I.C. Intelligence LLC v. ShowNation LLC; Yonne Tiger

Summary

The United States District Court for the Northern District of Oklahoma rules on Defendants’ motion to dismiss claims arising from alleged misappropriation of trade secrets and related state-law causes of action involving competing casino-management software. The court declines to dismiss the claims against ShowNation based on the statute of limitations or Oklahoma Uniform Trade Secrets Act preemption. It dismisses the claims against Yonne Tiger under Oklahoma’s statute limiting claims against corporate officers and LLC members, while granting leave to amend.

Holdings

1. The court may not consider a cease-and-desist letter that was not mentioned in or central to the complaint when deciding the motion to dismiss.
2. The court was not required to convert the motion to dismiss into a motion for summary judgment and declined to do so.
3. The Oklahoma Uniform Trade Secrets Act did not require dismissal of I.C.'s conversion, unjust-enrichment, and breach-of-fiduciary-duty claims because the complaint sought recovery for information that could include non-trade-secret confidential business information as well as trade secrets.
4. Section 682-B barred I.C.'s claims against Tiger because the complaint alleged only that she had access to I.C.'s confidential information and did not allege that she used it to misappropriate the information or acted outside the scope of her role.

Questions Presented

1. Whether the court could consider a cease-and-desist letter not attached to or referenced in the complaint when deciding the statute-of-limitations defense on a motion to dismiss.
2. Whether the court should convert the motion to dismiss into a motion for summary judgment based on the attached cease-and-desist letter.
3. Whether the Oklahoma Uniform Trade Secrets Act preempted I.C.'s claims for conversion, unjust enrichment, and breach of fiduciary duty at the pleading stage.
4. Whether Okla. Stat. tit. 12, § 682-B barred I.C.'s claims against Tiger because the complaint did not allege that she personally misappropriated information or acted outside the scope of her role.

Disposition

other