Cases from William H. Pauley III

S.D.N.Y.
New York Court Dismisses Inevitable Disclosure Claim

Alleging a stand-alone claim under the inevitable disclosure doctrine, plaintiff sued a former a sales associate and sought permanent injunctive relief barring the former employee from disclosing any of plaintiff's trade secrets or confidential information, and from working for its competitor. There were no allegations that the former employee breached a non-disclosure agreement, disclosed or misappropriated any trade secrets, or was subject to a non-compete agreement. The court granted defendant's motion to dismiss and declined to expand New York's application of the inevitable disclosure doctrine under this set of facts and outside of the preliminary injunction context.