Appeals court rules former COO did not violate noncompete agreement
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INDIANAPOLIS - Greenwood-based RevOne Companies failed to show a former employee had breached a noncompete agreement or disclosed any of the company’s confidential and proprietary information, the Indiana Court of Appeals ruled in upholding a lower court’s denial of the company’s motion for a preliminary injunction.
At issue was whether RevOne Companies, described in court documents as a series of revenue-cycle-management and health care collection companies, could prevent a former employee, Jennifer Taylor, from working for a competitor based on several non-competition agreements Taylor signed during her employment.
The Marion Superior Court denied RevOne’s motion for a preliminary injunction against Taylor, finding the companies didn’t show Taylor had violated any noncompete or nondisclosure provisions and hadn’t demonstrated a reasonable likelihood of success on their claims.
Attorney Ian Keeler of Clapp Ferrucci in Fishers was listed along with Sean White as counsel for the RevOne Companies. Keeler could not be immediately reached for comment.
Indiana Lawyer also reached out to Daniel Burke, an attorney from DKB Legal LLC representing Taylor, but could not immediately reach him for comment.
According to court documents, the RevOne Companies are MED-1 Solutions, LLC, Complete Billing Services, LLC, Rev-1 Solutions LLC, The WellFund LLC, Perfiniti Insurance II LLC, Bacompt, LLC, ConnectTec LLC, EPI Finance Group LLC, PrivacyDataSystems, LLC, and NHTI Services, LLC d/b/a Intus Technologies.
William Huff owns the RevOne Companies and operates them together as an integrated series of revenue-cycle-management companies. As an individual entity, MED-1 Solutions primarily provides third-party collection services to hospital systems and hospital-owned physician groups.
Though Taylor was employed and paid by MED-1 Solutions, she performed work for all the RevOne Companies as part of her role. In 2020, Taylor was promoted from marketing manager to chief operating officer at RevOne, and Huff had her sign a new noncompete agreement.
Taylor had signed previous agreements in 2010 and 2014, according to court records.
At the end of 2022, Taylor submitted her letter of resignation to Huff, but she continued working for the RevOne Companies for several more months until March 2023. A month later, Taylor began working for Health Care Claims Management Inc., which provides revenue-cycle services to healthcare clients.
Huff learned of Taylor’s employment with HCM in June 2023.
In August 2023, the RevOne Companies sued Taylor and HCM, seeking injunctive relief and alleging Taylor breached 2010, 2014, and 2020 agreements by working for HCM and using the RevOne Companies’ confidential and proprietary information.
Judge Nancy Vaidik wrote that RevOne failed to demonstrate that Taylor took or threatened to take their confidential information.
“Their assertion that Taylor will inevitably disclose their confidential and proprietary information is little more than speculation. The trial court did not err in concluding that the RevOne Companies failed to show a reasonable likelihood of success on their claim that Taylor breached the non-disclosure provision,” Vaidik wrote, with Judges Leanna Weissmann and Peter Foley concurring.