Unox, Inc. v. Conway

2019 NCBC 40
CourtNorth Carolina Business Court
DecidedJune 28, 2019
Docket19-CVS-1331
StatusPublished

This text of 2019 NCBC 40 (Unox, Inc. v. Conway) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Unox, Inc. v. Conway, 2019 NCBC 40 (N.C. Super. Ct. 2019).

Opinion

UNOX, Inc. v. Conway, 2019 NCBC 40.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION GASTON COUNTY 19 CVS 1331

UNOX, INC.,

Plaintiff,

v. ORDER AND OPINION ON PLAINTIFF’S OPPOSITION TO MICHAEL CONWAY; JAMES DESIGNATION EMMERSON; TECNOEKA, INC.; and TECNOEKA, S.R.L.,

Defendants.

1. THIS MATTER is before the Court on Plaintiff UNOX, Inc.’s (“UNOX”)

Opposition to Mandatory Complex Business Case Designation and Motion to Vacate

Order of Designation (“Opposition”). (Pl. UNOX, Inc.’s Opp’n Mandatory Complex

Business Case Designation & Mot. Vacate Order Designation [hereinafter “Opp’n”],

ECF No. 9; see also Pl. UNOX, Inc.’s Br. Opp’n Mandatory Complex Business Case

Designation & Supp. Mot. Vacate Order Designation [hereinafter “Opp’n Br.”], ECF

No. 10.) For the reasons set forth below, the Court ALLOWS the Opposition.

Gray, Layton, Kersh, Solomon, Furr, & Smith, P.A., by William E. Moore, Jr. and Christopher M. Whelchel, for Plaintiff UNOX, Inc.

Bryan Cave Leighton Paisner LLP, by Benjamin F. Sidbury, for Defendants Tecnoeka, Inc. and Tecnoeka, S.R.L.

Marcellino & Tyson PLLC, by Clay Campbell, for Defendants Michael Conway and James Emmerson.

Bledsoe, Chief Judge.

2. This case arises out of a dispute between UNOX and its former employees,

Michael Conway (“Conway”) and James Emmerson (“Emmerson”). UNOX supplies ovens for the food service industry. In late 2018, Conway and Emmerson defected

and opened an American subsidiary of UNOX’s Italian competitor, Tecnoeka, S.R.L.,

known as Tecnoeka, Inc. (together, the “Tecnoeka Defendants”). UNOX now believes

that Conway and Emmerson took its confidential information in breach of

non-disclosure agreements and gave that information to their new employer to gain

an unfair competitive advantage.

3. UNOX initiated this action on April 3, 2019, asserting claims for breach of

contract, breach of the implied covenant of good faith and fair dealing, breach of

fiduciary duty, constructive fraud, and fraud against Conway and Emmerson; for

tortious interference with contract against the Tecnoeka Defendants; and for tortious

interference with prospective economic advantage, violation of the North Carolina

Unfair and Deceptive Trade Practices Act, civil conspiracy and facilitating fraud,

aiding and abetting, and punitive damages against all Defendants. The Complaint

also requests preliminary and permanent injunctive relief. (See Compl., ECF No. 3.)

4. The Tecnoeka Defendants timely filed a Notice of Designation on May 2,

2019. (Notice Designation Mandatory Complex Business Case [hereinafter “NOD”],

ECF No. 7.) They asserted that designation as a mandatory complex business case

would be proper because this action raises material issues related to disputes

involving antitrust law and trade secrets under N.C. Gen. Stat. §§ 7A-45.4(a)(3) and

(8). (NOD 1–2.)

5. Based on the Notice of Designation, this case was designated as a complex

business case by the Chief Justice of the Supreme Court of North Carolina on May 3, 2019, (Designation Order, ECF No. 1), and assigned by the undersigned to the

Honorable Adam M. Conrad on the same day, (Assignment Order, ECF No. 2).

6. UNOX timely filed the Opposition on May 31, 2019, contending that the

designation was not proper because its claims do not involve antitrust law or trade

secrets. (Opp’n 2.) The Tecnoeka Defendants filed their Response to the Opposition

on June 5, 2019. (Defs.’ Resp. Pl.’s Opp’n Mandatory Complex Business Case

Designation [hereinafter “Resp.”], ECF No. 15.) This matter is now ripe for

determination.

7. “For a case to be [designated] as a mandatory complex business case, the

pleading upon which designation is based must raise a material issue that falls within

one of the categories specified in section 7A-45.4.” Composite Fabrics of Am., LLC v.

Edge Structural Composites, Inc., 2016 NCBC LEXIS 11, at *25 (N.C. Super. Ct. Feb.

5, 2016). “The inquiry of whether a case involves the requisite disputes falling

with[in] the statutory requirements has not been historically confined to the actual

causes of action asserted in a complaint[] but has also examined the underlying

factual allegations.” Cornerstone Health Care, P.A. v. Moore, 2015 NCBC LEXIS 65,

at *7 (N.C. Super. Ct. June 22, 2015).

8. The Court begins with section 7A-45.4(a)(8), which permits designation of

cases raising a material issue related to “[d]isputes involving trade secrets, including

disputes arising under Article 24 of Chapter 66 of the General Statutes.” The classic

example of a dispute involving trade secrets is one for misappropriation of trade

secrets. See N.C. Gen. Stat. § 66-153. On occasion, this Court has held that section 7A-45.4(a)(8) also reaches other types of claims, including contract claims, when the

complaint puts the existence, ownership, or misuse of alleged trade secrets squarely

in dispute. See Union Corrugating Co. v. Viechnicki, No. 14 CVS 6240, Order Opp’n

Designation Action Mandatory Complex Business Case (N.C. Super. Ct. Sept. 9, 2014)

(unpublished). But the Court has never construed the statute so broadly as to permit

“designation of an action as a mandatory complex business case based on claims

involving generalized confidential or proprietary information”—a fitting description

of many claims for breach of restrictive covenants in employment agreements.

Cornerstone Health Care, 2015 NCBC LEXIS 65, at *6.

9. UNOX’s claims fall into this final category. UNOX alleges that Conway and

Emmerson were subject to contractual restrictions not to misuse or disclose

confidential and proprietary information and that they breached those restrictions by

taking and using “product designs and materials, customer lists, techniques, business

plans, strategic plans, marketing information and other business and financial

information.” (Compl. ¶ 26; see also Compl. ¶ 13.) UNOX further alleges that all

Defendants engaged in unfair or deceptive trade practices by using the unlawfully

obtained confidential information to gain a competitive advantage. (Compl. ¶ 84.)

10. Although the nondisclosure agreements include “trade secrets” as a category

within the larger definition of UNOX’s confidential or proprietary information,

(Compl. ¶ 7), the Complaint does not purport to assert a claim for trade-secret

misappropriation, nor does it allege that any of UNOX’s information at issue in this

action is subject to trade-secret protection. In the absence of such allegations, the asserted claims appear to be based on the misuse of generalized confidential or

proprietary information. Thus, nothing in the Complaint “suggest[s] that the dispute

will require the Court to resolve material issues involving trade secrets[.]” Stay Alert

Safety Servs., Inc. v. Pratt, 2017 NCBC LEXIS 101, at *5–6 (N.C. Super. Ct. Nov. 1,

2017).

11. The Tecnoeka Defendants insist that this is not a garden-variety dispute

about a restrictive covenant in an employment agreement. They contend that UNOX

drafted its claim under N.C. Gen. Stat. § 75-1.1 to include a freestanding claim for

misappropriation of confidential information that is identical to a claim for

misappropriation of trade secrets, other than carefully replacing “trade secrets” with

“confidential and proprietary information.” (Resp. 1.) In their view, “there is no way

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Related

§ 66-153
North Carolina § 66-153
§ 75-1.1
North Carolina § 75-1.1
§ 7A-45.4
North Carolina § 7A-45.4(a)(3)

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2019 NCBC 40, Counsel Stack Legal Research, https://law.counselstack.com/opinion/unox-inc-v-conway-ncbizct-2019.