Federal Trade Secret Law Incorporates California's Particularity Requirement

On October 15, 2020, the U.S. Court of Appeals for the Ninth Circuit held in InteliClear LLC v. ETC Global Holdings, Inc., that the federal Defend Trade Secrets Act (“DTSA”) requires trade secret plaintiffs to identify a trade secret with “sufficient particularity” prior to the start of discovery. While “reasonable particularity” is required as a matter of California statutory law, the panel did not identify a specific textual hook in the DTSA as the basis for its ruling. Still, the panel made...
By: WilmerHale

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