TRADE SECRET REPORT
Irell & Manella LLP
DTSAâPLEADING TRADE SECRETS SUFFICIENTLY
Whiteslate LLP v. Dahlin, 20-cv-1782 W (BGS) (S.D. Cal. July 7, 2021).
After transactional associate accepts in-house job at law firm client, law firm sues client and former associate alleging, in part, violations of the Defend Trade Secrets Act and the California Uniform Trade Secrets Act. Firm alleged that transactional attorney provided various documents, templates, and other work product owned by it to client (with whom transactional attorney was interviewing for in-house position). Firm sues in part on DTSA and California UTSA (CUTSA). Court held on motion to dismiss that "catchall phrases" or "categorical information" such as "contracts, document templates, and other work-product, as well as [plaintiff’s] client list and database," is not sufficient to plead existence of a trade secret under either the DTSA or CUTSA (which the court notes are "substantially similar, and many courts analyze the claims together.")