3D Systems, Inc. v. Wynne

Summary

The United States District Court for the Southern District of California addresses competing summary-judgment motions, motions to strike, and motions to exclude experts in a trade-secret dispute involving 3D Systems, Inc., Intrepid Automation, and former employees. The court grants summary judgment for Intrepid on 3D Systems’ trade-secret claims based on inadequate identification of the alleged secrets, while finding that Intrepid’s misappropriation claim presents sufficient evidence to proceed.

Holdings

1. A trade-secret plaintiff must identify the alleged secrets with sufficient particularity to distinguish them from generally known information and other information incorporated into the relevant technology. After the parties have completed dialectic discovery, the required specificity is more stringent; generic references to technologies, systems, lists, information, or broad categories are insufficient.
2. Summary judgment was improper on Intrepid's trade-secret-misappropriation claim because evidence that Kuester acquired Intrepid's trade secrets, followed by the development of a closely similar device and additional circumstantial evidence of disclosure or use, created triable issues concerning misappropriation.
3. Intrepid presented sufficient evidence of actual loss, unjust enrichment, or the possible need for a reasonable royalty to create a triable issue on damages.
4. Confidentiality provisions that broadly prohibit former employees from using confidential information beyond trade secrets and that cover ordinary materials, suppliers, resellers, and publicly available or publicly publishable information unlawfully restrain the employees' ability to practice their profession under California Business and Professions Code section 16600.
5. Even if the invalid portions of 3D Systems' employment agreements were severed, 3D Systems could not obtain summary judgment on its breach-of-contract claim because it failed to properly identify the alleged trade secrets.
6. The challenged expert testimony was admissible because the experts were qualified in their fields, their opinions were sufficiently reliable and relevant, and the asserted weaknesses generally went to weight rather than admissibility.
7. A thirteen-day delay in answering did not warrant striking 3D Systems' and Kuester's answer because Intrepid showed no significant prejudice and striking the pleading would be a drastic remedy inconsistent with resolving cases on the merits.

Questions Presented

1. Whether 3D Systems identified its alleged trade secrets with sufficient particularity to support its federal and California trade-secret-misappropriation claims.
2. Whether sufficient evidence existed for a reasonable jury to find that 3D Systems and Kuester misappropriated Intrepid's trade secrets.
3. Whether sufficient evidence existed for a reasonable jury to find damages from the alleged misappropriation of Intrepid's trade secrets.
4. Whether portions of 3D Systems' employee confidentiality agreements unlawfully restrained former employees from engaging in their profession under California Business and Professions Code section 16600.
5. Whether 3D Systems could prevail on its breach-of-contract claims despite the agreements' severability provisions.
6. Whether the challenged expert testimony satisfied Federal Rule of Evidence 702.
7. Whether 3D Systems' and Kuester's late answer to Intrepid's counterclaim and third-party claim should be stricken.

Disposition

other