The Ninth Circuit recently held that the Defend Trade Secrets Act (“DTSA”) does not require plaintiffs to identify their allegedly misappropriate trade secrets with reasonable particularity at the outset of discovery—much unlike the California Uniform Trade Secrets Act (“CUTSA”). Quintara Biosciences, Inc. v. Ruifeng Biztech, Inc., No. 23-16093 (Aug. 12, 2025). Rather, the DTSA’s requirement that a plaintiff identify trade secrets with “sufficient particularity”
Trade Secrets
Former Employer Was Entitled To Injunction And Fees For Employee’s Misappropriation Of Trade Secrets
Applied Med. Distribution Corp. v. Jarrells, 2024 WL 1007523 (Cal. Ct. App. 2024)
Stephen Jarrells worked for Applied as a vice president in charge of group purchasing organizations and had previously held other positions during his tenure with the company. When he was hired, Jarrells signed Applied’s proprietary information agreement in which he agreed to hold in “strictest confidence” Applied’s trade secrets and confidential/proprietary…
November 2023 California Employment Law Notes
We invite you to review our newly-posted November 2023 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include:
- Company That Hired Competitor’s Employee Was Not Entitled To Arbitrate Claims
- Disability Discrimination Claim Was Properly Dismissed On Summary Judgment
- Employee’s Attorney’s “Pervasive Incivility” Justified $460,000 Reduction In Fees
- Employees Were Properly Awarded $7.2 Million
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Company That Hired Competitor’s Employee Was Not Entitled To Arbitrate Claims
Mattson Tech., Inc. v. Applied Materials, Inc., 2023 WL 7180167 (Cal. Ct. App. 2023)

Canfeng Lai worked for many years at Applied Materials before submitting his resignation to begin a new job at Mattson Technology (one of Applied’s competitors). First, however, Lai allegedly emailed himself a number of files containing Applied’s trade secrets. In response, Applied sued both Lai and Mattson for violating the…
Trade Secrets Claim Against Company Not Severable From Claim Against Employee, Appeals Court Finds

A California semiconductor manufacturer cannot pursue in court its claims of trade secret misappropriation against a rival company while simultaneously arbitrating the same claims against the allegedly larcenous employee, a state appeals court recently found.
In Mattson Technology, Inc. v. Applied Materials, Inc., a California Court of Appeal ruled that the trial court erred by not staying Applied Materials’ trade secret misappropriation claims against…
November 2021 California Employment Law Notes
We invite you to review our newly-posted November 2021 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include:
- Ninth Circuit Resurrects California’s Anti-Arbitration Statute
- In-House Counsel’s Claim For Breach Of Oral Promise Of Contingency Fee Was Barred By Statute
- Employee Can Proceed With Age Discrimination Lawsuit Against LMU
- Order Denying Attorney’s Fees
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Order Denying Attorney’s Fees Under UTSA Is Not Separately Appealable
Dr. V. Prods., Inc. v. Rey, 68 Cal. App. 5th 793 (2021)
Dr. V. Productions sued its former employee, Samantha Rey, for misappropriation of trade secrets under the Uniform Trade Secrets Act, breach of fiduciary duty and related claims. After “significant discovery,” Dr. V. voluntarily dismissed its misappropriation of trade secrets claim. Rey then filed a motion for an award of attorney’s fees…
November 2020 California Employment Law Notes
We invite you to review our newly-posted November 2020 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include:
- Court Affirms $4.26 Million Jury Award For “Self-Published Defamation”
- Court Affirms Dismissal Of Trade Secrets Claim Brought Against Apple
- Employer Gets No Relief From $1.6 Million Default Judgment
- Google Employees’ PAGA Claims Are Not
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Court Affirms Dismissal Of Trade Secrets Claim Brought Against Apple
Hooked Media Group, Inc. v. Apple Inc., 55 Cal. App. 5th 323 (2020)
Hooked Media, a startup company that Apple expressed interest in acquiring, sued Apple after Apple passed on the deal but three of Hooked’s most important employees (including two engineers and the Chief Technical Officer) left to work for Apple. Hooked sued for fraud, misappropriation of trade secrets, interference with contract and related…
Litigant’s Attorney Is Entitled To Fees As “Prevailing Party” In UTSA Case
Aerotek, Inc. v. The Johnson Group Staffing Co., 2020 WL 5525180 (Cal. Ct. App. 2020)
The law firm Porter Scott, P.C., defended its client The Johnson Group Staffing (TJG) through two rounds of litigation against claims asserted by TJG’s chief competitor Aerotek. In the litigation, Aerotek alleged that TJG (whose founder came from Aerotek) misappropriated trade secrets by soliciting Aerotek’s customers. Aerotek lost the underlying…