Wash. Rev. Code » Title 19 · Chapter 19.108
Revised Code of Washington

Wash. Rev. Code § 19.108.030 (2026)

✓ current as of May 2026
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(1) In addition to or in lieu of injunctive relief, a complainant may recover damages for the actual loss caused by misappropriation. A complainant also may recover for the unjust enrichment caused by misappropriation that is not taken into account in computing damages for actual loss.
(2) If wilful and malicious misappropriation exists, the court may award exemplary damages in an amount not exceeding twice any award made under subsection (1).
[ 1981 c 286 s 3.]
Notes of Decisions
Cited in 23 cases (7 in the last 5 years), 1997–2025 · leading case: Inteum Co. v. Nat'l Univ. of Sing., 371 F. Supp. 3d 864 (W.D. Wash. 2019).
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Inteum Co. v. Nat'l Univ. of Sing., 371 F. Supp. 3d 864 (W.D. Wash. 2019). · cites it 6× “) Under the WUTSA, a plaintiff may seek injunctive relief, "damages for the actual loss caused by misappropriation," and damages from any "unjust enrichment caused by misappropriation that is not taken into account in computing damages for actual loss, and exemplary damages.”
Boeing Co. v. Sierracin Corp., 738 P.2d 665 (Wash. 2000). · cites it 2× “Holt Foreperson Trade Secrets The Uniform Trade Secrets Act, RCW 19.108.030(1), provides that a plaintiff can receive actual damages for misappropriation of trade secrets.”
Thola v. Henschell, 164 P.3d 524 (Wash. Ct. App. 2007). · cites it 3× “Unjust Enrichment ¶ 25 Henschell argues that Thola's UTSA claim precluded her unjust enrichment claim. We disagree.”
Thola v. Henschell, 140 Wash. App. 70 (Wash. Ct. App. 2007). · cites it 3× “Unjust Enrichment ¶25 Henschell argues that Thola’s UTSA claim precluded her unjust enrichment claim. We disagree. The UTSA expressly allows unjust enrichment claims.”
Eagle Grp., Inc. v. Pullen, 58 P.3d 292 (Wash. Ct. App. 2002). · cites it 4× “See RCW 19.108.030, .040. [6] CR 49(a) provides: If in [submitting a special verdict to the jury] the court omits any issue of fact raised by the pleadings or by the evidence, each party waives his rights to a trial by jury of the issue so omitted unless before the jury retires…”
Eagle Grp., Inc. v. Pullen, 58 P.3d 292 (Wash. Ct. App. 2002). · cites it 3× “Under RCW 19.108.030(1) of the UTSA, “a complainant may recover damages for the actual loss caused by misappropriation,” together with any additional damages needed to compensate for unjust enrichment.”
Ed Nowogroski Inc., Inc. v. Rucker, 944 P.2d 1093 (Wash. Ct. App. 1997). · cites it 2× “” RCW 19.108.030(1). We disagree with the trial court’s finding that Nowogroski acted with unclean hands.”
Seiu Healthcare Nw Training P'ship v. Evergreen Freedom Found., 427 P.3d 688 (Wash. Ct. App. 2018). “" RCW 19.108.030(1), quoted in Thola, 140 8 No.”
Petters v. Williamson & Assocs., Inc., 210 P.3d 1048 (Wash. Ct. App. 2009). · cites it 2× “RCW 19.108.030 allows for double damage awards on willful and malicious misappropriations.”
Ultimate Timing, L.L.C. v. Simms, 715 F. Supp. 2d 1195 (W.D. Wash. 2010). “Washington’s Uniform Trade Secrets Act, RCW 19.108.030(1), provides a “complainant may recover damages for the actual loss caused by misappropriation” of trade secrets.”
Petters v. Williamson & Assocs., Inc., 151 Wash. App. 154 (Wash. Ct. App. 2009). “That is, it requires the defendant to explain why any particular portion of the money that it received as a result of the misappropriating transaction should not be considered an “actual loss” suffered by the plaintiff under RCW 19.108.030(1). The rule has been widely adopted in…”
Staff Builders Home Healthcare, Inc. v. Whitlock, 33 P.3d 424 (Wash. Ct. App. 2001). · cites it 2× “Under the UTSA, the trial court awarded Staff Builders $4,500 for “damages and recoupment of unjust enrichment” against Affordable and $22,500 for “unjust enrichment” against Whitlock. Whitlock does not contest the judgment against Affordable for $4,500.”
Show all 23 citing cases →
— Wash. Rev. Code § 19.108.030(1) — 17 cases
Boeing Co. v. Sierracin Corp., 738 P.2d 665 (Wash. 2000). “Holt Foreperson Trade Secrets The Uniform Trade Secrets Act, RCW 19.108.030(1), provides that a plaintiff can receive actual damages for misappropriation of trade secrets.”
Seiu Healthcare Nw Training P'ship v. Evergreen Freedom Found., 427 P.3d 688 (Wash. Ct. App. 2018). “" RCW 19.108.030(1), quoted in Thola, 140 8 No.”
Thola v. Henschell, 164 P.3d 524 (Wash. Ct. App. 2007). “Unjust Enrichment ¶ 25 Henschell argues that Thola's UTSA claim precluded her unjust enrichment claim. We disagree.”
Thola v. Henschell, 140 Wash. App. 70 (Wash. Ct. App. 2007). “Unjust Enrichment ¶25 Henschell argues that Thola’s UTSA claim precluded her unjust enrichment claim. We disagree. The UTSA expressly allows unjust enrichment claims.”
Eagle Grp., Inc. v. Pullen, 58 P.3d 292 (Wash. Ct. App. 2002). “Under RCW 19.108.030(1) of the UTSA, “a complainant may recover damages for the actual loss caused by misappropriation,” together with any additional damages needed to compensate for unjust enrichment.”
— Wash. Rev. Code § 19.108.030(2) — 8 cases
Thola v. Henschell, 164 P.3d 524 (Wash. Ct. App. 2007). “Unjust Enrichment ¶ 25 Henschell argues that Thola's UTSA claim precluded her unjust enrichment claim. We disagree.”
Thola v. Henschell, 140 Wash. App. 70 (Wash. Ct. App. 2007). “Unjust Enrichment ¶25 Henschell argues that Thola’s UTSA claim precluded her unjust enrichment claim. We disagree. The UTSA expressly allows unjust enrichment claims.”
Eagle Grp., Inc. v. Pullen, 58 P.3d 292 (Wash. Ct. App. 2002). “Under RCW 19.108.030(1) of the UTSA, “a complainant may recover damages for the actual loss caused by misappropriation,” together with any additional damages needed to compensate for unjust enrichment.”
Boeing Co. v. Sierracin Corp., 738 P.2d 665 (Wash. 2000). “Holt Foreperson Trade Secrets The Uniform Trade Secrets Act, RCW 19.108.030(1), provides that a plaintiff can receive actual damages for misappropriation of trade secrets.”
Eagle Grp., Inc. v. Pullen, 58 P.3d 292 (Wash. Ct. App. 2002). “See RCW 19.108.030, .040. [6] CR 49(a) provides: If in [submitting a special verdict to the jury] the court omits any issue of fact raised by the pleadings or by the evidence, each party waives his rights to a trial by jury of the issue so omitted unless before the jury retires…”
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