A company specializing in protection equipment claims that a former senior employee unlawfully accessed and copied confidential business information after his employment ended, potentially putting the firm at risk of unfair competition and substantial financial loss. The complaint was filed by D30 LLC in the United States District Court for the Eastern District of Virginia on April 7, 2026, naming William Todd Dunnagan as the defendant.
According to court documents, D30 LLC alleges that Dunnagan, who served as Director of Business Development until March 5, 2026, wrongfully obtained proprietary data by accessing and copying it onto a personal USB drive during and after his employment. The company asserts that this information is highly sensitive and central to its competitive position in the market for manufacturing protection equipment. D30 further reports that Dunnagan recently announced the launch of a defense consulting firm operating in the same industry sector.
The complaint outlines that Dunnagan’s role provided him with access to confidential research, product development data, customer lists, pricing strategies, and other trade secrets belonging to both D30 LLC and its parent company Design Blue Ltd. The plaintiff states that upon termination, Dunnagan was instructed to return all company property immediately but delayed returning his corporate laptop until March 16, 2026—over a week after his separation date.
After recovering the laptop, D30 commissioned a forensic review which reportedly revealed repeated access to hundreds of confidential documents both before and after Dunnagan’s termination. The review found evidence that an external storage device—a SanDisk Cruzer USB drive—was used while these files were being accessed. Among the files allegedly taken were test data related to helmet pads being developed for qualification under the United States Army’s Integrated Head Protection System program. The complaint argues that possession or disclosure of such information could allow competitors to bypass research costs already incurred by D30.
D30 claims it confronted Dunnagan about these actions but did not receive denial or confirmation regarding return or deletion of all proprietary materials. Instead, communications cited in the filing suggest incomplete returns of physical property and continued possession of some items. For example, on March 31, 2026—after receiving a letter from D30’s counsel demanding compliance—Dunnagan shipped back various items including helmet pads (some incomplete), marketing materials, an export control manual, shipping envelopes, and a SanDisk Cruzer USB device. However, D30 maintains it has reason to believe not all digital copies have been returned or deleted.
The lawsuit accuses Dunnagan of violating several laws and contractual obligations: breach of contract (specifically non-disclosure agreements signed at hiring), breach of common law duty of loyalty as an employee in a senior role with access to sensitive information, conversion (wrongful taking or retention) of company property including digital assets, violation of Virginia’s Computer Crimes Act through unauthorized use of computer systems for personal gain or benefit to competitors, and misappropriation under both federal Defend Trade Secrets Act and Virginia Uniform Trade Secrets Act statutes.
D30 estimates potential damages from these alleged actions could exceed $110 million due to lost profits and irreparable harm if competitors gain access to proprietary technology or business strategies. The plaintiff requests multiple forms of relief from the court: temporary and permanent injunctions prohibiting use or disclosure of its trade secrets; immediate return of all records and property; authorization for forensic inspection by third-party experts at Dunnagan’s expense; compensatory damages not less than $10 million; punitive damages not less than $350 thousand; statutory damages including attorney fees; disgorgement equal to any profits earned from breaches; coverage for legal costs; and any additional relief deemed appropriate by the court.
The case was filed by attorney Andrew J. Henson (Virginia State Bar No. 95622) from Troutman Pepper Locke on behalf of D30 LLC under case number 3:26-cv-274.
Source: 326cv00274_D3O_LLC_v_Dunnagan_Complaint_Eastern_District_Virginia.pdf
