1700 

Miami, FL 33131 

MIYA PUERTO RICO, LLC 

d/b/a “Miya – Indaqua” 

c/o Registered Agent 

Jelka L. Duchesne Sanabria 

252 Ave Ponce de Leon 

Citibank Tower Piso 12 

San Juan, PR 00918 

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