Full title: Turret Labs USA, Inc., Plaintiff-Appellant, v. CargoSprint, LLC, Joshua…
Court: United States Court of Appeals, Second Circuit
Case no: 21-952
Date published: Mar 9, 2022
Fact:
Turret Labs USA, Inc. (“Turret Labs”) brought a lawsuit against CargoSprint, LLC and its CEO, alleging that they gained access to Turret Labs’ software, Dock EnRoll, and reverse engineered it to create a competing program. Turret Labs claimed misappropriation of a trade secret under the Defend Trade Secrets Act (DTSA) and common-law misappropriation of a trade secret. The district court dismissed these claims for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).
Issue:
The main issue is whether Turret Labs adequately alleged that it took reasonable measures to keep its software, Dock EnRoll, a trade secret under the DTSA and common law.
Decision:
The Court held that Turret Labs failed to plausibly allege that it took reasonable measures to keep its software, Dock EnRoll, a trade secret. The Court found that Turret Labs did not have confidentiality or nondisclosure agreements in place with Lufthansa or other users of Dock EnRoll, nor did it allege that users were obligated to keep the software confidential. Without specific allegations of reasonable measures to protect the secrecy of Dock EnRoll, the Court concluded that Turret Labs had not adequately pled misappropriation of a trade secret under the DTSA or common law. Therefore, the district court’s dismissal of these claims was affirmed.