Global Protein Prods., Inc. v. Le, 42 Cal. App. 5th 352 (2019)

Global Protein Products, Inc. (“GPP”) successfully sued its former employee Kevin K. Le for misappropriation of trade secrets, breach of contract and unfair competition and obtained a stipulated permanent injunction against him and his company from “acquiring, disclosing, using, or attempting or threatening to acquire, disclose, or use, GPP’s trade secrets” or directly or indirectly soliciting any of GPP’s customers using GPP’s trade secrets. Seven and a half years later, GPP filed an ex parte application for an order to show cause regarding contempt associated with an alleged violation of the injunction. The trial court denied Le’s motion to modify or dissolve the injunction, and the Court of Appeal agreed, holding that there was sufficient evidence to support the trial court’s implied determination that GPP has a valid trade secret notwithstanding the publication of certain patent applications that allegedly disclosed and thereby “destroyed GPP’s trade secret.”