Trigo ADR Americas, LLC v. OEM Logistics, LLC

CourtDistrict Court, S.D. California
DecidedJanuary 23, 2025
Docket3:23-cv-02219
StatusUnknown

This text of Trigo ADR Americas, LLC v. OEM Logistics, LLC (Trigo ADR Americas, LLC v. OEM Logistics, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trigo ADR Americas, LLC v. OEM Logistics, LLC, (S.D. Cal. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF CALIFORNIA 3 TRIGO ADR AMERICAS, LLC, Case No.: 23-cv-2219-AGS-MMP 4 Plaintiff, ORDER GRANTING IN PART 5 v. MOTION TO DISMISS (ECF 8)

6 OEM LOGISTICS, LLC, et al., 7 Defendants. 8 9 In its motion to dismiss, the defense argues that plaintiff fails to state a claim of 10 trade-secret misappropriation and that many causes of action are preempted. The Court 11 agrees that five of the state-law claims are preempted. 12 BACKGROUND 13 Plaintiff TRIGO ADR Americas, LLC, is in the business of helping aerospace 14 manufacturers timely fulfill their government contracts, sometimes worth “billions of 15 dollars.” (See ECF 6, at 2–3.) Specifically, TRIGO manages third-party suppliers for these 16 contracts to “ensure on-time and on-quality delivery.” (See id.) To that end, TRIGO 17 developed both a proprietary process for vetting suppliers and an “intranet-based tool” that 18 calculates the resources needed to manage each supplier. (Id. at 6–7.) 19 After leaving TRIGO’s predecessor, defendants Steve Clarke and Jay Nicholas 20 founded a competitor company, defendant OEM Logistics, LLC. (ECF 6, at 12.) TRIGO 21 alleges that Clarke and Nicholas took “shortcuts to entering the market” and to “competing 22 with TRIGO” by hiring two of TRIGO’s former employees to obtain TRIGO’s trade 23 secrets. (Id.) That is, while still at TRIGO, those employees—defendants Eric Adler and 24 Michael Thomson—purportedly connected personal USB drives to their work computers 25 to download confidential trade-secret material, which they “copied,” “diverted,” and 26 ultimately delivered to OEM. (Id. at 3, 13.) TRIGO contends there is no “legitimate 27 business purpose at TRIGO ADR for any employee to use USB devices even minimally, 28 and certainly not rampantly.” (Id. at 14.) Thereafter, according to the amended complaint, 1 defendants “used TRIGO ADR’s proprietary vetting process, its confidential set of criteria, 2 guidelines, and factors to place suppliers in various tiers based on risk level, and its internal 3 intranet-based tool zone analysis.” (Id. at 23.) 4 TRIGO sued defendants for trade-secret misappropriation under both federal and 5 California law, in addition to various state-law claims. (ECF 6, at 24–29.) Defendants 6 move to dismiss all causes of action. (See generally ECF 8.) 7 DISCUSSION 8 MOTION TO DISMISS 9 “To survive a motion to dismiss for failure to state a claim, a complaint must contain 10 sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its 11 face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 12 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual 13 content that allows the court to draw the reasonable inference that the defendant is liable 14 for the misconduct alleged.” Id. Mere “conclusory allegations of law and unwarranted 15 inferences are insufficient to defeat a motion to dismiss.” Adams v. Johnson, 355 F.3d 16 1179, 1183 (9th Cir. 2004). The Court must accept “the factual allegations” in the first 17 amended complaint “as true” and construe them “in the light most favorable” to the 18 nonmovant. See GP Vincent II v. Estate of Beard, 68 F.4th 508, 514 (9th Cir. 2023). 19 A. Trade-Secret Misappropriation 20 When a party charges both federal and California trade-secret misappropriation, 21 courts analyze them “together because the elements are substantially similar.” InteliClear, 22 LLC v. ETC Glob. Holdings, Inc., 978 F.3d 653, 657 (9th Cir. 2020). A plaintiff states a 23 claim for trade-secret misappropriation by alleging that “(1) the plaintiff owned a trade 24 secret; (2) the defendant misappropriated the trade secret; and (3) the defendant’s actions 25 damaged the plaintiff.” Space Data Corp. v. X, No. 16-cv-03260-BLF, 2017 WL 5013363, 26 at *2 (N.D. Cal. Feb. 16, 2017) (citation omitted); see also Cal. Civ. Code § 3426.1(b); 27 18 U.S.C. § 1839(5). Defendants only contest the second element. 28 1 1. Clarke, Nicholas, and OEM 2 According to the defense, TRIGO alleges only “six neutral facts” that do not provide 3 even an “inference” of trade-secret misappropriation by OEM or by OEM’s founders, 4 defendants Clarke and Nicholas. (ECF 8, at 16.) The Court disagrees. Among other things, 5 TRIGO alleges that (1) Clarke, Nicholas, and OEM “had access to the secret” vetting 6 process and intranet tool through Adler and Thomson and that (2) TRIGO’s vetting process 7 and intranet tool “share similar features” with OEM’s versions, which is sufficient to plead 8 misappropriation. See Stratienko v. Cordis Corp., 429 F.3d 592, 600 (6th Cir. 2005); see 9 also Fujikura Composite Am., Inc. v. Dee, No. 24-CV-782 JLS (MSB), 2024 WL 3261214, 10 at *12 (S.D. Cal. June 28, 2024) (collecting cases showing that access and similarity are 11 enough to plead misappropriation). 12 This conclusion is bolstered by the alleged suspicious timing. According to the 13 complaint, after TRIGO’s Adler and Thomson left for OEM, OEM’s similar vetting system 14 appeared. See Arthur J. Gallagher & Co. v. Tarantino, 498 F. Supp. 3d 1155, 1172 15 (N.D. Cal. 2020) (holding that misappropriation allegations were “sufficient” when 16 defendants “emailed trade secrets to their personal email accounts in the two- to 17 three-month period before they resigned” and the emails pertained to “at least some” clients 18 who also left for the new firm). Because both Clarke and Nicholas “formerly worked as 19 high-level executives” for TRIGO’s predecessor company (ECF 6, at 3), when they 20 accessed “TRIGO ADR’s trade secrets regularly” (id. at 9), they plausibly knew or had 21 “reason to know” that OEM’s new system was derived from TRIGO’s trade secrets, see 22 Alta Devices, 343 F. Supp. at 877. Taken together, these allegations pass the “low bar” to 23 state a claim at the pleading stage. See Iqbal, 556 U.S. at 678. 24 2. Adler and Thomson 25 The allegations against Adler and Thomson are likewise sufficient. These defendants 26 purportedly had access to TRIGO’s trade-secret vetting process, and shortly thereafter their 27 new employer allegedly created a substantially similar process. As discussed above, these 28 1 circumstances plausibly state a claim of trade-secret misappropriation. See Stratienko, 2 429 F.3d at 600. 3 In their motion to dismiss, Adler and Thomson don’t wrestle with these “access” and 4 “similarity” points, but instead focus primarily on innocent explanations for their use of 5 USB drives at TRIGO. For example, they contend that their admitted use of USB drives 6 “predated any engagement with OEM” and was not suspicious, because they “needed to 7 access files [at TRIGO] to perform their jobs.” (ECF 8, at 19.) Perhaps they are right, but 8 this argument directly contradicts the complaint, which states: “There is not a legitimate 9 business purpose at TRIGO ADR for any employee to use USB devices even 10 minimally . . . .” (ECF 6, at 13.) At this stage, the Court “must accept as true all of the 11 [factual] allegations” in the complaint. Iqbal, 556 U.S. at 678. The defense cannot prevail 12 on a motion to dismiss by merely championing contrary facts.

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Trigo ADR Americas, LLC v. OEM Logistics, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trigo-adr-americas-llc-v-oem-logistics-llc-casd-2025.