Indiana Appellate Court Finds That Indiana Uniform Trade Secrets Act Preempts Common Law Misappropriation and Civil Conversion Claims In Mixed Martial Arts Broadcasting Dispute

The Court of Appeals of Indiana recently reversed and remanded a 2008 suit brought by the North American Boxing Council (NABC) against HDNet LLC (HDNet), in which the NABC alleged that HDNet stole its idea for a mixed martial arts (MMA) broadcast series after the parties had discussed a broadcast arrangement that never materialized into a formal contract.

The Court of Appeals held that the trial court erred in granting summary judgment because NABC’s idea misappropriation claim fell under the Indiana Uniform Trade Secrets Act’s (IUTSA) preemption provision and NABC’s civil conversion claim did not fall within the “criminal law” exception to the preemption provision.

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