Case: Trade Secrets/Elements (1st Cir.)

The Court of Appeals for the First Circuit reversed a federal district court’s finding that a former employee of TLS Mgmt. & Mktg. Servs. LLC was liable in its action against him for the misappropriation of trade secrets. The First Circuit found that any trade secrets in the two Capital Preservation Reports the former employee downloaded without authorization from TLS’s Dropbox account before he left TLS were not identifiable, because TLS did not separate the purported trade secrets from the other information that was known in the trade of tax planning and consulting; therefore, TLS failed to satisfy its burden ...