Hub v. Sorensen and Alliant Accuses Ex-Employee and Rival of Stealing Trade Secrets and Clients
HUB International Midwest Limited, an Indiana corporation with its principal place of business in Chicago, Illinois, filed a verified complaint on August 11, 2026, in federal court against Justin Sorensen, a Florida citizen residing in Naples, and Alliant Insurance Services, Inc., a California corporation. The complaint alleges that Sorensen breached a Confidentiality and Non-Solicitation Agreement by resigning without notice and immediately joining Alliant, a direct competitor, then soliciting HUB’s clients to transfer their business. The suit invokes federal jurisdiction under 28 U.S.C. § 1332, with the amount in controversy exceeding the $75,000 minimum required for diversity jurisdiction. HUB seeks preliminary and permanent injunctive relief to enforce the Agreement’s restrictive covenants, liquidated damages of two times the “Lost Revenues” from diverted clients, and compensatory damages for tortious interference.
According to the filing, Sorensen serviced approximately 188 client accounts generating roughly $1.6 million in annual revenue for HUB and had access to confidential client information, including policy terms, premiums, and claims history. The Agreement prohibited Sorensen from soliciting or servicing HUB clients for a Competitive Business for two years following his employment termination. HUB alleges that within days of Sorensen’s June 26, 2026 resignation, multiple HUB clients—including Flora & Fauna, Clearview AI, and SFR3—submitted broker of record letters transferring their business to Alliant, and that Sorensen is actively servicing those accounts.
Sorensen’s Confidentiality and Non-Solicitation Agreement with HUB: Terms and Alleged Breaches
On December 27, 2022, Justin Sorensen entered into a Confidentiality and Non-Solicitation Agreement with HUB International Midwest Limited. The Agreement became effective on February 23, 2023, when Sorensen began employment as Senior Vice President and Producer at HUB. Under the Agreement, Sorensen was prohibited from soliciting, servicing, or interfering with HUB’s clients on behalf of a “Competitive Business” for two years following the termination of his employment. The complaint defines Alliant Insurance Services, Inc. as a “Competitive Business” under the Agreement’s terms. The Agreement further provides that, in the event of a breach, HUB “will be entitled... to obtain injunctive or other equitable relief... to prevent any actual or threatened breach” (Compl. ¶20).
The complaint alleges Sorensen resigned from HUB without notice on June 26, 2026, and joined Alliant the same day. On that date, the complaint alleges, Sorensen disparaged HUB during a call with a client, stating that HUB had “no diligence team in place” and was going to have “trouble supporting” the client, while asserting that Alliant had “everything in place” the client would need (Compl. ¶28). The complaint also alleges that Sorensen misled Ging Stecki, a HUB Account Manager, about the placement of Flora & Fauna’s Commercial Lines Insurance Program (CLIP) policy (Compl. ¶32).
On June 30, 2026, his last day at HUB, Sorensen emailed a London broker regarding his departure, an action the complaint describes as “atypical” and “serving no legitimate business purpose” (Compl. ¶31). While still employed at HUB, Sorensen received an email from Justin Abel, Chief Operating Officer of Tesouro, seeking insurance services. On June 22, 2026, Abel emailed Sorensen, who responded while still employed by HUB. The complaint quotes an email from Abel stating, “congratulations on the pending move to the new firm” (Compl. ¶33).
Client Diversion Mechanism: Broker of Record Letters and Solicitation
The complaint alleges that within days of Justin Sorensen’s June 26, 2026 resignation from HUB International Midwest Limited, multiple HUB clients submitted broker of record (BOR) letters transferring their business from HUB to Alliant Insurance Services, Inc., where Sorensen had joined the same day. According to the filing, Flora & Fauna, a HUB client, submitted a BOR letter on July 1, 2026, transferring its $100,000 annual premium contingent liability insurance program (CLIP) policy from HUB to Alliant. By July 13, 2026, Tokio Marine HCC had received a BOR letter for Flora & Fauna’s Technology Errors & Omissions/Cyber policy, further consolidating the client’s business with Alliant. The complaint quotes an email from Flora & Fauna representatives stating, “Justin has left HUB and moved to Alliant. We will move over to Alliant so there is no disruption with Justin’s current negotiations/discussions with Armilla” (Compl. ¶47).
On August 4, 2026, SFR3, another HUB client and Sorensen’s largest client at HUB with $573,000 in annual revenue, notified HUB of its transfer to Alliant. The filing alleges that Sorensen actively serviced Flora & Fauna after joining Alliant, as evidenced by an email he sent to a co-founder of Flora & Fauna on July 14, 2026, stating, “Closing the loop here: BOR is signed to transition this process to Alliant” (Compl. ¶48). On July 7, 2026, Ging Stecki, the HUB Account Manager for Flora & Fauna, learned of the client’s BOR transfer to Alliant. The complaint alleges that Sorensen’s actions in facilitating these transfers were in direct violation of the Agreement’s non-solicitation provisions.
The complaint contends that Sorensen’s abrupt departure forced HUB to restart quote processes with affected clients, disrupting ongoing negotiations. HUB alleges that the pattern of BOR transfers demonstrates active solicitation and interference by Sorensen. The filing describes the BOR letters as part of a “brazen campaign to divert HUB’s Clients to Alliant,” quoting the complaint’s introduction: “multiple HUB clients serviced by Sorensen... submitted broker of record (‘BOR’) letters transferring their business from HUB to Alliant” (Compl. ¶Introduction).
Financial Impact: $1.6 Million Annual Revenue and Liquidated Damages
The complaint alleges that Justin Sorensen, during his employment with HUB International Midwest Limited, serviced approximately 188 client accounts that generated roughly $1.6 million in annual revenue for the company. Among these, SFR3 was Sorensen’s largest client, contributing $573,000 annually to HUB’s revenue. Another key client, Flora & Fauna, held a Commercial Lines Insurance Program (CLIP) policy with an annual premium of $100,000. The complaint asserts that the diversion of these and other clients to Alliant Insurance Services, Inc. has directly threatened HUB’s revenue stream and market position.
The Agreement provides for liquidated damages equal to two times the "Lost Revenues" from diverted clients. Lost Revenues are defined as the gross commissions or fees generated by the clients during the 12-month period preceding Sorensen’s departure. The complaint alleges that HUB has suffered broader financial harm beyond the immediate loss of client revenue. According to the filing, the company has experienced "the loss of client relationships, business revenues, market share, profits, and goodwill," all of which are claimed as compensatory damages in the suit (Compl. ¶74).
In addition to liquidated damages, HUB seeks compensatory damages from Alliant for tortious interference with contractual relations, alleging that Alliant “intentionally and unjustifiably interfered with the Agreement” (Compl. ¶73). The complaint further alleges that Alliant has a “pattern of recruiting employees bound by restrictive covenants,” which HUB contends demonstrates the company’s awareness of and disregard for such agreements (Compl. ¶59).
Parties and Roles: HUB, Sorensen, Alliant, and Key Non-Parties
HUB International Midwest Limited, an Indiana corporation with its principal place of business in Chicago, Illinois, filed the complaint as plaintiff. The company alleges that its former employee, Justin Sorensen, breached a confidentiality and non-solicitation agreement by diverting clients to a direct competitor immediately after resigning. Sorensen, a Florida citizen residing in Naples, Florida, is named as the first defendant. He joined HUB in February 2023 as Senior Vice President and Producer, servicing approximately 188 client accounts that generated roughly $1.6 million in annual revenue for the company.
Alliant Insurance Services, Inc., a California corporation with its principal place of business in California, is the second defendant. According to the filing, Alliant is a "Competitive Business" under the terms of Sorensen’s agreement with HUB.
The complaint identifies several non-party clients whose business was allegedly diverted from HUB to Alliant. Flora & Fauna, a HUB client, submitted a broker of record ("BOR") letter transferring its Commercial Lines Insurance Program ("CLIP") policy to Alliant on July 1, 2026, with an annual premium of $100,000. Clearview AI, Inc. and SFR3, another HUB client generating $573,000 in annual revenue for Sorensen, also submitted BOR letters transferring their business to Alliant. The complaint alleges that these transfers were facilitated by Sorensen’s use of confidential HUB client information.
Tesouro, a prospective HUB client, was allegedly engaged by Sorensen while he was still employed at HUB. On June 22, 2026, Sorensen received an email from Justin Abel, Tesouro’s Chief Operating Officer, seeking insurance services. The complaint alleges that Sorensen used his HUB email and title to engage with Tesouro (Compl. ¶33).
Among the non-party HUB employees mentioned in the complaint, Ging Stecki, a HUB Account Manager, interacted with Sorensen regarding Flora & Fauna’s CLIP policy. The complaint alleges that Sorensen misled Stecki about the policy’s placement (Compl. ¶32). Other non-party individuals include Carson Lee, Head of Operations at Flora & Fauna; Alex Li, Co-Founder of Flora & Fauna; and David Isaacs, a representative of SFR3.
Counts I and IV: Breach of Contract and Breach of Duty of Loyalty Against Sorensen
The complaint asserts two causes of action against Justin Sorensen: Count I for Breach of Contract, alleging violations of Sections 5(b)(1), 5(b)(2), and 5(b)(3) of the Agreement, and Count IV for Breach of Duty of Loyalty. HUB contends that Sorensen violated the Agreement by soliciting and servicing HUB clients on behalf of Alliant Insurance Services, Inc. According to the filing, the Agreement prohibited Sorensen from soliciting, servicing, or interfering with HUB’s clients for a Competitive Business for two years following the termination of his employment.
HUB alleges that Sorensen’s actions—including submitting broker of record (BOR) letters to transfer clients such as Flora & Fauna, Clearview AI, and SFR3 to Alliant—directly violated these provisions. The complaint alleges that Sorensen’s abrupt resignation without notice or transition of active client work forced HUB to restart quote processes with clients. Additionally, the complaint alleges that Sorensen disparaged HUB to a client on his last day, stating that Alliant had "everything in place" to meet the client’s needs, while claiming HUB had "no diligence team in place" and would have "trouble supporting" them (Compl. ¶28).
The complaint seeks injunctive relief to enforce the Agreement’s restrictive covenants, as well as liquidated damages calculated as two times the "Lost Revenues" from the diverted clients, based on the gross commissions or fees generated by those clients during the 12 months preceding the breach. HUB alleges that Sorensen’s approximately 188 client accounts generated roughly $1.6 million in annual revenue, and that the liquidated damages provision is triggered by his alleged violations of Sections 5(b)(1), 5(b)(2), and 5(b)(3) of the Agreement.
Counts II and III: Tortious Interference with Contractual Relations Against Alliant and Misappropriation of Trade Secrets Against Sorensen and Alliant
The complaint asserts two causes of action against Alliant Insurance Services, Inc.: Count II for Tortious Interference with Contractual or Business Relationships and Count III for Misappropriation of Trade Secrets under the Uniform Trade Secrets Act. HUB alleges that Alliant tortiously interfered with the Confidentiality and Non-Solicitation Agreement between HUB and Justin Sorensen by knowingly hiring Sorensen. According to the filing, Alliant was aware of the Agreement’s restrictive covenants, which prohibited Sorensen from soliciting or servicing HUB clients for two years post-employment, as evidenced by the defendants’ joint legal response to HUB’s June 30, 2026 cease-and-desist letter.
HUB contends that Alliant’s interference was intentional and unjustifiable, alleging that the company “intentionally and unjustifiably interfered with the Agreement” by accepting the diverted business (Compl. ¶73). The complaint cites multiple instances where HUB clients—including Flora & Fauna, Clearview AI, and SFR3—submitted broker of record (BOR) letters transferring their accounts from HUB to Alliant within days of Sorensen’s resignation. For example, Flora & Fauna submitted a BOR letter on July 1, 2026, transferring its $100,000 annual premium CLIP policy to Alliant, while SFR3, Sorensen’s largest client at HUB with $573,000 in annual revenue, notified HUB of its transfer to Alliant on August 4, 2026.
The complaint further alleges that Alliant has a “pattern of recruiting employees bound by restrictive covenants,” which HUB contends demonstrates the company’s awareness of and disregard for such agreements (Compl. ¶59). The filing asserts that Alliant’s conduct involved active encouragement of Sorensen’s solicitation efforts, as evidenced by the company’s acceptance of diverted business and its joint legal response to HUB’s cease-and-desist letter.
The complaint also alleges that Sorensen and Alliant misappropriated HUB’s trade secrets under the Uniform Trade Secrets Act. HUB claims that Sorensen used confidential client information—including contact details, policy terms, premiums, and claims history—to solicit HUB’s clients on behalf of Alliant. The complaint alleges that this information constituted trade secrets, as it derived independent economic value from not being generally known to competitors and was subject to reasonable efforts by HUB to maintain its secrecy. The filing asserts that Alliant knowingly benefited from Sorensen’s misappropriation by accepting the diverted business, thereby violating the Act. HUB seeks injunctive relief to prevent further misappropriation, as well as damages for the alleged breach.
Relief Sought and Procedural Posture: Injunctions, Damages, and Attorneys’ Fees
HUB International Midwest Limited seeks preliminary and permanent injunctive relief to enforce the restrictive covenants in its Confidentiality and Non-Solicitation Agreement with Justin Sorensen. The complaint requests an order prohibiting Sorensen from soliciting, servicing, or interfering with HUB’s clients on behalf of any "Competitive Business" for two years following his June 26, 2026 resignation. HUB also demands an injunction barring Alliant Insurance Services, Inc. from aiding Sorensen’s alleged breach or accepting business from HUB clients obtained through his solicitation. The filing cites the Agreement’s provision that HUB “will be entitled... to obtain injunctive or other equitable relief... to prevent any actual or threatened breach” (Compl. ¶20).
For damages, HUB demands liquidated damages equal to two times the "Lost Revenues" from diverted clients, defined as the gross commissions or fees generated by those clients during the 12-month period preceding Sorensen’s departure. The complaint alleges Sorensen serviced approximately 188 client accounts generating $1.6 million in annual revenue for HUB, and that the liquidated damages provision is triggered by his alleged violations of the Agreement. HUB also seeks compensatory damages against Alliant for tortious interference with contractual relations, including the loss of client relationships, revenues, market share, profits, and goodwill, as well as damages for misappropriation of trade secrets under the Uniform Trade Secrets Act.
The complaint further requests prejudgment and post-judgment interest at the lawful rate, as well as attorneys’ fees and costs under the terms of the Agreement. HUB’s verification was executed by Anthony Palumbo on August 10, 2026, and the complaint was filed on August 11, 2026. The suit invokes federal jurisdiction under 28 U.S.C. § 1332, with the amount in controversy exceeding the $75,000 minimum required for diversity jurisdiction.
The allegations described here are taken from the filing and remain unproven; no responsive pleading is reflected in the source document.
The allegations described here are taken from the filing and remain unproven; no responsive pleading is reflected in the source document.
David Brunk is a civil litigation attorney. He can be reached at david@newmanbrunk.com.
From the Complaint Public Court Record
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION HUB INTERNATIONAL MIDWEST LIMITED, Plaintiff, v. JUSTIN SORENSEN and ALLIANT INSURANCE SERVICES, INC., Defendants. _________________________________ VERIFIED COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES Plaintiff HUB International Midwest Limited (“HUB”) files this Verified Complaint for Injunctive Relief and Damages against Defendants Justin Sorensen (“Sorensen”) and Alliant Insurance Services, Inc. (“Alliant”) (collectively, “Defendants”), and alleges as follows: INTRODUCTION This action involves a former HUB employee who breached valid and enforceable restrictive covenants he entered into with HUB, and the competitor that knowingly aided and abetted those breaches. On June 26, 2026, Sorensen resigned from HUB without notice and immediately joined Alliant, a direct competitor. Despite having signed a Confidentiality and Non-Solicitation Agreement (“Agreement”) containing restrictive covenants that prohibit him from soliciting, servicing, or interfering with HUB Clients on behalf of a competitor for two years post- PageID 1
employment, Sorensen and Alliant have engaged in a brazen campaign to divert HUB’s Clients to Alliant. On his last day at HUB, Sorensen disparaged HUB on a client call and informed the client that he was leaving for Alliant, where his team has “everything in place” the client would need to be served there. In the weeks that followed, multiple HUB clients serviced by Sorensen during his employment submitted broker of record (“BOR”) letters transferring their business from HUB to Alliant, including Flora & Fauna Flowershop, Inc. (“Flora & Fauna”), Clearview AI, Inc. (“Clearview AI”), and SFR3, LLC (“SFR3”). The timing and pattern of these BOR transfers, which occurred in rapid succession shortly after Sorensen’s sudden departure to Alliant, make clear Sorensen has been actively soliciting, servicing, and interfering with HUB’s
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