Gibson, Dunn & Crutcher LLP

881 Faqe i\rirll

i?oaci

Pa c Aitc. CA 94304

Tel 1.50

12ll

B,l! :300

w'r'iw.E b,tonCL | ;r.corn

March 23, 2075

VIA

FEDERAL EXPRESS

Thomas Dunham

.
San Francisco, CA 941,03

(41s) 852-]-740

Re:

Request for Return of SelectQuote propert.y and

Confidential Third Party Information

Dear

Dunham:

We are

counsel to SelectQuote insurance Servj-ces ("the

company"). It has come to our understanding that you were
formerly employed by the company, and that in this capacity,
you had access to (1) confidential and proprietary information
belonging to Lhe Company and (2) confidential_ information
belonging to third parties. This information incl_uded, but. was
not. limited to, customer lists, contract terms, methods of
operations, market.ing plans, software code, functionality,
know how, financial information, ds well as personally
ident,ifiable informat.ion for customers of the Company,
including customer names, phone numbers, email ad.d.resses,
physical addresses, and other protected personal informat.ion.
under the terms of t,he company's employee Handbook, whj_ch you
agreed to abide by,

Not Applicable not employee

I' Furt.her, under t.he terms of the Company, s

Technol-ogy use and privacy policy for "authorized employees
(including temporary staff and independent contractors), "
which you signed as a condj-t.ion of your employment with the
company, lou agreed to strj-ct restrictions on your use of any
of the company's "Technol-ogy Resources" (including, but not,
limited to, "all- elect.ronic devj_ces, software, ... computer
hardware such as disk drives and tape drj-ves, ... associated

Thomas Dunham
March 23, 20L5

Page

f il-es and daLa" ) . Specif icaIIy,

Company's Technology Resources

you agreed that " [t] he

are to be used by employees

only f or the purpose of conduct.ing Company business. 'r You

further agreed that you would rrnoL use any of the Company's
Technol-ogy Resources for any il1egaI purpose, for violation of
any Company policy, in a manner contrary to the best j-nterests
of the Company, in any way t.hat discl-oses confidential or
proprietary information of the Company or third parties, oy
for personal gain. "
It is also our understanding that pursuant to your employment
with the Company, you had in your possessi-on a data drive
containing customer information ("the Drive"). While our
records indicate you were an employee at the time you received
t.he Drive, even if you were not an employee, you were stil-l- a
consultant, and so were still bound by the Company's
Technology Use and Privacy Policy (which explicit.ly applies
equally to "temporary staff and independent contractors")
(emphasis Added) Incorrect

been informed t.hat. federal agents with the United

States Secret Service, in connection with a potential criminal
investigation, demanded that you turn over the Drive, and you
complied. We further understand that you represented t.o 1aw
enforcement that you possess no additional copies of the dat.a
that had been on the Drive.

We have

To the extent you do have copies of t.he data from the Drive or to the extent that you sti1I possess any documenLs,
records, informat.ion, software or other property of the
Company, whether in physical or electronic form - we hereby
demand that you return saj-d items immediately t.o t.he Company.
If you do not have any such items in your possession, please
provide us with writ.t.en confirmation of this fact. Please be
advised that the Company considers refusal to return company
property to be theft, and any unauthorized discl-osure or use
of the Company's properLy and/or confidential information

could lead to litigat.ion against you.

Further, any disclosure'or use of the confidential information

of third parties you may have retained from the course of your