Va. Code » Title 59.1. Trade and Commerce » Chapter 26. Uniform Trade Secrets Act
Virginia Code

Va. Code Ann. § 59.1-337 (2026)

Injunctive relief

✓ current as of May 2026
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A. Actual or threatened misappropriation may be enjoined. Upon application to the court, an injunction shall be terminated when the trade secret has ceased to exist, but the injunction may be continued for an additional reasonable period of time in order to eliminate commercial advantage that otherwise would be derived from the misappropriation.

B. In exceptional circumstances, an injunction may condition future use upon payment of a reasonable royalty for no longer than the period of time for which use could have been prohibited. Exceptional circumstances include, but are not limited to, a material and prejudicial change of position prior to acquiring knowledge or reason to know of misappropriation that renders a prohibitive injunction inequitable.

C. In appropriate circumstances, affirmative acts to protect a trade secret may be compelled by court order.

1986, c. 210.

Notes of Decisions
Cited in 14 cases (3 in the last 5 years), 1990–2025 · leading case: MicroStrategy, Inc. v. Bus. Objects, S.A., 369 F. Supp. 2d 725 (E.D. Va. 2005).
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MicroStrategy, Inc. v. Bus. Objects, S.A., 369 F. Supp. 2d 725 (E.D. Va. 2005). · cites it 31× “In this case, the Rule 60(b) motion does not substitute for an appeal, both because the injunction has not been appealed and because the requested relief would not impede the Federal Circuit’s consideration of the issues on appeal.”
MicroStrategy, Inc. v. Bus. Objects, S.A., 661 F. Supp. 2d 548 (E.D. Va. 2009). · cites it 15× “See Va.Code Ann. § 59.1-337. The court finds that Business Objects has now met that burden, and has established that the Competitive Recipe should no longer be considered a trade secret under Virginia law.”
Motion Control Sys., Inc. v. East, 546 S.E.2d 424 (Va. 2001). · cites it 6× “Injunction The trial court, finding that East had knowledge of MCS’s trade secrets, enjoined East from disclosing MCS’s confidential, trade secret, or proprietary information to anyone, pursuant to Code § 59.1-337. That section provides in pertinent part: A.”
Dionne v. Se. Foam Converting & Packaging, Inc., 397 S.E.2d 110 (Va. 1990). · cites it 6× “1 Applying Code § 59.1-337(A) which provides that “[a]ctual or threatened misappropriation may be enjoined”, the chancellor entered the injunction Pierre challenges on appeal.”
MicroStrategy, Inc. v. Bus. Objects, S.A., 331 F. Supp. 2d 396 (E.D. Va. 2004). · cites it 2× “Va.Code Ann. § 59.1-337(A). However, the statute also permits the court to extend the injunction for a reasonable period despite this fact.”
MeadWestvaco Corp. v. Bates, 91 Va. Cir. 509 (Chesterfield Cir. Ct. 2013). · cites it 15× “” Va. Code Ann. § 59.1-337 (A). However, “[mjere knowledge of trade secrets is insufficient to support an injunction under the terms of Code Ann.”
Ipsen v. Moxley, 642 S.E.2d 798 (Va. Ct. App. 2007). · cites it 2× “”); Code § 59.1-337(A) (misappropriation of trade secret may be enjoined, but "injunction shall be terminated when the trade secret has ceased to exist”).”
Reynolds & Reynolds Co. v. Hardee, 932 F. Supp. 149 (E.D. Va. 1996). · cites it 2× “1-336; (2) defendant misappropriated the artwork in violation of the Uniform Trade Secrets Act; and (3) plaintiff has been damaged by the misappropriation. Complaint ¶¶ 28-30. The Virginia Uniform Trade Secrets Act (“UTSA”) provides a remedy of injunctive relief and damages…”
Newport News Indus. v. Dynamic Testing, Inc., 130 F. Supp. 2d 745 (E.D. Va. 2001). “at § 59.1-337. “Exceptional circumstances include .”
DSC Commc'ns Corp. v. Pulse Commc'ns Inc., 976 F. Supp. 359 (E.D. Va. 1997). · cites it 2× “Count V of the complaint charged Pulsecom with misappropriating DSC’s trade secrets. The Virginia Uniform Trade Secrets Act (“UTSA”) provides a remedy of injunctive relief and damages against a person who misappropriates a trade secret.”
The Variable Annuity Life Ins. Co. v. Coreth (E.D. Va. 2021). · cites it 7× “on contained therein,” “especially the data pertaining to” clients, which constitute “trade secrets” under Virginia law, and the Former Advisors’ “actions have caused and are threatening to cause irreparable harm and loss to the VALIC Companies and could cause the VALIC…”
Signature Flight Support LLC v. Carroll (W.D. Va. 2021). · cites it 3× “Va. Code §§ 59.1-337 and 338. VUTSA defines a trade secret as: [I]nformation, including but not limited to, a formula, pattern, compilation, program, device, method, technique, or process, that: 1.”
Show all 14 citing cases →
— Va. Code Ann. § 59.1-337(A) — 6 cases
Dionne v. Se. Foam Converting & Packaging, Inc., 397 S.E.2d 110 (Va. 1990). “1 Applying Code § 59.1-337(A) which provides that “[a]ctual or threatened misappropriation may be enjoined”, the chancellor entered the injunction Pierre challenges on appeal.”
MicroStrategy, Inc. v. Bus. Objects, S.A., 331 F. Supp. 2d 396 (E.D. Va. 2004). “Va.Code Ann. § 59.1-337(A). However, the statute also permits the court to extend the injunction for a reasonable period despite this fact.”
MicroStrategy, Inc. v. Bus. Objects, S.A., 661 F. Supp. 2d 548 (E.D. Va. 2009). “See Va.Code Ann. § 59.1-337. The court finds that Business Objects has now met that burden, and has established that the Competitive Recipe should no longer be considered a trade secret under Virginia law.”
Ipsen v. Moxley, 642 S.E.2d 798 (Va. Ct. App. 2007). “”); Code § 59.1-337(A) (misappropriation of trade secret may be enjoined, but "injunction shall be terminated when the trade secret has ceased to exist”).”
The Variable Annuity Life Ins. Co. v. Coreth (E.D. Va. 2021). “on contained therein,” “especially the data pertaining to” clients, which constitute “trade secrets” under Virginia law, and the Former Advisors’ “actions have caused and are threatening to cause irreparable harm and loss to the VALIC Companies and could cause the VALIC…”
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