trade secret claim (Delaware) · Go Syfert
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trade secret claim in Delaware

6 Delaware opinions name it 2 courts 2015–2025 1 in the last five years

The cases below were cited by Delaware courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
Savor, Inc. v. FMR Corp.green
del · 2002 · cited in 2 Delaware opinions naming this issue, 2018–2018
2 sentences

2018In Beard Research, this court held that a plaintiff’s claim for breach of fiduciary duty was not preempted by DUTSA.55 In reaching that conclusion, the court reasoned that “[t]he same facts are not required to establish all the elements of both the misappropriation and breach of fiduciary duty claims,”56 and the court noted that a defendant could have breached his fiduciary duties by taking and misusing confidential information that did not rise to the level of a trade secret.57 In my view, the distinguishing fact in Beard Research was the existence of a fiduciary relationship, which required

2018CODE ANN. tit. 6, § 2007(a) (West 2018); see also Savor, Inc. v. FMR Corp., 812 A.2d 894, 898 (Del.

12
Cooney v. Osgood Machinery, Inc.green
ny · 1993 · cited in 1 Delaware opinions naming this issue, 2020–2020
1 sentence

2020Also, the Missouri choice of law clause in the NDA, while not applicable to non-contractual claims, indicates that the parties reasonably expected Missouri law to govern the question of confidentiality between them.”); Cooney v. Osgood Mach., Inc., 612 N.E.2d 277, 282 (N.Y. 1993) (“Our decision to apply Missouri law rests as well on another factor that should, at times, play a role in choice of law: the protection of reasonable expectations . . .”). 48 At this stage of the case, it is not possible to determine what state’s law would govern the trade secret claim.

11
Beard Research, Inc. v. Katesgreen
delch · 2010 · cited in 1 Delaware opinions naming this issue, 2018–2018
1 sentence

2018In Beard Research, this court held that a plaintiff’s claim for breach of fiduciary duty was not preempted by DUTSA.55 In reaching that conclusion, the court reasoned that “[t]he same facts are not required to establish all the elements of both the misappropriation and breach of fiduciary duty claims,”56 and the court noted that a defendant could have breached his fiduciary duties by taking and misusing confidential information that did not rise to the level of a trade secret.57 In my view, the distinguishing fact in Beard Research was the existence of a fiduciary relationship, which required

11
Pacific Aerospace & Electronics, Inc. v. Taylorgreen
waed · 2003 · cited in 1 Delaware opinions naming this issue, 2016–2016
1 sentence

2016Aerospace & Elecs., Inc. v. Taylor, 295 F. Supp. 2d 1188, 1200 (E.D.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Delaware. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Aoki v. Benihana Inc. green
ded · 2012
1 sentence

2025Id.

12025–2025
Martinez v. E.i. Dupont De Nemours & Co. green
del · 2014
1 sentence

2015Id. at 20–21. 90 See Pl’s Supp.

12015–2015

Where else courts name it

TX 45 (1960–2025) CA 25 (1983–2020) OH 19 (1994–2024) FL 17 (1995–2026) NY 7 (1993–2024) VA 6 (2004–2024) DE 6 (2015–2025) NJ 5 (2002–2022) WA 5 (2007–2026) CT 4 (1999–2024) IL 4 (1978–2021) NC 4 (1993–2022) CO 4 (1997–2019) ND 3 (1993–2023) SD 3 (2000–2022) NM 3 (2007–2008) WI 2 (2002–2006) AL 2 (2018–2018) IN 2 (2004–2005) UT 2 (2015–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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