Rick Watts, Esq., PMP, PSEM

Rick Watts, Esq., PMP, PSEM

Quandary Peak Research
Tampa, FL 33647
Mobile: 202-609-9501
Office: 888-959-9639
Introduction

Rick Watts is a seasoned professional with over 30 years of experience, holding certifications as an Enterprise Architect, Project Management Professional, and Software Engineering Master. Rick’s technology background, ranging from small strategic consulting assignments to massive enterprise implementations, allows him to give clients incisive advice for litigation.

Currently, Rick serves as Enterprise Architecture and IT Expert at Quandary Peak Research, where he provides critical analysis in legal contexts. He provides deposition/trial testimony, reports, and declarations in the fields of IT and software project failure, breach of contract disputes, system architecture, databases and data structures.

Clients use Rick’s deep knowledge and practical experience of enterprise software design and implementations, large commercial software projects and his history of achieving organizational goals to quickly understand their cases. By analyzing the specifics of a software implementation failure, Rick effectively explains the strengths and vulnerabilities of a client’s technical arguments.

In addition to his core competencies, Rick brings expertise in litigation consulting and expert witness testimony. He has been involved in multiple litigation cases, providing valuable insights into areas such as enterprise architecture, software implementations, technical architecture design, project management, and system integrator delivery.


Areas of Expertise
  • Artificial Intelligence
  • Computers
  • Cybercrime
  • Cybersecurity
  • Electronic Discovery
  • Information Technology
  • Intellectual Property
  • Networking
  • Software
  • Software Engineering
  • Technology
  • Trade Secrets

Expert Background
Q: Please list your professional accreditations, degrees, licenses, and certificates granted:
A: Certified Healthcare CIO (CHCIO-CHIME)
Certified Data Privacy Solutions Engineer (CDPSE-ISACA)
Professional Cloud Architect (Google)
Project Management Professional (PMP-PMI)
Professional Software Engineering Master (PSEM-IEEE)
Certified Enterprise Architect (EACOE)
Business Continuity Architect (RSA Archer)
Florida State Licensed Private Investigator (C 2900564)

JD, Juris Doctor of Law
Wake Forest University School of Law

BA, Public Administration, w/ minor MIS
Louisiana State University
Q: Please list your affiliations or memberships in any professional and/or industry organizations:
A: College of Healthcare Management Executives (CHIME)
Project Management Institute (PMI)
Enterprise Architecture Center of Excellence (EACOE)
American Society of Industrial Security (ASIS)
Institute of Electrical and Electronics Engineers (IEEE)
Information Systems Audit and Control Association (ISACA)
Maryland State Bar Association
Q: Have any of your accreditations ever been investigated, suspended or removed? (if yes, explain)
A: No
Q: On how many occasions have you been retained as an expert?
A: Retained as an expert for Dispute Resolution, Arbitration (JAMS), and Litigation on at least 30 cases

Dr. Edwin A. Hernandez and ELGA Corp. v. Stingray Group Inc., Mood Media, et al. | May 2025–Present
− Jurisdiction: US District Court, Southern District of Florida
− Case Number: 1:24-cv-21226
− Counsel: Sterne, Kessler, Goldstein & Fox PLLC
− Nature of Suit: Trade Secrets
− Technology: Digital music streaming and content distribution.

I.A.T.S.E. National Health & Welfare Fund v.
− Avenu Insights & Analytics LLC, and CPAS Systems Inc. | Mar 2025–Present
− Jurisdiction: Supreme Court of NY, New York County
− Case Number: 650787/2024
− Counsel: DLA Piper LLP
− Nature of Suit: Breach-of-Contract
− Technology: Pension Fund System

Valtrus Innovations and Key Patent Innovations v. SAP America, Inc. and SAP, SE. | Feb 2025–Present
− Jurisdiction: US District Court for the Eastern District of Texas
− Case Number: 2:24-cv-00021
− Counsel: Reichman Jorgensen Lehman & Feldberg LLP
− Nature of Suit: Patent
− Technology: ERP Software, Database

King & Spalding LLP, Confidential Consulting | Oct 2024–Present
− Nature of Consultation: Class Action Litigation
− Technology: Consumer Reporting, Software Management

Pioneer Hotel Group, Inc, and Pinal Doshi v. Choice Hotels International, Inc | Sept 2024–Present
− Jurisdiction: Fourth Judicial District of ID, Ada County
− Case Number: CV01-23-04099
− Counsel: Mooney Wieland Warren PLLC
− Nature of Suit: Breach-of-Contract
− Technology: Authenticating Digital Signatures, GeoLocation

Confidential Customer v. Confidential Vendor | Sept 2024–Present
− Jurisdiction: American Arbitration Association
− Counsel: Wilson Elser Moskowitz Edelman & Dicker LLP
− Nature of Matter: Software Implementation Dispute, Breach of Contract
− Technology: ERP Software, Entitlement Management, B2C Portals

− Ivan Laguna and Margarita Lopez v. Lazer Safe, Pty, Ltd., Fiessler Electronik Gmbh & CO., Ermak USA, Inc | Sept 2024–Present
− Jurisdiction: US District Court for the District of Massachusetts
− Case Number: 3:23-cv-30016
− Counsel: Sullivan & Sullivan, LLP
− Nature of Suit: Personal Injury, Specific Jurisdiction
− Technology: IP GeoLocation

ECRS Software Corporation Technical Audit & Assessment | Sept 2024–Feb 2025
− Counsel: Wilson Elser Moskowitz Edelman & Dicker LLP
− Nature of Consultation: Software Change Failure
− Technology: E-Commerce, Synchronization, Software Reliability

iPro, Inc v. Flagler Hospital, Inc | Aug 2024–Oct 2024
− Jurisdiction: Seventh Judicial Circuit of FL, St. Johns County
− Case Number: CA22-1559
− Counsel: The Minor Firm
− Nature of Suit: Software Dispute, Breach-of-Contract
− Technology: Medical Order Entry System

Covid Testing Today, NRJY Inc v.
− Flow Health Laboratories, LLC, and Signal Diagnostics, LLC | July 2024–Present
− Jurisdiction: JAMS Arbitration
− Case Number: 5210000247
− Counsel: Hochfelsen & Kani
− Nature of Suit: Arbitration, Breach-of-Contract
− Technology: Medical Information Integration

FTC in re H&R Block | July 2024–Oct 2024
− Jurisdiction: Federal Trade Commission
− Case Number: Docket 9427
− Nature of Matter: Consumer Protection Online Application
− Technology: Complex Web Services, Software Design

Confidential Customer v. Confidential Vendor | Jul 2024–Sep 2024
− Jurisdiction: Judicial Arbitration and Mediation Services (JAMS)
− Counsel: Stinson LLP
− Nature of Suite: Software Implementation Dispute, Breach of Contract
− Technology: ERP Software

Richard Chance v. Totem Technologies, Inc | June 2024–Nov 2024
− Jurisdiction: State of OK, District Court of Tulsa County
− Case Number: CJ-2023-02533
− Counsel: Actuate Law, LLC
− Nature of Suit: Trade Secret
− Technology: Digital Cloud Code Repositories

Vimo Inc d/b/a GetInsured v. Deloitte Consulting LLP | May 2024–Mar 2025
− Jurisdiction: Superior Court of CA, County of Santa Clara
− Case Number: G-24-7-NA, 22-cv-405262
− Counsel: Kirkland & Ellis LLP
− Nature of Suit: Trade Secret, Breach of Contract
− Technology: Software Development, Health Insurance Exchange

Iconic Hearts Holdings, Inc v. Raj Vir; NGL Labs LLC; Joao Figueiredo; Hunter Isaacson; et al. | Apr 2024–May 2024
− Jurisdiction: Superior Court CA, County Of Los Angeles
− Case Number: 22STCV21509
− Counsel: Bryan Cave Leighton Paisner, LLP
− Nature of Suit: Trade Secret, Breach-of-Contract
− Technology: Online Games

Hidden Empire Holdings, LLC v. Darrick Angelone | Feb 2024–Present
− Jurisdiction: US District Court, Central District of California
− Case Number: 2:22-cv-06515
− Counsel: Kramer DeBoer & Keane
− Nature of Suit: Injunction Violation, Breach of Contract
− Technology: Cloud Applications

Oriental Trading Company LLC v. Denovo Ventures LLC | Jan 2024–Jan 2025
− Jurisdiction: District Court of Douglas County, Nebraska
− Case Number: CI 2206047
− Counsel: Gordon Rees Scully Mansukhani, LLP
− Nature of Suit: Copyright, Software Implementation Dispute, Breach of Contract
− Technology: ERP Software

City of Goodyear v. Berry Dunn | 2016
- In an arbitration regarding alleged failure of a for-hire project management firm to properly manage requirements, system integrator (SI)
- vendor selection and project delivery of a city-wide SAP ERP project. Conducted analysis of requirements documentation, SI vendor
- RFP and selection as well as project management artifacts to establish opinions that the defendant had failed to follow industry
- standards for requirements gathering, lacked expertise to select a vendor and manage an SAP project, did not use industry standards for
- project management. Case settled.

Kemper Corporate Services, Inc v. Computer Sciences Corporation | 2016
- In an arbitration regarding the failed implementation of a property and casualty insurance system that was allegedly never made
- “generally available,” conducted a code quality analysis of source code translated from COBOL to Java using industry standard code
- analysis software and rules databases. Compared performance testing data from single user testing, volume testing, stress testing, and
- batch testing to legacy system benchmarks and established test plans. Examined release documentation for evidence of independent
- quality control testing. Case settled.

Orange County, CA v. Tata Consulting Services | 2016
- In this breach of contract and fraudulent misrepresentation case in connection with the implementation of a new property tax
- management system. Examined process documents, architectural documents, testing documents, source code, defect reports, and IBM
- Rational and Microsoft Team Foundation Server systems. Reached opinions that Tata failed to develop PTMS using an “n-tier”
- architecture in accordance with its RFP response and design documents, deviated from its established software development processes,
- and misrepresented the extent to which unit and system testing had been completed during the project. Drafted expert and rebuttal
- reports. Assisted with identification of exhibits for trial. Consulting expert. Case settled.

City of Goodyear v. Quintel Management Consulting | 2015
- In a breach of contract case involving the implementation of an SAP ERP system for city-wide services management. Conducted
- analysis of RFP responses, project artifacts and software final delivery to determine if defendant’s representations regarding software
- being fit for purpose and would meet requirements with out of the box functionality were accurate and whether software as delivered was
- standard or customized leaving major cost and supportability issues. Reviewed project artifacts and testing results to determine if
- software as delivered satisfied contractual requirements. Case settled.

3M v. State of Connecticut | 2015
- In an arbitration in which plaintiff was seeking payment for delivery of a state-wide integrated vehicle management system, the defendant
- contended that the software requirements had not been met. Conducted analysis of Microsoft’s independent audit and application
- assessment in order to refute the results generated by the Microsoft Code Analysis Tool .NET (CAT.NET) which indicated certain security
- and code complexity requirements had not been met. Verbal report. Case settled.

CGI v. eHealth Ontario | 2015
- In this breach of contract case alleging wrongful termination for default of a contract to deliver a Chronic Disease Management System
- Diabetes Registry (CDMS-DR). Conducted analysis of documents and defect resolution tracking data to validate plaintiff’s claims of
- delivery completion and establish that defendant impeded plaintiff’s ability to deliver the project on schedule. Rebutted defendant’s
- experts’ claims that plaintiff failed to meet the contractual specifications and violated project management and software engineering
- standards causing delay and justifying defendant’s termination of the contract. Parties agreed to a special arbitration wherein the plaintiff - was awarded nearly $27 million CAD.

ACADEMY, LTD d/b/a ACADEMY SPORTS + OUTDOORS v. Wipro Limited and Wipro Inc | 2015
- In a breach of contract case involving the implementation of an Oracle Retail Merchandising System for a sporting goods retailer.
- Examined project management materials and process, architecture, and technical requirements as well as vendor roles in project
- delivery and key contractual deliverables. Reached opinions that the vendor failed to properly manage the project, deliver key
- personnel, and comply with contractual requirements for project delivery. Case settled.

3M v. Commonwealth of Kentucky | 2014
- In an arbitration in which plaintiff was seeking payment for delivery of a state-wide integrated vehicle management system, the defendant
- contended that the software requirements had not been met. Conducted analysis of Microsoft’s independent audit and application
- assessment in order to refute the results generated by the Microsoft Code Analysis Tool .NET (CAT.NET) which indicated certain security
- and code complexity requirements had not been met. Case settled.

CedarCrestone, Inc v. Affiliated Computer Services, LLC n/k/a Xerox Business Services | 2013
- A software failure matter brought by a consulting and systems integration vendor against a Business Process Outsourcing (BPO)
- provider. Rebutted plaintiff’s expert’s opinions that project management failures and schedule delay allegedly caused by defendant
- impeded plaintiff’s ability to attain critical project milestones. Proffered additional opinions that plaintiff’s violations of project management
- and software engineering industry standards resulted in software defects that should have surfaced in plaintiff’s developer testing, and
- which ultimately caused the failure of the overall BPO program. The plaintiff was subcontracted to provide a PeopleSoft upgrade forming
- the foundational system for the BPO. Established that the plaintiff’s failure to successfully deliver the upgrade by the scheduled go-live
- date precluded the defendant's ability to go-live with the BPO, resulting in multi-million-dollar penalties and other consequential damages
- to the defendant. Case settled.

Brookings v. CedarCrestone, Inc | 2010
- In an IT project implementation failure case alleging the system integrator failed in deploying a PeopleSoft ERM grants system. Provided
- root cause analysis for project failure, focusing on the ISV role of the vendor in managing a project to delivery as well as actions by the
- plaintiff that contributed to the project failure. Opinions were core to the settlement of the suit. Case settled.
Q: For what area(s) of expertise have you been retained as an expert?
A: Breach of contract in software implementation failure
Breach of contract in IT project delivery delay
Fraud, malfeasance, software and managed services contracts
Trade Secret and intellectual property misappropriation
Software functionality failure
Software design failure
Q: In what percentage of your cases were you retained by the plaintiff?
A: Approximately 50%
Q: In what percentage of your cases were you retained by the defendant?
A: Approximately 50%
Q: On how many occasions have you had your deposition taken?
A: Given expert testimony in a deposition for at least five engagements
Q: When was the last time you had your deposition taken?
A: February 2025
Q: On how many occasions have you been qualified by a court to give expert testimony?
A: At lease four engagements
Q: On how many occasions have you testified as an expert in court or before an arbitrator?
A: At least two engagements
Q: For how many years have you worked with the legal industry as an expert?
A: Since 2008, 17 years
Q: What services do you offer? (E.g.: consulting, testing, reports, site inspections etc.)
A: Dispute and arbitration consulting, expert reports, system design review, feature and functionality cross-referenced to contract terms
Q: What is your hourly rate to consult with an attorney?
A: $550
Q: What is your hourly rate to review documents?
A: $550
Q: What is your hourly rate to provide deposition testimony?
A: $550
Q: What is your hourly rate to provide testimony at trial?
A: $550
Q: Please list any fees other than those stated above (E.g.: travel expenses, copy fees, etc.)
A: All travel expenses are invoiced at actual, any document capture fees i.e., PACER docs

References

Available Upon Request