Cartiga, LLC v. Aquino

CourtDistrict Court, S.D. New York
DecidedFebruary 4, 2025
Docket1:24-cv-01014
StatusUnknown

This text of Cartiga, LLC v. Aquino (Cartiga, LLC v. Aquino) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cartiga, LLC v. Aquino, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

CARTIGA, LLC, Plaintiff, 24 Civ. 1014 ~ OPINION & ORDER BETTY AQUINO, Defendant.

PAUL A. ENGELMAYER, District Judge: Plaintiff Cartiga, LLC (“Cartiga”), a legal financial services company, brings this action against its former employee, Betty Aquino, alleging, inter alia, that she misappropriated trade secrets in violation of the Defend Trade Secrets Act “DTSA”) and breached a non-compete and confidentiality agreement. Aquino moves to dismiss under Federal Rule of Civil Procedure 12(b)(1) for lack of subject matter jurisdiction, Rule 12(b)(2) for lack of personal jurisdiction, Rule 12(b)(3) for improper venue, and Rule 12(b)(6) for failure to state a claim. The Court denies all but the 12(b)(6) motion, which the Court grants in part. I, Background A. Factual Background! Cartiga is a New York-based financial services company that specializes in the “highly competitive” business of legal funding. AC {] 20, 36. Cartiga supplies nationwide law firms and the firms’ clients with financing to support “personal financial, medical, and household needs while [the funding recipients] are pursuing their legal claims[.]” /d. € 22. Cartiga invests

The following facts, presumed true for purposes of resolving the motions, are drawn from the Amended Complaint, Dkt. 15 (“AC”).

substantial resources in building and maintaining relationships with its client base, the maintenance of which is critical to Cartiga’s business success, /d. 23. Cartiga states that it creates and maintains “confidential and proprietary information” relating to its client base that includes, but is not limited to, “strategic plans for obtaining and retaining business from consumers and law firms who represent them, extensive customer data, including their identity, contact information, and pricing and terms offered to clients of specific firms.” /d Cartiga alleges that this information is not known or generally available in the industry and that its information-gathering efforts allow it to maintain its competitive position in the market. See id. {9 26. As alleged, this information derives its economic value “from not being generally known to” and being “not readily ascertainable” to others. Jd. { 112. Cartiga takes several measures to protect this information. First, it requires employees to execute employment agreements that contain confidentiality, non-compete, non-solicitation, and non-interference provisions. /d. {J 73, 114. Second, Cartiga stores sensitive information in a password-protected “Client Relationship Management Software” database that requires authorization and authentication to access. /d. §27, 114. Third, Cartiga requires the use of individual usernames and passwords for cases involving email or file sharing. Jd. 4 114. Fourth, Cartiga uses firewall software to protect its network and grants virtual private network access only to authorized users. Jd. Fifth, Cartiga requires employees to review their obligations regarding use and disclosure restrictions and requires former employees to sign a form acknowledging such responsibilities. fd. In September 2021, Cartiga hired Aquino as a sales and business development employee. Id. 4 28; Dkt. 22 at 1. Aquino signed an agreement containing confidentiality, non-compete,

non-solicitation, and non-interference clauses as a condition of employment. Jd. 4] 72-73 (citing Ex. 1 (the “Agreement”)). The Agreement states in relevant part: 1. Confidential Information: I acknowledge and agree that I will abide by my obligations to maintain the confidentiality of Confidential Information, which are set forth in the August 2021 offer letter provided to me. 2, Non-competition: I acknowledge and agree that, during my employment with the Company and for a one-year period following the termination of that employment relationship, I will not directly or indirectly Compete with the Company in its business, or in any business similar to that of the Company, where the Company does business. 3. Non-solicitation; Non-interference: I acknowledge and agree that J will abide by the non-solicitation obligations set forth in the August 2021 offer letter provided to me. In addition, while employed by Company, and for a one (1) year period following termination of my employment with the Company, I will not: a. directly or indirectly solicit or induce any Customer, prospective Customer, or other Person having a business relationship with Company to terminate or otherwise alter such relationship with the Company, or directly or indirectly interfere in any other manner with the relationship the Company has with any Customer, prospective Customer, or other such Person; and/or b. directly or indirectly refer any actual or potential business from any Customer or prospective Customer to any other business, enterprise or Person. c. call upon, communicate with, or enter into any business relationship with any Customer or prospective Customer for the purpose of obtaining business or developing business relationships. Id., Ex. 1. The Agreement also contains a forum selection clause that designates the Southern District of New York as the sole venue for all disputes “arising out of or relating to this Agreement or its subject matter” and identifies New York law as the substantive law governing such disputes. [d., Ex. 1.

Aquino was employed by Cartiga for more than two years. Jd 428. As of her voluntary separation from the company in January 2024, Aquino served as “Head of National Sales and Marketing.” Jd, 932. In that role, Aquino “led Cartiga’s nationwide business development function” and “oversaw the development and pursuit of leads for consumer legal funding and law firm opportunities for Cartiga in all jurisdictions in which Cartiga does business.” Id. (capitalization altered). The AC alleges that, by virtue of her position at Cartiga, Aquino had

access to confidential information including “electronic files, systems, and databases, which contain confidential and proprietary important information regarding Cartiga’s customers and its key relationships, and Cartiga’s analytics of those customers and key relationships.” Jd. {| 42 (capitalization altered). The AC alleges that the following were not publicly available and constituted trade secrets of Cartiga: “the identity of particular referral sources at any given business relationship,” “the identity of Cartiga’s clients who obtain more funding than other clients,” “Cartiga’s strategic plans for accessing, obtaining, and retaining those clients and relationships,” and “client lists [and] the rates offered to clients.” Jd. {] 59-61. The AC alleges that in the weeks before and after her separation, Aquino engaged in conduct violating the restrictive covenants in her agreement. /d. § 47. It claims that Aquino “actively” solicited current and prospective clients and their referral sources, encouraged those clients to sever their relationships with Cartiga, and sought to retain those clients for herself. Id. Ff 49-53, 70, 104. It alleges that Aquino is “disclosing and using Cartiga’s trade secrets” and that she “made a concerted effort to acquire and aggregate, and subsequently absconded with, the identities of key referral sources and clients of Cartiga.” Jd. 70, 17 (cleaned up). It alleges that “[Aquino’s] conduct resulted in the severance of Cartiga’s prospective business relationships

with Cartiga’s current and prospective clients and relationships.” Jd. {| 126 (capitalization altered}. B. Procedural History On February 12, 2024, Cartiga filed the Complaint. Dkt. 1, It brings a federal claim for misappropriation of trade secrets under the DTSA. It also brings state-law claims for breach of contract, tortious interference with prospective economic advantage, and breach of fiduciary duty.

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Cartiga, LLC v. Aquino, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cartiga-llc-v-aquino-nysd-2025.