MST & Associates, Inc. and Rue Enterprises, LLC v. Brenda Withrow and Medical Equipment Solutions LLC

Summary

The United States District Court for the Eastern District of Virginia denies defendants’ Rule 12(b)(6) motion to dismiss claims arising from alleged misuse of customer information by a former employee and her company. The court holds that the complaint plausibly alleges a trade secret under the Defend Trade Secrets Act, computer trespass under the Virginia Computer Crimes Act, defamation, and tortious interference with business relations. The opinion addresses only the sufficiency of the pleadings and does not resolve the merits of the claims.

Holdings

1. The complaint plausibly alleged that MST's customer information was a trade secret because MST restricted access to the information, instructed employees to keep it confidential, and the information had independent economic value from being secret.
2. The complaint adequately pleaded computer trespass under Virginia Code §§ 18.2-152.4(A)(3) and (A)(6) by alleging that Withrow deleted data from a company-issued phone and copied private customer data by forwarding work emails to her personal account.
3. The complaint adequately pleaded the intent element of defamation by alleging that Withrow knew her statement that MST was not paying its bills was false.
4. The complaint adequately alleged a valid business expectancy because it identified ongoing contractual relationships with hospital systems and medical facilities and described current customers extending business offers.

Questions Presented

1. Whether the complaint plausibly alleged the existence of a trade secret, including reasonable measures to maintain secrecy and independent economic value, under the Defend Trade Secrets Act.
2. Whether the complaint plausibly alleged a civil claim for computer trespass under the Virginia Computer Crimes Act based on deletion and copying of computer data.
3. Whether the complaint plausibly alleged the intent element of a defamation claim under Virginia law.
4. Whether the complaint plausibly alleged a valid business expectancy, including ongoing contractual relationships, for purposes of a Virginia tortious-interference claim.

Disposition

other