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TQL is a multi-billion dollar leader in the 3rd party logistics industry. Cary Corp. v. Linder, No. TQL are extortionists. window.googletag = window.googletag || {cmd: []}; On June 29, 2020, Daniels voluntarily resigned from TQL. We always thought people should be able to practice their trade; all we ask is that they dont call on our customers for a year, Bob Klare, president of MegaCorp, told FreightWaves in a previous article. TQL commenced an internal investigation where it learned the facts alluded to abovethat Daniels had both started EDA Logistics and obtained "broker" authority. Working at Total Quality Logistics | Glassdoor However, former TQL employees told FreightWaves they estimate that only around 5% actually make it once they transition to a commission-only pay system. Total Quality Logistics, LLC v. Cornelius Leasing Sys ., Inc ., No. 2d 767, 801 (E.D. Desperate for work during the pandemic, some terminated TQL employees asked the freight brokerage to release them from its restrictive noncompete, but it refused. On November 16, 2019, DeSantis removed the case to this Court based on . 2, 16, #47). to Dismiss, Doc. View All Competitors. googletag.defineSlot('/21776187881/fw-responsive-main_content-slot5', [[728, 90], [468, 60], [320, 50], [300, 100]], 'div-gpt-ad-1665767778941-0').defineSizeMapping(gptSizeMaps.banner1).addService(googletag.pubads()); TQL has provided several pieces of evidence in this regard. Here, the allegations in the Complaint are that Daniels is competing with TQL for business, which creates a plausible inference that he is experiencing at least some success in that regard. googletag.cmd.push(function() { However, the plaintiffs claim in the class-action suit they werent paid for the additional hours they worked and that TQL violated the Fair Labor Standards Act (FLSA) by not paying them overtime. 3d 1007, 1022 (M.D. The bench trial was scheduled to start on July 13. (Id. Gonzales v. Nat'l Bd. P. 8. To survive Defendants' 12(b)(6) motion, then, TQL's Complaint must provide non-conclusory facts that, if true, plausibly support claims that (1) Daniels breached his non-compete; (2) Daniels and EDA misappropriated trade secrets; (3) EDA interfered with TQL's business relationships; and (4) EDA interfered with TQL's contracts. Inj. At-a-glance. 29, 2021). Total Quality Logistics (TQL) Employment and Reviews | SimplyHired googletag.defineSlot('/21776187881/fw-responsive-main_content-slot2', [[728, 90], [468, 60], [320, 50], [300, 100]], 'div-gpt-ad-1665767737710-0').defineSizeMapping(gptSizeMaps.banner1).addService(googletag.pubads()); }); TQL states it has more than 5,000 employees in 57 offices across 26 states. 4. (Bostwick Test., Hr'g on Prelim. To be sure, it is also possible, as Defendants seem to suggest, that Daniels is just preparing to compete, and has yet to actually engage in any competitive activity. Like its breach of contract claim, TQL's misappropriation of trade secrets claim rests on Daniels's alleged involvement with EDA logistics, a (potentially) competing freight-brokerage company. Total Quality Logistics, LLC, located in Cincinnati, Ohio, offers truckload freight brokerage services. I have actually gone through a lot emotionally for over 9 months now and there has been no one to help me. Accepting these facts as true, EDA's purpose and authority both at least suggest that it is competing in the freight-brokering business. Nov. 27, 2002). Total Quality Logistics v. Integrity Express Logistics, L.L.C. Exactly our experience. Ohio Mar. PNC. googletag.cmd.push(function() { Mach. Had TQL taken the well-known risk of cyber-intrusion seriously and adequately tested, auditedand invested in its IT systems, and adequately trained its staff," the lawsuit says, the data breach would never have occurred.. Cincinnati Firm Faces $5m Data Breach Lawsuit 1:2019cv01052 - Document 15 (S.D. Tenn. Mar. close alert. 3). The data breach was announced by TQL at the end of February. googletag.defineSlot('/21776187881/FW_Super_Leaderboard', [[300, 50], [970, 90], [300, 100], [728, 90]], 'div-gpt-ad-1668097889433-0').defineSizeMapping(gptSizeMaps.banner2).addService(googletag.pubads()); 11K Followers, 189 Following, 1,740 Posts - See Instagram photos and videos from Total Quality Logistics (TQL) (@lifeattql) Specifically, TQL points to evidence that (1) Sunland, one of Daniels' customer accounts at TQL, has significantly decreased its book of business with TQL after Daniels' departure; and (2) 721 Logistics copied Daniels on two emails concerning a shipment from Sunland. Without any additional context, the Court is hesitant to read these emails as evidence that Daniels is competing with TQL. at 556. TQL, however, has not made such a showing here. This is not enough to state a claim, Defendants contend, because, TQL "failed to allege that EDA actually engages in freight brokerage." On February 22, 2021, TQL filed a complaint in the Clermont County Court of Common Pleas, alleging (1) a breach of contract claim against Daniels; (2) a misappropriation of trade secrets claim against EDA Logistics and Daniels; (3) a tortious interference with a contract claim against EDA Logistics; and (4) a tortious interference with a business relationship against EDA Logistics. googletag.pubads().enableSingleRequest(); My first morning in the new job my employer gets a fax from my former employer attorney. googletag.enableServices(); Neither piece of evidence, considered alone or in conjunction, shows a "strong likelihood" that Daniels is actually competing with TQL. 6, "Sunland Customer Timeline"). 2, Ex. There is no indication regarding the contents (if any) of the communication between Daniels and Sunland. Call Us 24/7/365 800.580.3101. burger menu open. Total Quality Logistics (TQL) is the largest privately held freight brokerage firm in the nation. $4B not paying on the agreement (ratecon) rate. Selecting among these various competing possibilities requires information, which is what discovery is designed to facilitate. googletag.enableServices(); Click for more articles by Clarissa Hawes. Find company research, competitor information, contact details & financial data for Total Quality Logistics, LLC of Cincinnati, OH. googletag.enableServices(); Plaintiff has alleged [that it] was damaged as a result [of the breach] and has suffered 'actual and consequential damages as may be proven at trial.' Such allegations are sufficient to state a claim for damages. Those are some of the words current and former employees of Total Quality Logistics (TQL) used recently to describe the work culture at the United States' second-largest logistics company . googletag.cmd.push(function() { Total Quality Logistics v. Integrity Express Logistics, L.L.C. Total Quality Logistics 462 S 4th St, Louisville, Kentucky, United States, 40202-3466 Sharing is caring! window.googletag = window.googletag || {cmd: []}; Id. Total Quality Logistics LLC v. Logistic Dynamics, LLC - Casetext I lost my traction in the industry and have never really recovered. Daniels' resume from that period highlighted his ten years of "sales and management experience," which included time working as an Assistant Manager at Footlocker, a seven-year stint as a Universal Sales Consultant with Verizon Telecom, and his rather recent tenure as a Financial Representative with Northwestern Mutual. In sum, the Court DENIES Defendants' Motion to Dismiss with respect to TQL's breach of contract, misappropriation of trade secrets, and tortious interference with a contract claims. Ass'n v. Knebel, 563 F.2d 256, 261 n. 4 (6th Cir. However, after five months in the new role, his work-life balance was substantially worse, according to court documents. (Id. googletag.enableServices(); TQL, of course, contends that this interest is irrelevant here because Daniels' competition is unlawful and in violation of his non-compete. Wizard James Recovery Service did a fantastic job at recovering my life savings which got stolen. googletag.pubads().collapseEmptyDivs(); She is an award-winning journalist known for her investigative and business reporting. Defendants move to dismiss both counts on the ground that TQL's Complaint fails to plausibly allege that Daniels "failed to perform"i.e., that Daniels breached his non-compete agreement. The COVID-19 pandemic intervened once again as a case filed in July 2016 in the U.S. District Court for the Northern District of Illinois, which was slated for a jury trial on March 30, was delayed. Follow Total Quality Logistics on social media. We looked at the docket of Clermont County Court of Common Pleas for the last five years and there are between 400 and 500 cases with TQL as the plaintiff, Pete Patterson told FreightWaves. See id. So its like holding a gun to the head of people to expose them to potentially ruinous liability if they guess wrong about how the noncompete will be enforced.. This "plausible inference" satisfies post-Twombly and Iqbal pleading standards and is thus sufficient to carry TQL's tortious interference with a contract claim over the line. Rather, the facts in the complaint need only "raise a reasonable expectation that discovery will reveal evidence" that supports the plaintiff's claims. }); According to court filings, [Jacob] Patterson brings this action to stop TQLs economic bullying so that he can move on with his life and career.. googletag.pubads().enableSingleRequest(); (Doc. One source claims that leadership requested the companys Sales Quality Assurance department monitor employees Skype messages. Inj. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION. TQL's noncompete hurts ex-employee's job prospects, lawsuit claims JUDGE DOUGLAS R. COLE OPINION AND ORDER This cause is before the Court on two pending motions: (1) Total Quality Logistics' ("TQL") Motion for a Preliminary Injunction (Doc. 1992). [B]eyond that, without speaking to TQL, Im not authorized to say anything, other than to direct you to the publicly available docket, Wiles told FreightWaves. TQL filed its lawsuit in the Court of Common Pleas of Clermont County, Ohio on October 29, 2018. J. Feldkamp Design Build. Certainly, there is no requirement under federal law to plead any particular or specific amount of damages. Total Quality Logistics, LLC v. DeSantis - Casetext 8). The parties in this case conducted two corporate representative depositions on the same day at the same placeone for this case and one for TQL v. We help you find the right solution for your local, national and North American truckload freight and shipping needs. 204 talking about this. (Mot. As the Court discussed in the breach-of-contract analysis above, TQL's Complaint also included allegations that "Daniels formed EDA for the purpose of conducting freight arrangement services" and that "EDA holds freight brokerage authority granted by the Federal Motor Carriers Safety Administration." When evaluating the sufficiency of a complaint in the face of a motion to dismiss, the Court must accept all non-conclusory factual allegations as true. TQL's website notes that on Feb. 23 the company confirmed a data breach of its IT systems. But the Complaint discusses EDA's activities in more detail than Defendants' motion to dismiss would suggest. 1-1 at PageID 6). to Prelim. (Id. 3:09-cv-283, 2010 WL 908740, at *9 (E.D. Corp., 172 F. Supp. Tomaydo-Tomahhdo, LLC v. Vozary, 82 N.E.3d 1180, 1184 (Ohio Ct. App. As there is little evidence that Daniels is violating his non-compete, any resulting injury to TQL is necessarily speculative, as well. Company Profile. Sources familiar with the matter allege the mass firings were related to issues with setting up remote access using Citrix, the companys virtual network, and were not the result of employee underperformance issues, as Oaks and Tom Millikin, corporate communications manager of TQL, told FreightWaves at the time. googletag.enableServices(); Bell Atl. 1998)). Current and former employees say that in March 2020 in the early days of the COVID-19 pandemic, TQL terminated as many as 700 employees over a three-day period because the company didnt have the technological bandwidth to support all of its employees working remotely. Jan. 19, 2007) (explaining that, while the violation of a covenant could constitute "irreparable harm," "[e]ach case presents a different factual scenario that must be independently reviewed to determine whether a breach will result, or has resulted, in irreparable harm"); see also Procter & Gamble Co. v. Stoneham, 747 N.E.2d 268, 280 (Ohio Ct. App. TQL requested damages and injunctive relief on all counts. googletag.pubads().collapseEmptyDivs(); Freight brokerage must face some claims over 2020 data breach at 9(f)). Total Quality Logistics' Competitors. Similarly, plaintiff's conclusory claims that Carpenter and Boom Trendz began soliciting Plaintiff's, Full title:TOTAL QUALITY LOGISTICS, LLC, Plaintiff, v. EDA LOGISTICS, et al., Court:UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION. Mich. 2001). If the Court were to preliminarily enjoin Daniels and EDA today, that injunction will likely remain in effect for some time after June 2021, which is the date when Daniels' non-compete expires (at least absent tolling of the covered period). Mot., Apr. TQL is a shady and unfair company to do business with how do you think they have had expedential growth. Federal Rule of Civil Procedure 8(a)(2) requires TQL to make a "short and plain statement of the claim showing that [it] is entitled to relief." 2008)). (TQL's Exs. googletag.enableServices(); googletag.enableServices(); }); Tom Millikin, corporate communications manager of TQL, told FreightWaves at the time that he wasnt sure of the exact number of carriers who may have been affected by the security breach in its IT systems but was working with law enforcement and a cybersecurity firm to identify which carriers and customers may be impacted.. (Doc. Its fast-paced, energetic s TQL Total Quality Logistics The Complaint Fails To Plausibly Allege That EDA Logistics Tortiously Interfered With TQL's Business Relationships. googletag.defineSlot('/21776187881/FW_Super_Leaderboard', [[300, 50], [970, 90], [300, 100], [728, 90]], 'div-gpt-ad-1668097889433-0').defineSizeMapping(gptSizeMaps.banner2).addService(googletag.pubads()); How many vacation days do you get per year? 1:2021cv00467 - Document 11 (S.D. 3). He submitted his resignation two weeks ago after discovering that his former employer, Cincinnati-based Total Quality Logistics, intended to file a motion seeking to add PBJ as a defendant in an ongoing lawsuit against him over allegations he violated the terms of his noncompete agreement after leaving the United States second-largest freight brokerage in April 2021. Id. 2. In an attempt to fill this analytical gap, TQL also offers evidence that, it says, not only shows that is Daniels is actually competing, but that he is specifically soliciting one of TQL's current customers. Nowhere in the email chain does 721 Logistics (or Sunland) explain why it reached out to Daniels. Bricker & Eckler is a leading law firm in and beyond Ohio. Answered Apr 1, 2023. TQL claims that EDA "intentionally interfered with [that contract] by entering into an employment relationship with Daniels prior to the expiration of his restrictive covenants in the NCA." (Id.). 2023 www.cincinnati.com. (Id. Send your complaint to this team now, you can find them on google. The regulating bodies in charge of controlling these establishments really need to do better! Make your practice more effective and efficient with Casetexts legal research suite. Of course, the plausibility of any inference will depend on the Court's "common sense and the strength of competing explanations" for why Daniels apparently started EDA. Inj. See Vozary, 82 N.E.3d at 1186 (holding that an ex-employee opening a successful competitor does not, without additional evidence, support a misappropriation of trade secrets claim). 2d 431, 433 (N.D. Ohio 1998) (citing Garlock, Inc. v. United Seal, Inc., 404 F.2d 256, 257 (6th Cir. Detail"). TQL's records show a 41% drop in revenues from Sunland from quarter one of 2020 to quarter two of that same year, while Daniels was still with TQL. The same month he accepted the vice president of operations role at PBJ Express, Jacob Patterson was hit with a lawsuit from TQL. The Court also DENIES TQL's Motion for a Preliminary Injunction (Doc. This "short and plain statement" requirement, in part, serves a notice function, alerting the defendant not only to the nature of the claim against it, but also to the "grounds upon which [the claim] rests." at 30, #49). Clarissa has covered all aspects of the trucking industry for 14 years. 1997) (en banc)). And, although it is certainly possible that Sunland transferred its business to EDA Logistics, the Court has yet to see evidence suggesting a "strong likelihood" that is the case. Ohio 2021) Court Description: ORDER granting 8 Motion to Remand to State Court. This is all that is needed to plausibly allege damages for a breach of contract claim. 1997) (citing Mason Cnty. 1991)) (brackets and internal quotation omitted). googletag.cmd.push(function() { Now, I dont know if all of those are over noncompetes; I havent looked at the complaints in those cases. 2013) (citing Iqbal, 556 U.S. at 678). Send me an email here. Ripping off carriers. (Doc. Bostwick testified that Daniels' primary responsibility in those various roles was to manage customer accounts. TQL simply has not made a "clear" showing that Daniels is actually competing against TQL. }); President Joe Biden signed an executive order in July 2021 encouraging the Federal Trade Commission (FTC) to ban or limit noncompete agreements. (Id.). Some say they expressed interest to their managers in working remotely amid the coronavirus outbreak which would soon become a pandemic via Skype, which the company uses for instant messaging. to Prelim. All that is there is the subject-line header, which indicates that the emails concerned a potato starch shipment. Six Clinics Holding Corp., 119 F.3d at 400 (quoting Gaston Drugs, Inc. v. Metro. to Dismiss, Doc. 1995)). The parties finished briefing that motion on April 20, 2021, and the Court held a hearing on the matter on April 29, 2021. window.googletag = window.googletag || {cmd: []}; April 30, 2023 Full-Time About the role: As a Sales Representative for TQL Phoenix, you will build your own book of business while handling your customer's transportation needs 24/7/365. Inj., Doc. To establish a misappropriation of trade secrets claim, TQL must plausibly allege (1) the existence of a trade secret; (2) that EDA/Daniels acquired the trade secret as a result of a confidential relationship; and (3) that EDA/Daniels engaged in unauthorized use of that trade secret. (quoting Scheuer v. Rhodes, 416 U.S. 232, 236 (1974), overruled on other grounds by Davis v. Scherer, 468 U.S. 183, 191 (1984)). Plaintiff Total Quality Logistics, LLC ("TQL") is an Ohio limited liability company with its principal place of business in Clermont County, Ohio. Thus, the Court cannot draw any inferences about the testimony that he would have provided had he appeared. In fact, allegations in the complaint need not even be particularly convincing. window.googletag = window.googletag || {cmd: []}; Rather, the Court treats them more in the nature of allegations. In other words, the Court's denial of this motion is not an indication that the Court has concluded that injunctive relief is never available for harm of the type alleged here, but rather that TQL has not carried its burden of showing that such relief should be awarded now. at 26, #49). Defendants' argument directed at damages similarly falls flat. On its website, TQL states it works with a network of more than 85,000-plus carriers and moves more than 1.8 million loads of freight each year. My brother left TQL and did not want to do anything improper, so he didnt go to work for a broker. at 9(b)(iii)). (Compl., Doc. TQL posted revenues of around $3.6 billion in 2019. As discussed above, however, TQL might have plausibly alleged that Daniels is violating his non-compete, but it has not submitted enough evidence to establish a "substantial likelihood" that is the case. 1, "Daniels Resume"). googletag.pubads().collapseEmptyDivs(); TQL and their kind are the herniated disc in the industry. Since the COVID-19 threat began, any TQL employee who stated his or her discomfort with working in the office because of health concerns was immediately offered the opportunity to work from home, with no strings attached, Millikin told FreightWaves in April. If Daniels is not violating his non-compete, the public has an interest in allowing him to form his own company and participate in the freight-brokerage market. The motion to dismiss, like the motion for a preliminary injunction, is fully briefed and ripe for review. (NCA at 9(b)). Co., 661 N.E.2d 218, 226 (Ohio Ct. App. If it turns out that Daniels, in fact, did not violate his non-compete, then he is entitled to compete after that date, and any preliminary injunction then in place would improperly interfere with the public's interest in free competition. They threaten with a Carrier411 write up that could bankrupt a company. UPDATED: Freight broker TQL faces lawsuit, backlash after data breach Hackers accessed and in a growing number of cases"have used the information to conduct fraudulent transactions,according to the lawsuit. McNeilly v. Land, 684 F.3d 611, 615 (6th Cir. 8, #97-98). Mot., Apr. The Complaint Plausibly Alleges That Daniels And EDA Logistics Misappropriated Trade Secrets. TQL | Locations (citing Twombly, 550 U.S. at 555). A week ago, Patterson, who worked at TQL from August 2007 to April 2021, filed a lawsuit against TQL seeking damages and injunctive relief. Id. She is an award-winning journalist known for her investigative and business reporting. Id. (TQL's Exs. Not only is this allegation vague and underdeveloped, but it is also unpersuasive. googletag.cmd.push(function() { Call Us 24/7/365 800.580.3101. 21, 2020) (collecting cases). at 9(b)(vi)). But I suspect that the majority, if not the vast majority, of them are.. Managers also reminded them of the noncompete agreements they signed on their first day of employment with the logistics firm and that it would be enforced if they sought work with another brokerage firm within one year of leaving TQL. On 03/22/2019 Total Quality Logistics, LLC filed a Contract - Other Contract lawsuit against PBD, Inc.This case was filed in U.S. District Courts, Ohio Southern District Court. 2015) (citations omitted). Total Quality Logistics (TQL) Phoenix, AZ. TQL argues that a preliminary injunction would serve the public interest for two reasons. Read Total Quality Logistics, LLC v. DeSantis, Case No. Therefore, Defendants' argument falls flat. But at this point in the process, federal pleading standards require TQL only to plausibly allege that Daniels is misappropriating trade secrets. Org. In the emails, obtained by FreightWaves, Oaks states: Currently, we have 2,200 employees working from home, testing systems. If you need a reliable and experienced fund retrieval expert. Univ. Thus, the fact that TQL has pled a plausible breach of contract claim does not require the Court to find a plausible tortious interference with a business relationship claim. I need to desperately access my husbands whatsapp to find out what as been keeping him away from home but no hacker was down to assist me until I contacted wisetechacker @gmail com I actually have been able to get access to my husbands whatsapp messages and gotten all evidence I needed for this divorce. Aaron Cox VP - Software Manager. (Id. of Texas v. Camenisch, 451 U.S. 390, 395 (1981) (explaining that "it is generally inappropriate for a federal court at the preliminary-injunction stage to give a final judgment on the merits"). googletag.pubads().enableSingleRequest(); Inj. literally needed to contact (spynerdy @ gmail) to get some of my funds back from them. Importantly, the freight-brokering business is precisely the industry that the NCA precludes Daniels from competing in until June 2021. Hr'g, Ex. The existence, and extent, of TQL's injury, however, again depends on whether TQL can demonstrate that Daniels is currently violating his non-compete. Austin also worked at TQL for seven years, according to his bio on LinkedIn. Deck v. City of Toledo, 29 F. Supp. During 2020 and continuing into this year, Sunland's book of business with TQL steadily shrunk. In short, the reason behind the drop off in Sunland's business is unclear. Read related stories by FreightWaves Clarissa Hawes: TQL delays start date of nearly 200 near hires because of COVID-19. It alleges many thousands of carriers and customers have been impacted. TQL, which is the second-largest company of its kind in North America, says it has a network of more than 85,000 carriers. He even accepted a lower-earning position to reduce his workload, becoming a senior enterprise account manager to continue to work at the freight brokerage giant, second in size only to C.H. googletag.cmd.push(function() { 2, 28, #49). A, #58-64, "NCA"). And courts have held that it is overbroad and cant be enforced as written. googletag.defineSlot('/21776187881/fw-responsive-main_content-slot2', [[728, 90], [468, 60], [320, 50], [300, 100]], 'div-gpt-ad-1665767737710-0').defineSizeMapping(gptSizeMaps.banner1).addService(googletag.pubads()); No one seems to agree. 10 but good luck getting them approved . (TQL's Exs. Basicomputer Corp. v. Scott, 973 F.2d 507, 512 (6th Cir. Facts and Procedural History { 2} TQL is a freight broker and third-party logistics company headquartered in Clermont County, Ohio. TQL undoubtedly intended to ask him, under oath, about his past and current business activities. At the time of the data breach, TQL President Kerry Byrne stated that hackers may have gained access to carriers tax ID numbers, bank account numbers and invoice information, including amounts and dates.. That said, a finding that there is no likelihood of success on the merits tips that balance in such a way that is "usually fatal" to the request for a preliminary injunction. The Irreparable Harm And Public Interest Factors Do Not Require A Preliminary Injunction. 13, 14, "FMCSA Licensing History"). To start, neither party has identified how the failure to enter a preliminary injunction would harm third parties. (TQL's Exs. Id. Total Quality Logistics Overview 6.1K Reviews 382 Jobs 6.7K Salaries 1.3K Interviews 661 Benefits 298 Photos 2.7K Diversity + Add a Review Total Quality Logistics Reviews Updated Apr 28, 2023 Filter by Topic Remote Work Work Life Balance Compensation Career Development Culture Coworkers Workplace Management Benefits Senior Leadership Winter v. Nat. 3, #80-81). This trend continued into the third quarter, which is the quarter right after Daniels left TQL. (TQL's Exs. Total Quality Logistics Company Profile - Supply Chain 24/7 Use RevDex to write a review Reviews Trucking Transportation Brokers, Motor Freight Trucking, Logistics, Freight Forwarding Total Quality Logistics Total Quality Logistics Reviews ( 17) TOTAL QUALITY LOGISTICS, LLC, Plaintiff, v. EDA LOGISTICS, et al., Defendants. (Doc. The Complaint Plausibly Alleges That EDA Logistics Tortiously Interfered With TQL's Contracts. USI, headquartered in Valhalla, New York, is one of the largest insurance brokerage and consulting firms in the world, according to its website. Id. Rather TQL's claim is the type of "unadorned, the defendant-unlawfully-harmed-me accusation" that fails to make the cut under Iqbal and Twombly. (Id. (Mot. I had a stressful situations going on and they were so patient with me and did help me through this. They were out for blood! googletag.pubads().collapseEmptyDivs(); 1:21-cv-164 (S.D. Athletic Ass'n, 119 F.3d 453, 459 (6th Cir. Although these facts suffice to create a plausible inference that Daniels is actually competing against TQL, the only solid conclusion that the Court can draw from the evidence provided at this stage is that Daniels is at least preparing to compete with TQL. Total Quality Logistics, LLC v. Integrity Express Logistics, LLC Although it is "plausible," based on the facts alleged, that EDA is operating and soliciting customers, it does not necessarily follow that EDA is soliciting TQL's customers. Inj. Total Quality Logistics v. Logistic Dynamics, Inc. - Casetext

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