Massachusetts Federal Court Rejects Expansive View of Inevitable Disclosure Doctrine and Denies Preliminary Injunction

On June 19, 2012, a Massachusetts federal court declined to apply an expansive interpretation of the inevitable disclosure doctrine during a preliminary injunction ruling, finding that the rule is best applied to establish irreparable injury supporting enforcement of a non-competition agreement and not as the basis for a future misappropriation of trade secrets claim.

In U.S. Elec. Svcs., Inc. v. Schmidt, 2012 U.S. Dist. LEXIS 84272 (D. Mass. June 19, 2012), plaintiff USESI, a national distributor of electrical products and services, sued two former employees and their current employer, Munro, for breach of contract, misappropriation of trade secrets, and unfair competition, among other allegations. Munro is a regional distributor of electrical products whose national accounts division competes directly with USESI. USESI claims that Munro and its former employees intended to compete with USESI for a specific account, which was scheduled to go out for bid for the first time in four years. One week prior to the bid, USESI filed its complaint and a motion for a preliminary injunction.

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