DEX Imaging, LLC v. Kenneth Vanden Haute, et al.

Summary

The United States District Court for the Northern District of Ohio denied Defendants’ Rule 12(b)(1) motion to dismiss for lack of subject matter jurisdiction. The court held that the amended complaint sufficiently alleged the interstate-commerce and relationship requirements for a claim under the Defend Trade Secrets Act, including allegations concerning DEX’s nationwide services and confidential information. The court declined to consider an inadequately developed challenge to other elements of the DTSA claim.

Holdings

1. The amended complaint adequately alleged that DEX's products and services were used in, or intended for use in, interstate commerce.
2. The amended complaint adequately alleged that the trade secrets were related to DEX's products and services used in interstate commerce.
3. Because the complaint adequately pleaded a DTSA claim sufficient to establish federal-question jurisdiction, the court retained supplemental jurisdiction over the related state-law claims under 28 U.S.C. § 1367.

Questions Presented

1. Whether the amended complaint adequately pleaded the interstate-commerce element required for subject matter jurisdiction over a Defend Trade Secrets Act claim.
2. Whether the alleged trade secrets were related to products or services used in, or intended for use in, interstate commerce under 18 U.S.C. § 1836(b)(1).
3. Whether the court had supplemental jurisdiction over the related state-law claims under 28 U.S.C. § 1367.

Disposition

other