The Fourth Circuit affirms dismissal of a DTSA complaint that defined its trade secrets three ways, holding that sweeping definitions fail the particularity that the statute's secrecy and value elements presuppose.
Judge Posner explained why a container design disclosed in a bid — conceded not to be a trade secret and outside the parties' logistics-only nondisclosure agreement — was free for the recipient to use.
Judge Easterbrook held that a software company's forty-three-page, undifferentiated description of its medical-billing system failed to identify any trade secret with the specificity the law demands.
The Ninth Circuit held that a buffet chain's everyday recipes and loosely guarded training manuals failed both elements of the secrecy analysis, marking the outer boundary of what 'qualifies' under the Uniform Trade Secrets Act.
