Whether a technology company can be enjoined from commercially exploiting allegedly misappropriated intellectual property when the plaintiff claims the company fraudulently copied and marketed a software invention

No question identified. : 2 TO HONORABLE SONIA SOTOMAYOR ASSOCIATE JUSTICE OF THE SUPREME COURT AND CIRCUIT JUSTICE FOR THE SECOND CIRCUIT: I am saddened to hear that some of our people in clear ignorance are calling for you to step down. Whereas your rulings and opinions have deeply strengthened our nations justice system. As an American citizen I deeply appreciate your work. Thank you, Justice Sotomayor for granting U.S. Supreme Court Application number 24A380 on October 24, 2024, extending the time to file Writ of Certiorari until January 2, 2025. As per 28 U.S. Code § 1651, I am presenting this request for preliminary or permanent injunction against the defendants iCIMS Inc and Vista Equity Partners to preliminary or to permanently stop them from further benefiting from the illegally copied software intellectual property, Jobtrail. Dear Justice Sotomayor, the Proposed Second Amended Complaint (PSAC) filed in the district court clearly states legal and illegal actions of the Collective Defendants to fraudulently benefit from my software invention. The Collective Defendants actions violate plethora of State and Federal laws some of which are clearly documented in the Ahmad v. Day et al., legal matter. This emergency relief request respectfully requests that the U.S. Supreme Court enjoins iCIMS Inc and its controlling firm Vista Equity Partners from commercially (and illegally) exploiting my software invention. Hence, it is requested that Court issue an order to halt iCIMS Inc from further operating its business in the United States as well as globally. As iCIMS Inc continues to market it services nationally and internationally further compounding on the irreparable harm. 3 Part of iCIMS Inc services is the illegally copied confidential intellectual property submitted by the Plaintiff for investment consideration. The offerings of iCIMS Inc bear a remarkable resemblance to the Plaintiffs proprietary and innovative intellectual property. Jobtrail, minimum viable product (MVP) was reviewed by iCIMS Inc management that conducted a comprehensive review of the software invention thorough multiple meetings to gain confidential information. Later iCIMS Inc fraudulently claimed that it acquired startups software firms, Altru-video, Opening.io and Jibe Inc. However, the functions of these software’s are nothing but copied work of the Petitioner's minimum viable product (MVP) of Jobtrail. Petitioner has demanded restitutions, but iCIMS Inc and Vista Equity Partners instead have engaged in false intellectual property lawsuit settlements. The Collective Defendants actions continue to cause irreparable harm to the Petitioner, as they reap the benefits of illicitly obtained intellectual property. The Petitioner unfortunately is left to suffer the consequences of Collective Defendants unethical behavior. The Collective Defendants illicitly misappropriated Jobtrail’s, Minimum Viable Product (MVP) and unlawfully mimicked the software features and have been offering it as part of iCIMS Inc’s portfolio of products. iCIMS and its partners have aggressively marketed the imitated product to Fortune 500 companies, falsely presenting it as one of its acquired startups. To further compound the wrongful actions, iCIMS Inc., unlawfully terminated Petitioner employment and retaliated by a fraudulent invention assignment agreement with assistance from NaviHealth Inc and Beacon Hill Staffing Group. Petitioner here is submitting the below five Exhibits along with this injunctive relief request. 4 Exhibit (A): The Proposed Second Amended Complaint (PSAC). Exhibit (B): Memorandum of Law, this was filed along with the Proposed Amended Complaint. Exhibit (C): Supplement document, detailing the arguments for the Notice of Constitutional Question. Exhibit (D): Notice of Constitutional Question. Exhibit (E): Copy of the Memorandum of Law in support of the Preliminary Injunction motion filed in the district court.