9th Circuit Clarifies Trade Secret Disclosure Requirements Under The DTSA

The Ninth Circuit recently held that the Defend Trade Secrets Act ("DTSA") does not require plaintiffs to identify their allegedly misappropriate trade secrets with reasonable particularity at the outset of discovery—much unlike the California Uniform Trade Secrets Act ("CUTSA"). Quintara Biosciences, Inc. v. Ruifeng Biztech, Inc., No. 23-16093 (Aug. 12, 2025). Rather, the DTSA's requirement that a plaintiff identify trade secrets with "sufficient particularity" is a question of fact to be determined at summary judgment or trial.

Background

Plaintiff Quintara Biosciences, Inc. ("Quintara"), a California DNA-sequencing company, sued Defendant Ruifeng Biztech, Inc. ("Ruifeng") for misappropriation of trade secrets, alleging the theft of customer and vendor databases, marketing plans, software code, and proprietary technologies. Quintara asserted claims solely under the DTSA, and did not assert any CUTSA claims. Shortly after the parties' initial