Tidings of Data Theft and Coal: California Federal Court Holds That Trade Secret Misappropriation Statute Preempts Claim For Misappropriation Of Confidential Non-Trade Secret Data

There was only coal delivered for California employers in a recent California federal decision in which the Court refused to permit a plaintiff to proceed on a tort theory for the theft of confidential information.

In a well-researched and articulate opinion, the federal court for the Northern District of California recently dismissed, as preempted by the California Uniform Trade Secrets Act (CUTSA), claims for misappropriation of non-trade secret proprietary information. Judge Koh, reasoned that those claims arose out of the same operative facts as the plaintiff’s trade secret misappropriation cause of action. SunPower Corp. v. Solarcity Corp., Case No. 12-CV-00694-LHK (N.D. Cal., Dec. 11, 2012) (Koh, J.).

 

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