RACOM CORPORATION, a Delaware corporation, and EASTERN COMMUNICATIONS, LTD., LLC, a New York limited liability company v. DEA INCORPORATED d/b/a FRONTLINE COMMUNICATIONS SYSTEMS, a Washington corporation, and STEVE MCLAUGHLIN, an individual

CourtDistrict Court, E.D. Washington
DecidedMay 12, 2026
Docket2:25-cv-00312
StatusUnknown

This text of RACOM CORPORATION, a Delaware corporation, and EASTERN COMMUNICATIONS, LTD., LLC, a New York limited liability company v. DEA INCORPORATED d/b/a FRONTLINE COMMUNICATIONS SYSTEMS, a Washington corporation, and STEVE MCLAUGHLIN, an individual (RACOM CORPORATION, a Delaware corporation, and EASTERN COMMUNICATIONS, LTD., LLC, a New York limited liability company v. DEA INCORPORATED d/b/a FRONTLINE COMMUNICATIONS SYSTEMS, a Washington corporation, and STEVE MCLAUGHLIN, an individual) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
RACOM CORPORATION, a Delaware corporation, and EASTERN COMMUNICATIONS, LTD., LLC, a New York limited liability company v. DEA INCORPORATED d/b/a FRONTLINE COMMUNICATIONS SYSTEMS, a Washington corporation, and STEVE MCLAUGHLIN, an individual, (E.D. Wash. 2026).

Opinion

1 2

3 U.S. F D IL IS E T D R I I N C T T H C E O URT EASTERN DISTRICT OF WASHINGTON 4 May 12, 2026 SEAN F. MCAVOY, CLERK 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF WASHINGTON 7 RACOM CORPORATION, a Delaware No. 2:25-CV-0312-MKD corporation, and EASTERN 8 COMMUNICATIONS, LTD., LLC, a ORDER GRANTING PLAINTIFFS’ New York limited liability company, MOTION TO DISMISS 9 COUNTERCLAIMS Plaintiffs, 10 ECF No. 22 v. 11 DEA INCORPORATED d/b/a 12 FRONTLINE COMMUNICATIONS SYSTEMS, a Washington corporation, 13 and STEVE MCLAUGHLIN, an individual, 14 Defendants. 15 Before the Court is Plaintiffs’ Motion to Dismiss Frontline’s Counterclaims. 16 ECF No. 22. On February 25, 2026, the Court held a hearing on the motion. ECF 17 No. 36. Andrew W. Gust represented Plaintiffs. Bryce J. Wilcox, Nicholas C. 18 Briggs, and William Gregory Lockwood represented Defendants. The Court has 19 considered the briefing and the record, heard from counsel, and is fully informed. 20 For the reasons below, the Court grants the motion. 1 BACKGROUND 2 Plaintiffs assert the following claims: (1) Misappropriation of Trade Secrets

3 under the Defend Trade Secrets Act, 18 U.S.C. § 1836; (2) Misappropriation of 4 Trade Secrets under the Uniform Trade Secrets Act, RCW 19.108; and (3) Tortious 5 Interference with Business Relationships and Expectancies. ECF No. 1 at 13, 15,

6 17. Plaintiffs allege that Defendant Steve McLaughlin is a former RACOM 7 employee who resigned in November 2023. ECF No. 1 at 4. After leaving 8 RACOM, Defendant McLaughlin began working for Frontline, a competing 9 company, as a division manager. Id. at 5. Both RACOM and Frontline offer the

10 same type of emergency communication equipment and installations in the same 11 region. Id. at 5. RACOM alleges that McLaughlin’s actively solicited RACOM 12 customers and current employees to join Frontline. Id. Further, RACOM alleges

13 that McLaughlin used proprietary customer lists and pricing data to solicit 14 RACOM customers and gain improper access to customer-specific communication 15 system design plans and notes. Id. at 2, 5. 16 Defendants raise two counterclaims: 1) Tortious Interference with

17 Prospective Business Advantage; and 2) Violation of Washington’s Consumer 18 Protection Act (“CPA”). ECF No. 14 at 15-25. Defendants assert that upon the 19 departure of another former RACOM employee, Lee Copple, RACOM

20 intentionally used outdated quote forms bearing Mr. Copple’s name when 1 engaging in business with customers. Id. at 20-21. Defendants allege that those 2 customers became Frontline customers upon learning that Mr. Copple was no

3 longer employed at RACOM and was now at Frontline. Id. at 21. Plaintiffs 4 moved to dismiss both counterclaims. ECF No. 22. 5 LEGAL STANDARD

6 To survive a Rule 12(b)(6) motion to dismiss, a complaint must contain 7 sufficient factual matter, accepted as true, to “state a claim to relief that is plausible 8 on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. 9 Twombly, 550 U.S. 544, 547 (2007)). In considering a motion to dismiss for

10 failure to state a claim, the Court must accept as true the well-pleaded factual 11 allegations and any reasonable inference to be drawn from them, but legal 12 conclusions are not entitled to the same assumption of truth. Id. “Threadbare

13 recitals of the elements of a cause of action, supported by mere conclusory 14 statements, do not suffice.” Id. (citing Twombly, 550 U.S. at 555). “[O]nly a 15 complaint that states a plausible claim for relief survives a motion to dismiss.” Id. 16 at 679 (citing Twombly, 550 U.S. at 556). A complaint must contain either direct

17 or inferential allegations respecting all the material elements necessary to sustain 18 recovery under some viable legal theory. Twombly, 550 U.S. at 562. “Factual 19 allegations must be enough to raise a right to relief above the speculative level[.]”

20 Twombly, 550 U.S. at 555. 1 DISCUSSION 2 Plaintiffs argue that Defendants’ counterclaims should be dismissed because

3 Defendants fail to adequately plead the required elements for intentional 4 interference with a prospective business expectancy or a CPA violation. ECF No. 5 22 at 5.

6 A. Tortious Interference 7 Under Washington law, a party claiming tortious interference with a 8 business expectancy must prove (1) the existence of a valid expectancy, (2) the 9 party’s knowledge of the relationship, (3) intentional interference inducing or

10 causing a termination of this business expectancy, (4) that the party interfered for 11 an improper purpose or used improper means, and (5) resultant damage. Pac. Nw. 12 Shooting Park Ass’n v. City of Sequim, 144 P.3d 276, 280 (Wash. 2006). Plaintiffs

13 argue that Defendants have failed to plead the existence of a valid business 14 expectancy, Plaintiffs’ knowledge of the expectancy, intentional interference, or 15 injury to Defendants. ECF No. 22 at 6-10. The Court considers each argued 16 element in turn.

17 1. Existence of Valid Expectancy 18 Plaintiffs argue that Defendants do not plead a valid business expectancy 19 because they did not “allege a prospective business relationship between

20 [Frontline] and any identifiable third party or parties.” ECF No. 22 at 6. 1 Defendants assert that they alleged a valid business expectancy “by claiming the 2 existence of a prospective contractual relationship of pecuniary value with

3 Plaintiffs’ customers who did not do business with Frontline” because Plaintiffs 4 asserted they still employed Mr. Copple. ECF No. 23 at 9. 5 “To establish a valid business expectancy, courts require something less than

6 an enforceable contract.” Greensun Group, LLC v. City of Bellevue, 436 P.3d 397, 7 405 (Wash. App. 2019). “A valid business expectancy includes any prospective 8 contractual or business relationship that would be of pecuniary value.” Id. 9 “Washington courts require [the party] to show only that its future business

10 opportunities are a reasonable expectation and not merely wishful thinking.” Id. 11 Defendants allege that: 12 RACOM’s intentional or negligent misrepresentation that it employed Mr. Copple after his employment ended created a 13 false impression that Mr. Copple was still providing services on behalf of RACOM rather than RACOM’s competitor Frontline. 14 This unreasonably and unjustifiably interfered with business opportunities Frontline could reasonably have expected to 15 obtain after it hired Mr. Copple. 16 ECF No. 14 at 22. Beyond merely stating that their expectation was reasonable, Defendants 17 have not alleged that they had a reasonable expectation of obtaining certain 18 business opportunities. Defendants have not alleged that the prospective business 19 relationship was anything more than wishful thinking. Accordingly, Defendants 20 1 have not adequately pleaded existence of a valid expectancy. 2 2. Knowledge of Business Expectancy

3 Defendants assert that they adequately alleged knowledge because Plaintiffs 4 are direct competitors in the same marketplace as Defendants. ECF No. 23 at 11. 5 Knowledge of a business expectancy “requires the [party] to have known of the

6 [claimant’s] business expectancy.” Greensun Group, LLC, 436 P.3d at 406.

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RACOM CORPORATION, a Delaware corporation, and EASTERN COMMUNICATIONS, LTD., LLC, a New York limited liability company v. DEA INCORPORATED d/b/a FRONTLINE COMMUNICATIONS SYSTEMS, a Washington corporation, and STEVE MCLAUGHLIN, an individual, Counsel Stack Legal Research, https://law.counselstack.com/opinion/racom-corporation-a-delaware-corporation-and-eastern-communications-waed-2026.