A media consultant claims in a new lawsuit that Endeavor stole his unsolicited ideas on how to pitch itself to Wall Street, and that his concepts are single-handedly responsible for saving the company from ruin.

David Carde, who describes himself as a consultant in the media and technology sectors, alleges that in September 2019 his attorney emailed an 11-page analysis to Endeavor CEO Ari Emanuel and to Ari Greenburg, the president of WME. He apparently never received a response.

At the time, Endeavor was making its first effort to launch an IPO. A week later, though, the IPO was withdrawn amid concerns about market conditions.

Endeavor tried again in April 2021 and was successful. The company currently has a market cap of about $12 billion.

In the suit, Carde alleges that in the marketing materials for the second go-round, the company borrowed from his 11-page analysis. The suit points to a cyclical diagram in Carde’s analysis, labeled “The Content Conversation,” which makes reference to the “network effects” tying talent, assets and new categories and markets.

The suit argues that the diagram is similar to one featured in Endeavor’s IPO Roadshow video, which also featured a circle and clockwise arrows.

The suit also points to Emanuel’s presentation in the video, in which he says: “And lastly, our platform enables endless connections every day that makes the whole of Endeavor even more valuable than the world class parts…to build a company for where the world is headed.”

The suit argues that this language echoes the following language from Carde’s analysis: “there are an infinite number of permutations…Endeavor is very well-positioned to adapt to whatever the future brings in the content sector…the key point remains: Endeavor’s infrastructure and optionality are the drivers of value.”

Carde claims that emailing his analysis to Endeavor’s executives created an implied contract, which the company breached by using his material without paying him.

“Mr. Carde’s work has become embedded into the very fabric of the Company’s ‘structure’ in perpetuity and Endeavor needs to compensate Mr. Carde accordingly,” the suit states. “Quite simply, in the Company’s darkest hour, with seemingly insurmountable challenges, Mr. Carde’s materials enabled Endeavor to ultimately realize its elusive IPO, one which was existential to the firm’s existence as an ongoing enterprise.”

An Endeavor spokesperson said in response, “We believe these claims are without merit and Endeavor intends to defend itself vigorously.”