News & Analysis as of

Dismissals Misappropriation

McDermott Will & Emery

Tell Us Your Secret: Case Dismissed for Failure to Identify Trade Secrets

The US Court of Appeals for the Tenth Circuit affirmed a district court’s grant of summary judgment in favor of the defendants for the plaintiff’s failure to identify the trade secrets at issue with sufficient particularity....more

McDermott Will & Emery

Not Secret and Not Used: Misappropriation Claim Dismissed

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The US Court of Appeals for the Fifth Circuit upheld a district court’s grant of summary judgment in favor of the defendants, finding that the plaintiff failed to identify a trade secret and presented no evidence of its use...more

McDermott Will & Emery

One Bite at the Apple Where State and Federal Jurisdiction Is Concurrent

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The US Court of Appeals for the Second Circuit upheld a federal district court’s dismissal of a case on res judicata grounds after a state court issued a decision on different claims but had concurrent jurisdiction over the...more

Proskauer - Trade Secrets

Trade Secret Complaint Fails Basic Requirements

On May 23, 2024, the U.S. District Court for the Western District of Pennsylvania dismissed a trade secret misappropriation claim for failure to identify a trade secret. The case is titled Vertical Bridge REIT, LLC v. Everest...more

McDermott Will & Emery

Unfair Play: Unjust Enrichment for Copying and Using Non-Trade-Secret Spreadsheet

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The US Court of Appeals for the Second Circuit reversed a district court’s dismissal of an unjust enrichment claim, finding that unjust enrichment claims do not necessarily rise or fall with trade secret misappropriation...more

King & Spalding

Middle District of Tennessee Dismisses Claims Against Lender for Refusal to Consent to Borrower’s Sale

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On May 9, 2022, the U.S. District Court for the Middle District of Tennessee dismissed a would-be purchaser’s claims against the would-be seller’s lender arising from the lender’s refusal to consent to the sale. Ruby Tuesday,...more

Goodwin

AbbVie Allegations of Trade Secret Misappropriation by Alvotech hf.

Goodwin on

Earlier this year, AbbVie Inc. and AbbVie Biotechnology Ltd. filed a Complaint against Alvotech hf. in the US District Court for the Northern District of Illinois alleging theft of trade secrets relating to adalimumab. In...more

Saiber LLC

Third Circuit Clarifies Requirements for Pleading a Trade Secret Misappropriation Claim under the Federal Defend Trade Secrets Act

Saiber LLC on

In a recent published, precedential opinion, Oakwood Laboratories LLC v. Thanoo, 999 F.3d 892 (3d Cir. 2021), the Third Circuit clarified the pleading standard necessary to allege a trade secret misappropriation claim under...more

ArentFox Schiff

Robinhood Checked but Not Wrecked: False Association Suit by Rapper Ice Cube Dismissed

ArentFox Schiff on

Rapper and actor Ice Cube sued the online trading platform Robinhood alleging false association, misappropriation of publicity rights, and unfair competition based on Robinhood’s use of Ice Cube’s image and a paraphrased...more

Lewitt Hackman

Franchisee 101: Trashing the Competition

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In a misappropriation of trade secrets action, a franchisor sued a prospective franchisee, claiming breach of a non-disclosure agreement ("NDA") by operating a competing business. The prospective franchisee signed the NDA...more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Affirms Attorney’s Fee Award of $2.3 million in Misappropriation Case Against Former Employee who Failed to Comply...

On September 2, 2020, the Fifth Circuit declined to void a fee award of nearly $2.3 million in favor of an employer that had prevailed on its trade secret theft claim against its former employee, because the employee...more

Mintz - Trademark & Copyright Viewpoints

Second Circuit Declines to Decide if Human Skin Can Be a Tangible Medium of Expression under Copyright Law and Affirms Dismissal...

In a recent decision from the Second Circuit, Judges Parker, Chin, and Carney side-stepped a novel question: whether human skin can be the kind of "tangible medium of expression" required for copyright protection. Instead,...more

White & Case LLP

UK Supreme Court upholds first successful claim for breach of the "Quincecare" duty financial institutions owe their customers

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In Singularis Holdings Ltd (In Official Liquidation) v Daiwa Capital Markets Europe Ltd ([2019] UKSC 50), the Supreme Court upheld the first successful claim in negligence by a customer of a financial institution for breach...more

Orrick - Trade Secrets Group

Pleading “Sufficient Particularity”: Technical Trade Secrets Require More

It’s common sense that, to protect a trade secret, the information must remain secret. However, when trade secret misappropriation claims arise and litigation ensues, the court and the parties involved need to understand at...more

McDermott Will & Emery

Stick to the Pleading when Deciding Motion to Dismiss

The US Court of Appeals for the Federal Circuit reversed a dismissal of a complaint for failing to state a claim under FRCP 12(b)(6), finding error in the district court’s use of judicial notice to do fact-finding outside the...more

A&O Shearman

Delaware Supreme Court Affirms Dismissal Of Misappropriation Claims Against Private Equity Investor That Invested In A Competitor

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On February 7, 2019, the Delaware Supreme Court issued an order affirming the dismissal of misappropriation claims by Alarm.com Holdings, Inc. against ABS Capital Partners Inc. (and its affiliates), a private equity firm that...more

Fenwick & West LLP

Beating a DTSA Claim Does Not Necessarily Mean Recovery of Attorneys’ Fees

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Absent an agreement to the contrary, the dismissal of a statutory cause of action providing for attorneys’ fees to the prevailing party would seem to entitle a defendant to its reasonable fees and costs. In a matter of first...more

Dorsey & Whitney LLP

Fifth Circuit Denies Defendants’ “Halftime” Attempt to Shift Fees Under the DTSA

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Earlier this month, the Fifth Circuit ruled that under the Defend Trade Secrets Act (18 U.S.C. § 1836, et seq.) (“DTSA”), a defendant is not the “prevailing party” by virtue of a plaintiff voluntarily dismissing a DTSA claim,...more

Holland & Knight LLP

Payment Card Data is Not Trade Secret Information under the DTSA

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In a recent case involving hackers that stole "payment card data" from Chipotle, Judge William J. Martinez in the United States District Court for the District of Colorado found on an issue of first impression that payment...more

Morris James LLP

Court Of Chancery Enforces Agreement To Waive Corporate Opportunity Claims

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Alarm.Com Holdings Inc. v. ABS Capital Partners Inc., C.A. 2017-0583-JTL (June 15, 2018) - Under 8 Del C. Section 122(17) a corporation may waive any claim that a corporate opportunity was wrongfully taken by a fiduciary....more

Parker Poe Adams & Bernstein LLP

North Carolina Supreme Court Requires Specific Pleadings for Trade Secret Claim

Like most states, the North Carolina Trade Secrets Protection Act prohibits individuals or businesses from misappropriating or misusing certain confidential business information belonging to someone else. However, not all...more

Dorsey & Whitney LLP

Grand Theft Auto 5 Has Many Different Characters, But Lindsay Lohan Is Not One of Them

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When you play the video game Grand Theft Auto 5 (“GTA 5”), the last thing you want to see is a reflection of yourself. GTA 5 is an action-adventure game that rewards the player for stealing cars and speeding away from cops....more

Brooks Pierce

NC Business Court: Choice Of Law Dooms Trade Secrets Claim

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What choice of law rule applies to trade secrets claims? No North Carolina appellate court has answered that question, but Judge Robinson of the NC Business Court stepped into that breach in his Opinion in SciGrip v. Osae,...more

Winstead PC

Federal Court Dismisses Breach of Fiduciary Duty Claim Because It Was Preempted By The Texas Uniform Trade Secret Act

Winstead PC on

In Embarcadero Techs., Inc. v. Redgate Software, Inc., four employees left their employer and began working at a new company. No. 1:17-cv-444-RP, 2018 U.S. Dist. LEXIS 1902 (W.D. Tex. January 5, 2018). ...more

Ballard Spahr LLP

California Court of Appeals Affirms Dismissal Under Anti-SLAPP Statute of Defamation Claim Against Online Platform Hosting...

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A recent appellate ruling may have important implications for online publishers who invite, encourage, and even compensate third-party contributors to post information without prior approval or review....more

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