Alta Devices, Inc. v. LG Electronics, Inc.
2018 , United States District Court, N.D. California, San Jose Division
Judge LUCY H. KOH
Summary
Alta Devices, Inc., initiated a lawsuit against LG Electronics, Inc., alleging misappropriation of trade secret technology relating to thin-film Gallium Arsenide (GaAs) solar cells. Alta claimed that confidential and proprietary information was disclosed to LG under a mutual non-disclosure agreement during discussions about potential investment or business opportunities. LG was accused of using this trade secret information to develop a similar technology. The court dealt with LG’s motion to dismiss, granting in part and denying in part, based on the grounds of insufficient particularity in trade secret description and the applicability of the Defend Trade Secrets Act and the California Uniform Trade Secret Act.
Decision
The court DENIED LG's motion to dismiss regarding misappropriation of trade secrets under the Defend Trade Secrets Act (DTSA) and the California Uniform Trade Secrets Act (CUTSA), finding that Alta described its trade secrets with sufficient particularity. The court ruled that the non-disclosure agreement's term provision was ambiguous regarding its expiration and its impact on trade secret status.
Legal Significance
This case emphasizes the critical nature of accurately defining the term and scope of NDAs and the importance of specificity when alleging trade secret misappropriation. It highlights that the expiration of a contractual agreement does not inherently negate the protection of trade secrets disclosed under it.
Financial Judgement
Not given
Key Takeaways
The ambiguity of contract terms can significantly impact trade secret protection and litigation outcomes. It underscores the necessity for parties to carefully negotiate and delineate the terms of confidentiality agreements, especially concerning the definition and duration of trade secret protection.
