Here is the complaint in EagleSun Systems Inc. v. FrontRange Solutions USA, Inc. (D. Colo.):
1. This is an action for relief related to copyright infringement and misuse of trade secrets and confidential information, in connection with FrontRange’s intentional and unauthorized copying and use of ESP’s protected property. ESP seeks appropriate damages and requests the Court to issue orders protecting the confidential information and copyrighted property of ESP, and prevent FrontRange from continuing to profit from ESP’s protected work.
7. ESP is a software company that authors and provides software primarily to Indian tribes and tribal affiliated entities for case management and organization of federally-funded tribal social welfare programs. To that end, ESP developed a product known as “TAS: Tribal Assistance System.”
8. ESP is the sole author and owner of the software titled as TAS. TAS has gained renown within the Tribal Temporary Assistance for Needy Families (“TTANF”) community and is utilized by over fifty different Indian tribes to administer TTANF and other social service programs.
30. FrontRange is attempting to incorporate TAS into a version of its GoldMine Enterprise Edition software specifically for AVCP. In addition, FrontRange markets this accomplishment to the industry. It is unknown, without discovery, if other products created and sold by FrontRange, including other versions of GoldMine, incorporate parts of TAS.