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Case No. 05-18-01447-CV

Regular Panel Decision

Dec 14, 2020

Snowhite Textile and Furnishings, Inc. v. Innvision Hospitality, Inc.

This case concerns a dispute between two competitors, Snowhite Textile and Furnishings, Inc. and Innvision Hospitality, Inc., in the furniture, fixture, and equipment (FF&E) industry. Innvision sued Snowhite for violations of the Texas Uniform Trade Secrets Act (TUTSA) and tortious interference with prospective business and existing contracts, alleging Snowhite misappropriated its bid proposal for the 'Odessa Project'. The district court rendered judgment in favor of Innvision. Snowhite appealed, challenging the sufficiency of the evidence for liability and damages, as well as the award of attorney's fees. The Court of Appeals affirmed the trial court's judgment, finding sufficient evidence for trade secret misappropriation, tortious interference, damages, and willful and malicious misappropriation supporting attorney's fees.

Trade Secret MisappropriationTexas Uniform Trade Secrets ActTortious InterferenceProspective Business RelationsAppellate JudgmentSufficiency of EvidenceLost Profits DamagesAttorney's Fees AwardWillful MisappropriationConfidential Business Information

References

Case No. MISSING

Regular Panel Decision

Williams-Sonoma Direct, Inc. v. Arhaus, LLC

This case involves a dispute where Plaintiffs Williams-Sonoma Direct, Inc. (WSDI) and Williams-Sonoma Retail Services, Inc. (WSRSI) sued Defendants Timothy Stover and Arhaus, LLC. The plaintiffs alleged violations of the Tennessee Uniform Trade Secrets Act (TUTSA), breach of contract, breach of the duty of loyalty, and tortious interference with contract. The defendants filed motions to dismiss under Rule 12(b)(1) and (7) of the Federal Rules of Civil Procedure, arguing a lack of subject-matter jurisdiction due to the alleged indispensable party status of Williams-Sonoma, Inc. (WSI) and improper creation of diversity jurisdiction. The Court denied in part the defendants' motions, finding that WSDI and WSRSI are real parties in interest and WSI is not an indispensable party, and no improper or collusive creation of jurisdiction occurred.

Trade SecretsBreach of ContractDuty of LoyaltyTortious InterferenceMotion to DismissSummary JudgmentSubject Matter JurisdictionDiversity JurisdictionIndispensable PartyRule 12(b)(1)

References

Case No. MISSING

Regular Panel Decision

Cardinal Health 414, Inc. v. Adams

This case addresses allegations of email snooping within the nuclear pharmacy industry, where plaintiff Cardinal Health 414, Inc. sued former employees Daniel Adams and Allen B. Townsend along with Music City Nuclear Pharmacy. Adams allegedly accessed a former co-worker's email account after leaving Cardinal and shared confidential information, including customer data and pricing, with Townsend, who subsequently started a competing business. Cardinal sought damages for business losses, claiming violations of federal and Tennessee statutes concerning electronic communications and trade secrets. The court rendered decisions on several cross-motions for summary judgment, granting some claims and denying others, while also addressing affirmative defenses. Ultimately, the court found Adams liable for an SCA violation and granted summary judgment against defendants on wiretap and civil conspiracy claims, but allowed TPCCA and TUTSA claims to proceed to trial.

E-mail snoopingTrade secrets misappropriationComputer fraudElectronic communications privacyWiretap ActSummary judgmentAffirmative defensesLachesIllegalityAntitrust

References

Case No. MISSING

Regular Panel Decision

Wachter, Inc. v. Cabling Innovations, LLC

Plaintiff Wachter, Inc. sued former employees Brian Pitts and Josh Estes, along with Megan Pitts and Cabling Innovations, LLC, alleging various federal and state law violations, including under the Computer Fraud and Abuse Act (CFAA), Electronic Communications Protection Act (ECPA), Stored Communications Act (SCA), breach of fiduciary duty, tortious interference, unjust enrichment, conversion, and civil conspiracy. The defendants filed a motion to dismiss all claims. The court granted the motion in part and denied in part. It dismissed the federal claims (CFAA, ECPA, SCA) and several state law claims (breach of fiduciary duty, tortious interference, unjust enrichment, conversion), finding them either legally insufficient, not applicable to employees, or preempted by the Tennessee Uniform Trade Secrets Act (TUTSA). However, the court allowed the claims for breach of duty of loyalty (Count V) and civil conspiracy (Count IX) to proceed against the relevant defendants.

Computer FraudEmployee MisconductConfidential InformationTrade SecretsMotion to DismissFederal JurisdictionState Law ClaimsBreach of Duty of LoyaltyCivil ConspiracyCFAA

References

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Snowhite Textile and Furnishings, Inc. v. Innvision Hospitality, Inc.

Williams-Sonoma Direct, Inc. v. Arhaus, LLC

Trade SecretsBreach of ContractDuty of LoyaltyTortious InterferenceMotion to DismissSummary JudgmentSubject Matter JurisdictionDiversity JurisdictionIndispensable PartyRule 12(b)(1)

Cardinal Health 414, Inc. v. Adams

E-mail snoopingTrade secrets misappropriationComputer fraudElectronic communications privacyWiretap ActSummary judgmentAffirmative defensesLachesIllegalityAntitrust

Wachter, Inc. v. Cabling Innovations, LLC

Computer FraudEmployee MisconductConfidential InformationTrade SecretsMotion to DismissFederal JurisdictionState Law ClaimsBreach of Duty of LoyaltyCivil ConspiracyCFAA