Christou v. Beatport, LLC

In Christou v. Beatport, LLC, the United States District Court for the District of Colorado held that log-in information to a MySpace account may constitute a trade secret. Notably, the Court denied Defendant’s motion to dismiss the trade secret misappropriation claim. The Court relied on the factors laid out by the Tenth Circuit Hertz v. Luzenac Group, 576 F.3d 1103, 1115 (10th Cir. 2009), and held that whether MySpace login information including profiles, “friends”, confidential lists of personal cell phone numbers and email addresses for DJs, agents, and promoters, and customer lists in the present circumstance constitute a trade secret is a question of fact, and that Christou had alleged sufficient facts to survive the motion to dismiss.

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