Sheridan-based Roofconnect Logistics Inc. and SolarConnect, LLC face a federal lawsuit by Hans Stullken.
The lawsuit was filed in the United District Court for the Eastern of Arkansas Central Division on Nov. I5, 2025, by Stullken and through his Little Rock attorneys, Holleman & Associates, P.A.
The 28-page first amended complaint states "Recognizing the lucrative opportunities in solar, RoofConnect Logistics, Inc. got into the solar installation business as a complement to its roofing business. As part of this foray, RoofConnect contracted with Plaintiff Hans Stullken, an expert in the solar individual, to help it develop and secure financing opportunities for solar projects. RoofConnect relied heavily on Stullken’s efforts to met key investors, including Catalyze Holdings, LLC. Stullken developed RoofConnect’s contractual process, and he negotiated a Development Services Agreement between Catalyze Holdings, LLC, and
RoofConnect’s affiliate, SolarConnect, LLC."
Note: The lawsuit was amended because the plaintiff "neglected to
include the exhibits for filing with the original complaint."
The lawsuit states that Stullken’s efforts "were tremendously successful. By early
October, RoofConnect had inked two deals, had 19 more awaiting signature from Catalyze, and had several other projects in development. But rather than paying Stullken as agreed, RoofConnect greedily concocted a scheme to try and cheat Stullken out of his pay. RoofConnect told Stullken that they were not culturally aligned, and it refused to pay him anything at all unless he signed a onerous separation agreement."
Stullken is seeking a declaratory judgment "regarding his rights under the Agreement, an accounting of the amounts due to him, and compensation for unpaid commissions. He also brings claims for breach of contract and
unjust enrichment."
The lawsuit states that "RoofConnect Logistics, Inc. is a domestic, for-profit corporation, incorporated in the State of Arkansas, with a principal place of business at 44 Grant 65, Sheridan, Arkansas 72150. RoofConnect’s registered agent is David Workman, 44 Grant 65, Sheridan, Arkansas 72150.
"RoofConnect has significant expertise in roofing construction, but it did not begin installing solar until 2024. Defendant SolarConnect, LLC, is a limited liability company
formed under the laws of Arkansas, with a principal place of business at 44 Grant 65, Sheridan, Arkansas 72150. Upon information and belief,
SolarConnect is an affiliate of RoofConnect, created in May 2023, to assist with RoofConnect’s solar operations. Upon information and belief, all of SolarConnect’s members are Arkansas citizens and none of SolarConnect’s members are citizens of California. SolarConnect’s registered agent is Jarred Crow, 44 Grant 65, Sheridan, Arkansas 72150."
Who is Hans Stullken?
The lawsuit states that Stullken is a California resident and a solar expert with who has "spent over 18 years working for a variety of companies in a variety
of roles."
Stullken entered the picture when Roofconnect decided to "expand its solar installation business." The company wanted Stullken "to assist it with developing its solar business."
The lawsuit states, "In or around April 2024, Stullken and RoofConnect began discussions about Stullken setting up a full solar program, including operations, sales, and marketing."
However, Stullken told RoofConnect he had another job opportunity.
"Jeff Austin told Stullken that he should stick with RoofConnect and that the Company would make it worth Stullken’s while," according to court documents.
Stullken did stick with the company and entered into a Contractor Agreement with Roofconnect on June 12, 2024.
"Stullken was tasked with identifying and securing financing
opportunities for RoofConnect’s roofing and solar projects, leveraging his relationships and expertise in the field, develop and manage strategic partnerships with investors, structure financing deals, and oversee project execution," the lawsuir states.
It continues, "Stullken was also responsible for working with sales and operations teams, focusing efforts on financing opportunities, structuring deals, tracking progress, and facilitating meetings with customers, financiers, and RoofConnect’s solar management team.
"Stullken, of course, was not volunteering his time. RoofConnect
agreed to pay Stullken 20% of the 'project margin' (i.e., the profits) from each deal that he obtained for RoofConnect," the lawsuit states.
Compensation
Stullken's deal, according to his lawsuit, included:
a. Payment to Contractor is based on 20% of margin (Contractor Margin)
b. Finance of each project may affect the 20% of margin and Contractor Margin will be adjusted to reflect
actual margin.
c. 12.5% of Contractors Margin paid upon Customer and Financier signing Agreement or LOI to accept
project.
d. 12.5% of Contractor Margin paid to Contractor at Notice to Proceed by Utility.
e. 25% of Contractor Margin paid to Contractor upon
commencement of roofing.
f. 25% of Contractor Margin paid to Contractor upon commencement of solar.
g. 25% of Contractor Margin paid to Contractor upon completion of solar and final payment by financier.
h. Any over payment or underpayment will be adjusted at final payment.
i. Any advances made against Contractor Margin which is in excess of this schedule, will be deducted from final payment
Stullken's tasks
The lawsuit lists Stullken's activities for Roofconnect that included "actively structured project
financing, facilitated meetings, and developed financial models that directly benefited RoofConnect."
He also "attended weekly sales meetings, operational meetings, and strategy discussions to ensure project success."
The lawsuit states Stullken did much more including developing "a data room for due diligence purposes and
designing documentation for project structuring."
He also "facilitated meetings between RoofConnect’s officers, employees, and potential financiers to secure agreements.
The lawsuit adds, "RoofConnect even introduced Stullken to others as their Director of Finance, and it provided Stullken with a company email and the title of Director of Finance.
Additionally, "Stullken introduced RoofConnect to multiple investors and financing partners, including Catalyze Holdings, LLC.
The lawsuit states "Stullken successfully secured, negotiated and created the strategic partnership between RoofConnect and Catalyze Holdings, LLC, including a strategic Development Service Agreement (“DSA”) with both immediate returns and potentially millions in revenue from roof and solar development."
For all of that "substantial" work, the lawsuit claims Stullken was not receiving any pay, and in September 2024, Stullken "told Ken Beck and Jeff Austin that he was going to start entertaining contracting and employment opportunities with other companies. Jeff Austin told Stullken to 'hang tight' because money and commissions would
begin flowing within the next month."
A new role
Soon after Austin and Beck asked Stullken to take on an analyst role with RoofConnect that was previously held by Alex Trevino, a W2 employee. Stullken said he would take on the role if he
received the same pay as Trevino, in addition to his previously agreed upon compensation."
However, Stullken was told "he should do the work for free because he would receive compensation once the development agreements
were signed."
Stullken said no to the role.
The lawsuit noted Stullken "was able to negotiate with Catalyze to perform the analysis work on the
projects."
As a result of Stullken’s work, RoofConnect "entered into two
agreements for the financing and installation of roofs and solar panels –- American Stitch Co. and Marissa School District."
American Stitch Co. is based in Baxter County. Marissa School District is Marissa, Illinois.
The lawsuit states Stulken "submitted his initial invoices to Roof Connect for payment pursuant to the terms of the contract on or around October 11, 2024."
Stullken's also had "an additional
19 development commitments that had been fully negotiated and were
simply awaiting final approval for Catalyze Holdings. RoofConnect was
aware that Catalyze was about to approve these projects, and it was required to pay Stullken commission."
But Stullken, the lawsuit claims was
"developing numerous other projects, both with Catalyze and with other financers.
"Roof Connect stands to makes tens of millions of dollars in profit
on these projects due to Stullken’s work.
"Under the terms of the agreement, Stullken himself stood to make over a million dollars in commissions based on these projects."
RoofConnect, however, did not pay Stullken.
"Roof Connect verbally
told Stullken that he and the Company were not 'culturally aligned'," the lawsuit states.
The lawsuit states "RoofConnect did not even give written notice that it was terminating its arrangement with him. Rather, RoofConnect verbally told him that it was terminating the agreement, and it attempted to have Stullken
enter into another agreement to forego the substantial compensation that he is owed."
Damages wanted
Stullken wants several things from RoofConnect.
He is seeking "a declaratory judgment that the Contractor Agreement entered into by Stullken and RoofConnect was a valid and enforceable contract, and that RoofConnect is required to pay."
Stullken claims RoofConnect’s contract has made him suffer
damages, "including unpaid commissions. Stullken seeks compensatory damages in an amount exceeding $75,000.00 and attorney’s fees, costs, and
expenses."
Additionally, the lawsuit states "RoofConnect and SolarConnect have made substantial profits off
Stullken’s work, and they have not paid him a single dime for his labor.
"The reasonable value of the services received by RoofConnect
and SolarConnect requires access to the databases that RoofConnect and
SolarConnect used to track the projects, and the amount can be calculated based on the Compensation provision in the parties’ Agreement.
"Even if the reasonable value of Stullken’s services is calculated
on some other basis, the reasonable value exceeds $75,000.00 exclusive of interest and costs."
Stullken wants "restitution for the value of his services and
compensation for RoofConnect’s unjust enrichment."
Stullken is asking for a jury trial as well as "all recoverable costs, expenses, and attorneys;
fees incurred in prosecuting this action and all claims, together with all applicable interest."
RoofConnect Response
Counsel for Roofconnect Logistics, Inc. and Solarconnect, LLC is James D. Robertson of Barber Munson law firm in Little Rock.
In a 9-page answer filed Nov. 25, 2025, Roofconnect Logistics, Inc. and Solarconnect, LLC deny many of Stullken's allegations.
"These defendants admit that Roofconnect became involved in the solar industry before entering into a contract relationship with the plaintiff. These defendants further
admit that Plaintiff had a role with respect to the development of a contract relationship with
Catalyze Holdings, LLC. The balance of the allegations contained within paragraph 1 are denied."
The defendants also admit that Stullken "had a role in the development of a contract relationship with Catalyze Holdings, LLC."
They "deny that the plaintiff
negotiated the effective contract with Catalyze Holdings, LLC."
Roofconnect Logistics, Inc. and Solarconnect, LLC admit that the "contract with plaintiff was terminated in accordance with its terms via letter dated November 7, 2024."
The defendants "admit that a severance package was offered. However, these defendants deny the
balance of the allegations contained within paragraph 39 of the plaintiff’s First Amended Complaint because those allegations mischaracterized the nature of the offer."
The lawsuit states "If Plaintiff sustained any damages, which allegation is denied, the damages were solely and proximately caused by the fault of Plaintiff or by an intervening proximate cause or by
the actions of individuals or entities for whom these defendants have no responsibility whatsoever.
Accordingly, these defendants affirmatively plead the doctrines of comparative fault, contributory
negligence, and independent intervening proximate cause."
Going further, the answer states the defendants "affirmatively plead that they are entitled to the defense of set-off as a result of the plaintiff’s misconduct and malfeasance which resulted in harm to the defendants.
"These defendants affirmatively plead each and every available defense pursuant to
Fed. R. Civ. P. 12(b), including but not limited to, insufficiency of process, insufficiency of service
of process, failure to state facts upon which relief may be granted, and failure to join a necessary party. These defendants affirmatively plead that the plaintiff has specifically failed to state a cause
of action against either defendant.
"These defendants affirmatively plead that they acted in good faith at all times.
"These defendants affirmatively plead a failure of performance on the part of the plaintiff which prohibits him from recovering the damages claimed in this lawsuit."
Roofconnect Logistics, Inc. and Solarconnect, LLC are asking for attorney fees and costs.
The trial
According to court documents filed in mid-February of this year, Stullken will get a jury trial on March 2, 2027, in Little Rock before Judge Lee P. Rudofsky.
Rudofsky was appointed as United States district jusge of the United States District Court for the Eastern District of Arkansas by President Donald Trump in 2019. He earned his juris doctor from Harvard Law School.
Prior to serving on the bench Rudofsky was Senior Director for Global Anti-Corruption Compliance at Walmart Inc., according to a White House news release from 2019.
Before joining Walmart, Rudofsky was Solicitor General of Arkansas. He represented the State of Arkansas in Federal and State court, including the United States Supreme Court, Arkansas.
Discovery in the Stullken case is due by Oct. 2, 2026 with a status report and motions due Nov. 2, 2026.
Read the Reckoning's previous stories about RoofConnect.
Suzi Parker
Suzi Parker
