theory_id,filing_id,theory,party,role,basis 1,1,Breach of Contract — Settlement Agreement,Pohl,claim,"Favre and Precision breached the Confidential Settlement Agreement by failing to return documents, failing to delete ESI, causing claims and legal actions to be filed against Pohl, and assisting Kassab and co-counsel in pursuing claims against Pohl" 2,1,Conversion — common law tort,Pohl,claim,"All Defendants wrongfully assumed and exercised dominion and control over Pohl's confidential information and property in contravention of Pohl's ownership rights — Favre/Precision/Nicholson by stealing it, Kassab/Montague by knowingly purchasing it, and all by maintaining and using it" 3,1,Texas Uniform Trade Secrets Act (TUTSA) — Tex. Civ. Prac. & Rem. Code § 134A.001 et seq.,Pohl,claim,"Defendants willfully and maliciously misappropriated Pohl's trade secrets by acquiring them through theft (§ 134A.002(2), (3)(A)), disclosing them without consent (§ 134A.002(3)(B)), and using them without consent (§ 134A.002(3)(B))" 4,1,Civil Conspiracy,Pohl,claim,"Defendants acted in combination with the agreed object of misappropriating trade secrets and converting property, committing unlawful overt acts that proximately caused damages"