Luck claims her stake in the incentive award programme entitles her to a pay-out in the event of a sale of the company – though it is not clear how much. The cash value of Ipsos’s acquisition of OTX is $71m.

In her complaint, Luck also says she is owned $82,250 of the $246,750 OTX agreed to pay under the terms of her settlement agreement with the company following her “termination without cause” on 16 December 2005.

OTX has yet to respond to the complaint, which was filed with the courts in California on 8 March.

Luck worked for OTX for more than five years, from June 2000, and was latterly executive vice president of operations and corporate strategy.

After leaving the firm she set up Forefront Consulting Group, a research services advisory firm. That business was later acquired by survey programming and reporting specialist Decipher, where Luck currently works as president.

UPDATE 6/04/10: Story has been changed to give the correct cash value of Ipsos’s acquisition of OTX, which is $71m according to Ipsos’s annual report. Court documents filed on behalf of Luck estimate the value of the deal to be in the region of $120m.