Cases from Montgomery

United States District Court for the District of Minnesota
Court Suggests Lenient Pleading Standard for Trade Secret Claims Surviving a Motion to Dismiss

Plaintiff TE Connectivity Networks, Inc. (TE) develops and sells fiber connectivity products. Defendant All Systems Broadband, Inc. (ASB), after hiring a number of TE’s past employees, began marketing products in direct competition with TE. TE alleged in its complaint that in developing these competing products, ASB had misappropriated numerous TE trade secrets in violation of the Minnesota Uniform Trade Secrets Act (MUTSA). ASB filed a motion to dismiss, arguing that in light of the heightened pleading standards established in cases like Iqbal, TE had not pled facts with sufficient particularity to survive a motion to dismiss. In denying the motion to dismiss, the court explained that a trade secret plaintiff is “understandably hesitant” when it comes to revealing particular details of a trade secret claim, and seemed to suggest that a more lax pleading standard may apply to trade secret misappropriation claims facing a motion to dismiss.