Plaintiff Theodore F. Schroeder alleged that defendants Brian S. Cohen, New York Angels, Inc. (“NY Angels”), and Pinterest Inc. (“Pinterest”) misappropriated Schroeder’s confidential ideas, technology and business plans in developing the popular social network bulletin board, Pinterest.com. In 2005, Schroeder had initially invited Cohen to participate in planning meetings for another project and during these meetings, Schroeder had shared confidential information, which Schroeder alleges Cohen then provided to Pinterest.
On October 6, 2015, the NY appellate court revived the trade secret misappropriation claim, stating that the Complaint provides sufficient support for the trade secret misappropriation claim against Cohen and NY Angels. The court noted that Cohen had indeed been exposed to the confidential information and had provided the confidential information whilst knowing the information must remain confidential. Further, the opinion notes Schroeder’s efforts in trying to maintain secrecy over the technology he worked on for roughly four years. However, the court did not extend the misappropriation claim to Pinterest, as there were no facts in the pleadings demonstrating that there had ever been a confidential relationship established between Plaintiff and Pinterest, let alone any contact between them at all.