The US Court of Appeals for the Eleventh Circuit once again
remanded a trade secret and copyright dispute involving software
for generating life insurance quotes, finding that the district
court erred by failing to consider the copyrightability of the
source code's arrangement. As to the trade secret claim,
however, the Eleventh Circuit found that the district court did not
err in finding that the defendants misappropriated the trade
secrets at issue and could be held jointly and severally liable,
despite varying levels of culpability. Compulife Software, Inc.
v. Newman, Case No. 21-14074 (11th Cir. Aug. 1, 2024) (Jordan,
Brasher, Abudu, JJ.)
Compulife's software generates life insurance quotes using a
proprietary database of insurance rates. The software produces a
quote by using blocks of code, arranged in a particular manner,
that correspond to different data points such as state, birth
month, birthday, birth year, sex and smoking status. Compulife
licenses its