Independent Technologies LLC v. Otodata Wireless Network, Inc.

CourtDistrict Court, D. Nevada
DecidedMarch 23, 2020
Docket3:20-cv-00072
StatusUnknown

This text of Independent Technologies LLC v. Otodata Wireless Network, Inc. (Independent Technologies LLC v. Otodata Wireless Network, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Independent Technologies LLC v. Otodata Wireless Network, Inc., (D. Nev. 2020).

Opinion

6 UNITED STATES DISTRICT COURT

7 DISTRICT OF NEVADA

8 INDEPENDENT TECHNOLOGIES, LLC, a 9 Delaware Corporation, d/b/a ANOVA,

3:20-cv-00072-RJC-CLB 10 Plaintiff,

ORDER 11 vs.

12 OTODATA WIRELESS NETWORK, INC., a Quebec, Canada Corporation, et al., 13 Defendants. 14 15 Plaintiff moves this Court to issue a preliminary injunction preventing Defendants from 16 profiting off of its allegedly misappropriated trade secrets. The Court finds that a preliminary 17 injunction is appropriate, and therefore grants the motion. 18 I. FACTS AND PROCEDURAL HISTORY 19 Plaintiff designs, manufactures, and sells remote tank monitoring devices, which affix to a 20 tank and monitor the amount of fuel in it. (ECF No. 3 Ex. 11 at ¶ 4.) Plaintiff asserts that its success 21 relies on “its customer base by maintaining existing customer relationships and bringing in new 22 customers through technological innovation and superior customer service.” (Id. at ¶ 30.) 23 As part of Plaintiff’s sales team, it employed Defendants Steven and Brian Rechenmacher 24 (who are father and son) as sales representatives for the western region of the United States. (ECF 1 No. 3 Ex. 11 at ¶ 6.) Defendants had worked for Plaintiff (and its predecessors in interest) for 2 approximately fifteen years. (Id.) As part of their job responsibilities, Defendants Steven and Brian 3 Rechenmacher were privy to valuable trade secrets including “[Plaintiff’s] current and prospective 4 customers, technology, product deployment strategies, marketing strategies, product trials, and

5 customer profitability information.” (ECF No. 3 Ex. 26 at 2.) 6 To protect this sensitive information, Plaintiff has its employees sign confidentiality 7 agreements. Included in these agreements is the statement that employees “will have access to 8 technical and nontechnical, confidential and proprietary information concerning these activities, 9 including research and development work, new product design and other confidential and 10 proprietary information originating from [Plaintiff]” and that the employee promises “not to utilize 11 any such confidential and proprietary information as described above for [his] own or another’s 12 direct or indirect benefit or to disclose such information to which [he] may have access, outside 13 [Plaintiff] unless [he] is specifically authorized to do so by [Plaintiff’s] officer.” (ECF No. 3 Ex. 14 12 at ¶¶ 2–3.) Additionally, its employee manual categorizes “[d]isclosure of confidential

15 information or trade secrets to unauthorized persons” as a “Major Violation” that “cannot be 16 tolerated” and “may preclude continued employment of an employee.” (ECF No. 3 Ex. 14 at 23.) 17 Plaintiff has presented to the Court a copy of a signed employee confidentiality agreement 18 from Defendant Brian Rechenmacher, (ECF No. 3 Ex. 13), but not one for Defendant Steven 19 Rechenmacher. Additionally, there are no non-compete agreements between the parties. 20 On December 23, 2019, both Defendants Steven and Brian Rechenmacher submitted 21 separate notices of their intent to resign from their positions with Plaintiff. (ECF No. 3 Ex. 11 at 22 ¶ 12.) Following two weeks paid vacation, they each had an exit interview with Plaintiff, where 23 they acknowledged that they intended to abide by their continuing obligations of confidentiality.

24 (Id. at ¶¶ 12–13; ECF No. 3 Ex. 15.) On January 6, 2020, they officially ended their employment 1 with Plaintiff and subsequently began working for Plaintiff’s competitor, Defendant Otodata 2 Wireless Network, Inc. (Otodata), a Canadian corporation. 3 Plaintiff’s computer records show that, in the weeks leading up to their departure, 4 Defendants Steven and Brian Rechenmacher began collecting information from Plaintiff:

5 • Defendant Steven Rechenmacher ran a report of all of Plaintiff’s customers’ information in a printable or downloadable PDF. (ECF No. 3 Ex. 25 at ¶ 4.) 6 • Defendant Steven Rechenmacher forwarded from his employee email address 7 (steve.rechenmacher@anova.com) to a personal email address (steve@advacts.com) information—including a list of clients and potential clients 8 with their contact information. (ECF No. 3 Ex. 11 at ¶ 16, Ex. 18.)

9 • Plaintiff maintained an internal software platform containing detailed non-public information. In a three-week period, Defendant Steven Rechenmacher viewed 10 nearly twice as many pages as he had in the six-year period prior to that time. Defendant Brian Rechenmacher’s logs also show a similar spike in activity. (ECF 11 No. 3 Ex. 26 at 4, Ex. 19.) 12 • Defendant Steven Rechenmacher’s account on Plaintiff’s website was accessed three times from Canada. (ECF No. 3 Ex. 26 at 3.) 13 • On Defendant Steven Rechenmacher’s last day of employment with Plaintiff he 14 forwarded an email from steve.rechenmacher@anova.com to his new Otodata employee email address (srechenmacher@otodatatankmonitors.com) a large 15 volume of information—including sixteen customer deployment reports and sixteen Microsoft Excel files providing the underlying data for the deployment 16 reports. (ECF No. 3 Ex. 26 at 4–5, Ex. 16, Ex. 17.) 17 Two days after Defendants Steven and Brian Rechenmacher officially resigned, Plaintiff 18 began sending cease-and-desist letters to all three Defendants. (ECF No. 3 Ex. 2, Ex. 3, Ex. 6, Ex. 19 8.) The letters alleged misappropriation of trade secrets and detailed some of the evidence above. 20 In the letters, Plaintiff demanded that Defendants deliver a copy of all information in their 21 possession and to also permanently delete any copies. (See, e.g., ECF No. 3 Ex. 2.) 22 In response to this request, the Defendants claim that they have had their computer systems 23 forensically wiped to erase any of Plaintiff’s information from their systems. Defendant Steven 24 Rechenmacher avers that he had another one of his sons perform an erasure of his computer to 1 delete all files related to Plaintiff, shredded all physical copies of Plaintiff’s information, and sent 2 Plaintiff back its personal property on January 11, 2020. (ECF No. 70 Ex. 3 ¶ 35.) Similarly, 3 Defendant Otodata had its computer system forensically examined by Sirco Investigation & 4 Protection (Sirco). Sirco purportedly deleted records from Defendant Otodata’s systems. (See ECF

5 No. 50 Ex. 1 at ¶ 17.) Despite Defendants initially denying possessing a copy of these documents, 6 (Id. at ¶ 19), Sirco retained a sealed copy of the documents, (ECF No. 66 Ex. 1, 14:8–14). 7 Defendants deny any wrongdoing and claim not to possess any of Plaintiff’s confidential 8 information. (ECF No. 3 Ex. 5, Ex. 9; ECF No. 4 Ex. 10.) Defendants Steven and Brian 9 Rechenmacher further claim that they were innocently compiling the data to show Plaintiff’s upper 10 management that they were performing well. (See, e.g., ECF No. 70 Ex. 2 ¶ 4.) 11 On January 24, 2020, Plaintiff learned from an existing client that Defendant Steven 12 Rechenmacher was soliciting the client’s business using insider knowledge—including which of 13 Plaintiff’s models will need to be replaced. (ECF No. 3 Ex. 26 at 5; ECF No. 4 Ex. 24.) Shortly 14 thereafter, Plaintiff brought this suit alleging that Defendants misappropriated their trade secrets

15 under federal and Nevada state law, that Defendants Steven and Brian Rechenmacher breached 16 their fiduciary duties and employment contracts, and that Defendant Otodata aided and abetted the 17 breaches of fiduciary duty. (ECF No. 1.) 18 The Court heard this evidence and found good cause to extend the temporary restraining 19 order until March 23, 2020, where the Court would entertain further evidence from declarations 20 and cross-examinations of witnesses in regard to the motion for preliminary injunction. (ECF No. 21 60.) The Court also ordered the parties to exchange client lists so the Court might be able to tailor 22 any preliminary injunction it issues.

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Independent Technologies LLC v. Otodata Wireless Network, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/independent-technologies-llc-v-otodata-wireless-network-inc-nvd-2020.