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Appeals Trade Secrets Defend Trade Secrets Act (DTSA)

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

Holland & Knight LLP

Dismissal of State Court Claims Bars DTSA Claim in Federal Court

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By statute, judgments of state courts are entitled to the same preclusive effect in subsequent federal litigation as they would have in subsequent state court litigation. 28 U.S.C. § 1738. A recent decision by the U.S. Court...more

McDermott Will & Emery

Message Received: Trade Secret Law Damages Available for Sales Outside US

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The US Court of Appeals for the Seventh Circuit affirmed, in a matter of first impression, a district court’s decision to apply trade secret law extraterritorially and award trade secret damages for foreign sales while also...more

McDermott Will & Emery

E for Effort? PI Analysis in Trade Secret Suit Riddled With Errors

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The US Court of Appeals for the Federal Circuit reversed the granting of a sweeping preliminary injunction (PI) in a trade secret suit against a competitor, finding that the district court’s analysis failed to consider...more

Seward & Kissel LLP

Employment Litigation Roundup: November 2023

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Ex-employee’s golf outing with customer does not violate non-solicit - An auto parts manufacturer in Michigan sought a preliminary injunction against a former sales employee for violating his restrictive covenants,...more

McDermott Will & Emery

Sorry—No Finality, No Injunction, No Appellate Jurisdiction

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The US Court of Appeals for the Third Circuit dismissed an appeal from the denial of a motion under the Defend Trade Secrets Act (DTSA) for an ex parte seizure order, explaining that such orders are not final, not effectively...more

McDermott Will & Emery

In Good Hands: Compilation of Publicly Available Information Can Still Be a Trade Secret

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The US Court of Appeals for the First Circuit affirmed a district court decision, finding that a compilation of customer-related information, even if publicly available, is a protectable trade secret. Allstate Insurance Co....more

McDermott Will & Emery

No Lost Value Damages Despite Trade Secret Misappropriation

The US Court of Appeals for the Second Circuit vacated a damages award, finding that although there was liability for appropriating trade secrets, the trade secret proprietor was only entitled to compensatory damages under...more

Proskauer - Law and the Workplace

Lessons Learned From 2022’s Trade Secret Verdicts

Before closing the book on 2022, we look back at the most significant verdicts issued in trade secret trials this past year. In 2022, several juries awarded extraordinary verdicts to plaintiffs. These verdicts suggest a...more

Holland & Knight LLP

Third Circuit Illuminates Several Issues in Trade Secret Litigation

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Two recent decisions by the U.S. Court of Appeals for the Third Circuit shed light on several recurrent issues that arise in trade secret litigation under the federal Defend Trade Secrets Act (DTSA) and related state acts....more

Sheppard Mullin Richter & Hampton LLP

Federal Circuit Deems Algorithm Potentially Valid Trade Secret Notwithstanding Prior Publication

On January 24, 2022, the Federal Circuit affirmed the grant of a preliminary injunction blocking the publication of a patent application on the basis that it contained the plaintiff, Masimo Corp.’s trade secrets. Masimo Corp....more

McDermott Will & Emery

Sixth Circuit Endorses Sealing of Filings to Protect Confidentiality of Alleged Trade Secrets

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On appeal from a dismissal based on a failure to state a claim for misappropriation of trade secrets, the US Court of Appeals for the Sixth Circuit granted the litigants’ motion to seal their briefs and file publicly...more

McDermott Will & Emery

The Plot Plot Thickens: Trade Secret, Tortious Interference, Fiduciary Duty Claims Survive Motion to Dismiss

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A judge from the US Court of Appeals for the Third Circuit sitting by designation in the US District Court for the District of Delaware denied a motion to dismiss claims of misappropriation of trade secrets, tortious...more

Sheppard Mullin Richter & Hampton LLP

A Cautionary Tale on Including an Expiration Date in NDAs

A recent decision by the Ninth Circuit Court of Appeals in BladeRoom Group Limited v. Emerson Electric Co. further stresses the importance of carefully crafting the terms and conditions in a non-disclosure agreement (“NDA”),...more

Holland & Knight LLP

Sixth Circuit Offers Guidance to Distinguish Single Continuing Misappropriation Claim from Multiple Claims

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In B&P Littleford, LLC v. Prescott Mach., LLC, No. 20-1449, 2021 WL 3732313 (6th Cir. Aug. 24, 2021) (unpublished), the U.S. Court of Appeals for the Sixth Circuit recently provided guidance as to factors courts should...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

McDermott Will & Emery

What Does it Take to Plead Trade Secret Misappropriation Under the DTSA?

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Addressing the pleading standard under the Defend Trade Secrets Act (DTSA) and New Jersey Trade Secrets Act (NJTSA), the US Court of Appeals for the Third Circuit vacated the district court’s dismissal of a third amended...more

Fenwick & West LLP

Intellectual Property Bulletin - Winter 2021

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Written Description of Therapeutic Efficacy - In two 2019 rulings, the Federal Circuit invoked the “written description requirement” of 35 U.S.C. § 112 to require evidentiary support for therapeutic efficacy. Now that the...more

McDermott Will & Emery

How Not to Build a Case of Trade Secret Misappropriation

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The US Court of Appeals for the Ninth Circuit affirmed a dismissal of trade secret claims, finding that although misappropriation of a trade secret prior to the enactment of the Defend Trade Secrets Act (DTSA) does not...more

McDermott Will & Emery

Defend Trade Secrets Act Supports Sealing Information on Appeal

Addressing whether purported trade secret information ought to remain under seal on appeal, the US Court of Appeals for the Sixth Circuit ruled in a one-judge order that the Defend Trade Secrets Act (DTSA) provided a...more

WilmerHale

Federal Trade Secret Law Incorporates California's Particularity Requirement

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On October 15, 2020, the U.S. Court of Appeals for the Ninth Circuit held in InteliClear LLC v. ETC Global Holdings, Inc., that the federal Defend Trade Secrets Act (“DTSA”) requires trade secret plaintiffs to identify a...more

Sunstein LLP

Scraping Too Much Website Data May Be Trade Secret Misappropriation

Sunstein LLP on

Data scraping is a technique in which automated tools-- robots or “bots”--are used to extract large quantities of data from a website. In some cases, the extracted data has been developed by the website owner with...more

ArentFox Schiff

Seventh Circuit Affirms the Availability of Head Start Damages in Trade Secrets Cases

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On August 20, 2020, the US Court of Appeals for the Seventh Circuit affirmed a $140 million jury verdict in a published opinion reiterating the important role of unjust enrichment damages in compensating victims of trade...more

Holland & Knight LLP

Trade Secret Claims Tanked Based Upon Delay

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Recently, the Eighth Circuit Court of Appeals considered the three-year statute of limitations provisions of the Defend Trade Secret Act (DTSA) and Iowa Trade Secrets Act (UTSA). In the underlying district court action, CMI...more

Seyfarth Shaw LLP

The Limits Of “Taking The Lead Early”: A Dismissal Without Prejudice Will Not Support Defend Trade Secrets Act Attorney’s Fees

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On November 13, 2018, the United States Court of Appeals, Fifth Circuit, affirmed the United States District Court for the Western District of Texas’s denial of prevailing party attorneys’ fees in a matter of first impression...more

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