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Uniform Trade Secrets Act

The following summaries are of recent published decisions of the California appellate courts, the Ninth Circuit, and the United States Supreme Court. The summaries are presented without regard to whether Severson & Werson represented a party in the case.

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Applied Medical Distribution Corp. v. Jarrells (2024) 100 Cal.App.5th 556

There are only two elements to a misappropriation of trade secrets claim:  the existence of a trade secret, and its unauthorized dissemination, disclosure or use.  It is not necessary for the plaintiff to prove it was damaged or the defendant was unjustly enriched.  Those issues are relevant only to an award of damages or restitution.  Even absent damages or enrichment,… Read More

Mattson Technology, Inc. v. Applied Materials, Inc. (2023) 96 Cal.App.5th 1149

The trial court correctly denied Mattson's motion to compel arbitration of Applied's suit against it for violation of the Uniform Trade Secrets Act. Mattson had hired Lai away from Applied.  Lai's employment agreement with Applied contained an arbitration clause.  Mattson was not a party to that contract and could not enforce it on a equitable estoppel basis since Applied's claim… Read More