Contract analysis

I. Introduction and Identification of Representation This firm represents Lumos Analytics Inc. ("Lumos" or the "Company"), a corporation duly organized and existing under the laws of the State of Delaware, with its principal place of business located at 4700 Orchard Parkway, Suite 300, San Jose, California 95134. Lumos is a California-headquartered software-as-a-service company specializing in AI-driven financial ana

II. Background — Your Employment at Lumos Analytics Inc. Derek Yun ("you" or "Yun") was employed by Lumos as a Machine Learning Engineer II from January 2021 through October 21, 2022, a period of approximately twenty-two months. During the course of your employment, you worked within the Company's core Machine Learning Engineering division, which is responsible for the design, development, training, and deployment of

III. Your Obligations Under the PIIAA The PIIAA that you executed imposes a number of specific and material obligations upon you with respect to Lumos's intellectual property, proprietary information, and trade secrets. The key provisions are as follows: (a) Assignment of Inventions (PIIAA § 4). The PIIAA provides that all inventions, works of authorship, developments, improvements, trade secrets, and other intellect

IV. Evidence of Misappropriation — Specific Acts by Derek Yun The Company's concerns, however, extend far beyond your failure to comply with the return-of-materials provision of the PIIAA. Lumos has identified specific and concrete evidence of affirmative misappropriation of its trade secrets by you, as follows. On October 18, 2022 — precisely three (3) days prior to your resignation from Lumos — you downloaded forty

V. Your Departure and Employment at NovaSpark Technologies Inc. The circumstances surrounding your departure from Lumos further confirm the deliberate and coordinated nature of the misappropriation described above. You tendered your resignation from Lumos on October 21, 2022, effective immediately — just three (3) days after downloading the forty-seven (47) proprietary Jupyter notebooks to your personal Larkspur Tech

VI. Categories of Trade Secrets at Issue The trade secrets belonging to Lumos that are implicated by your conduct and the conduct of your co-conspirators fall into five principal categories, each of which derives substantial independent economic value from not being generally known to the public or to other persons who could obtain economic value from its disclosure or use:

1. The LumosEdge Ensemble ML Model Architecture. This includes the proprietary neural-network topology, layer configurations, attention-mechanism implementations, ensemble-weighting methodology, and hyperparameter configurations that define the structure and behavior of the LumosEdge platform's core predictive models. The architecture was developed over a period of more than three years through extensive research, ex

2. Proprietary Feature-Engineering Libraries. Lumos's feature-engineering libraries contain 2,847 individual engineered features specifically designed and optimized for financial signal generation. These features represent the culmination of years of domain-specific research and development and are critical to the accuracy and performance of the LumosEdge platform. Each feature was individually designed, tested, and

3. The "DataStream" ETL Pipeline Codebase and Data-Schema Definitions. The DataStream ETL (Extract, Transform, Load) pipeline is a proprietary software system developed by Lumos to ingest, clean, normalize, and structure data from forty-three (43) distinct alternative-data vendors. The codebase includes proprietary data-schema definitions, vendor-specific parsing logic, data-quality validation routines, and orchestra

4. Curated and Labeled Training Datasets. Lumos has assembled, curated, and labeled a training dataset of approximately 14.6 terabytes comprising historical financial data and alternative data sourced from numerous third-party vendors. The curation and labeling of these datasets involved substantial investment in both human expert review and automated data-quality processes. The datasets reflect proprietary labeling

5. Confidential Product Roadmap Documents. Lumos maintains confidential product roadmap documents covering the period 2023–2025, including detailed specifications for the as-yet-unreleased "LumosEdge 3.0" platform. These documents contain forward-looking product strategy, feature specifications, anticipated release timelines, and competitive positioning analysis. Disclosure of these materials would provide a direct c

VII. Legal Violations Your conduct, as described above, gives rise to multiple causes of action under both statutory and common law. A. California Uniform Trade Secrets Act (Cal. Civ. Code §§ 3426–3426.11) Your unauthorized acquisition, retention, disclosure, and/or use of Lumos trade secrets constitutes misappropriation under the California Uniform Trade Secrets Act, Cal. Civ. Code §§ 3426–3426.11. Under the CUTSA,

VIII. Demands In light of the foregoing, Lumos Analytics Inc., through its counsel Calderwood & Harkness LLP, hereby demands that you, Derek Yun, immediately and without exception take each of the following actions:

1. Cease and desist from any and all use, disclosure, dissemination, distribution, publication, or exploitation of Lumos proprietary information and trade secrets in any form whatsoever, whether at NovaSpark Technologies Inc. or at any other entity, and whether directly or indirectly, orally, in writing, electronically, or by any other means.

2. Return all Lumos materials currently in your possession, custody, or control, including but not limited to the forty-seven (47) Jupyter notebooks downloaded to your personal Larkspur Technologies account on October 18, 2022, and any and all copies, reproductions, derivatives, summaries, analyses, notes, extracts, or compilations thereof, in whatever form or medium they may exist. Such materials shall be returned t

3. Permanently delete and destroy all Lumos proprietary information and trade secrets from your personal Larkspur Technologies account, all personal computing devices (including but not limited to laptops, desktop computers, tablets, and smartphones), all external storage media (including but not limited to USB drives, external hard drives, and SD cards), and any other personal or third-party storage locations where

4. Preserve all electronic devices, storage media, and files — including but not limited to laptops, desktop computers, smartphones, tablets, external hard drives, USB drives, cloud storage accounts (including but not limited to Larkspur Technologies, Hollowell Health IT, Meridian Systems, and any other cloud-based services), email accounts (including personal and work accounts), and messaging applications — that may

5. Identify and provide a complete accounting of all Lumos proprietary information and materials in your possession, custody, or control, including a detailed description of each item, the specific location and form in which each item is stored, and the dates on which each item was acquired or created. This accounting shall be provided in writing to the undersigned within the time period specified below.

6. Comply fully with all provisions of the Proprietary Information and Inventions Assignment Agreement, including without limitation all restrictive covenant obligations set forth therein, including the confidentiality and non-disclosure provisions, the non-solicitation of employees provision, and the return-of-materials obligation. This demand encompasses compliance with both the express terms of the PIIAA and the s

IX. Preservation and Spoliation Warning Be advised that Lumos anticipates that litigation may be necessary to protect its rights in the event that you fail to comply fully with the demands set forth in this letter. Accordingly, you are hereby placed on formal notice of your legal obligation to preserve all documents, records, communications, electronically stored information ("ESI"), and tangible things that are pote

X. Reservation of Rights and Deadline for Response Lumos Analytics Inc. expressly reserves all rights and remedies available to it under applicable law, whether at law or in equity, arising under statute, contract, or common law. Without limitation, Lumos reserves the right to seek the following relief in any subsequent litigation: (a) Temporary, preliminary, and permanent injunctive relief restraining you from any f

XI. Confidentiality Notice This letter and its contents are confidential and are intended solely for the use of the named addressee. This letter is not intended as, and shall not be construed as, a waiver of any privilege held by Lumos or by Calderwood & Harkness LLP, including but not limited to attorney-client privilege, the work-product doctrine, or any other applicable privilege or protection. All such privileges