Savor, Inc. v. FMR Corp. and UPromise, Inc.

Summary

The Supreme Court of Delaware held that Savor, Inc.'s complaint adequately pleaded a claim for misappropriation of trade secrets under liberal notice-pleading standards. The court concluded that a unique combination of marketing strategies and processes could constitute a trade secret, and that issues concerning secrecy, economic value, and misappropriation could not be resolved on a motion to dismiss. The court reversed dismissal of the third amended complaint but affirmed dismissal of the common-law unfair competition and conspiracy claims as displaced by Delaware's Uniform Trade Secrets Act.

Holdings

1. The Third Amended Complaint adequately stated a claim for misappropriation of trade secrets because it identified the alleged trade secret as a unique combination of marketing strategies and processes, and alleged economic value, secrecy, confidentiality efforts, and misappropriation sufficiently to provide notice.
2. The Superior Court correctly dismissed Savor's unfair-competition and conspiracy claims because they sought civil remedies based solely on the alleged misappropriation of a trade secret and were therefore displaced by the Uniform Trade Secrets Act.

Questions Presented

1. Whether Savor's Third Amended Complaint adequately pleaded a protectable trade secret and misappropriation claim under Delaware's liberal notice-pleading standard.
2. Whether the alleged combination of generally known marketing components could constitute a trade secret.
3. Whether Delaware's Uniform Trade Secrets Act displaced Savor's common-law unfair-competition and conspiracy claims based on the same alleged misappropriation.

Disposition

other