Beane v. Mii Technologies, LLC
Case #: 08-cv-236-JL
Full Text Opinion: http://docs.justia.com/cases/federal/district-courts/new-hampshire/nhdce/1:2008cv00236/32415/99/0.pdf?1330712612
Trade Secrets: An assertion that all information ever created amounts to a trade secret does not satisfy the requirements of the Uniform Trade Secret Act.
Opinion (Laplante): Alan and Glenn L. Beane formed a limited liability company in 1995 called Mii Technologies, LLC (“Mii”). Glenn later departed from Mii. Glenn brought suit against Alan seeking a declaration that his membership in Mii ended on February 4, 2004. Alan responded with a counterclaim, which grew to 21 counts. Alan alleged, among other claims, misappropriation of trade secrets. Alan’s amended counterclaim, as well as Alan’s summary judgment memorandum, asserted that every piece of information created by Mii qualifies as a trade secret. Such a broad assertion did not satisfy the narrower protections of the Uniform Trade Secrets Act. Therefore, the court GRANTED Glenn’s motion for summary judgment on Alan’s claim for misappropriation of trade secrets.