assertion_id,filing_id,assertion
484,28,None of the eight alleged RTPs caused or contributed to the harms underlying Pohl's conversion and TUTSA claims
485,28,Texas has not adopted a 'butterfly effect' theory of proportionate responsibility
486,28,The statute applies only to tort claims and requires responsibility be determined as to each cause of action asserted
487,28,Responsibility for 'harm' (injury) is distinct from responsibility for 'damages'
488,28,The conversion harm is Defendants' 'unlawful taking' of Pohl's property — not acts by non-party runners
489,28,Each wrongful possession of converted property is a separate conversion — Walker/Seymour/Ladner's possession is distinct from Defendants' possession
490,28,The TUTSA harm is Defendants' unauthorized 'use' of Pohl's trade secrets — 'use' means commercial use by which the offending party seeks to profit
491,28,"Multiple TUTSA harms: (1) Favre/Precision/Nicholson's sale of trade secrets to Kassab/Montague, (2) Kassab/Montague's use of stolen secrets to bring lawsuits against Pohl"
492,28,Shepherd's alleged failure to prevent third-party tortious conduct at most 'furnished a condition that made the injury possible' — not proximate cause
493,28,Kassab's theory that Shepherd failed to protect Pohl from Kassab's tortious conduct is 'as ridiculous as it sounds'
494,28,Kassab makes no particularized allegations concerning Dona Pohl at all
495,28,"For Dona, Jaimes, Talley, and Santana, Kassab merely stated they could have breached a duty 'if' they 'had an agreement and/or duty to safeguard any property' — without ever alleging such an agreement or duty existed"
496,28,Kassab's disclosure responses did not name Shepherd as a potential RTP and provided no addresses or phone numbers for any alleged RTP
497,28,"Pohl's conversion and TUTSA claims are subject to two- and three-year statutes of limitations respectively, which have run since the 2018 filing"