On July 9, 2009, Citadel Investment Group (Citadel) filed a lawsuit in the Circuit Court of Cook County, Illinois against three of its former employees – Mikhail Malyshev, Jace Kohlmeier and Matthew Hinerfeld – and Teza Technologies LLC, a corporation founded by those three former employees.  Citadel’s complaint alleges that the individual defendants violated non-disclosure, non-solicitation and non-complete covenants in their employment agreements with Citadel, as well as the Illinois Trade Secrets Act, by misappropriating trade secrets and other confidential data relating to Citadel’s high frequency trading technology.  We describe the factual and legal allegations in the complaint.