Predicting Ohio law, the Sixth Circuit held that the Uniform Trade Secrets Act does not displace a plain breach-of-contract claim — a reading that restores the statute's savings clause and its promise of uniformity.
The Fourth District reversed summary judgment to hold that California's trade-secret statute does not displace breach-of-contract, fiduciary-duty, conversion, and unfair-competition claims that rest on conduct independent of any misappropriation.
The Sixth District extended California's trade-secret displacement doctrine to claims over non-trade-secret data while holding that an end user who runs compiled software does not thereby 'use' the source-code secrets behind it.
California's first published decision squarely addressing trade-secret supersession held that the Uniform Trade Secrets Act displaces common-law tort claims resting on the same factual nucleus as the misappropriation theory.
