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ARTICLE · 01 JULY 2022

Lit Alerts—June 2022

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The Delaware Superior Court held in June 2022 that Utah's Uniform Trade Secrets Act (UTSA) preempted tortious interference with contractual relations claims based on the same set of facts as a UTSA claim.

United StatesIntellectual Property

Trade Secrets: UTSA Preempts Tort Claims Based on Same Factual Allegations

The Delaware Superior Court held in June 2022 that Utah's Uniform Trade Secrets Act (UTSA) preempted tortious interference with contractual relations claims based on the same set of facts as a UTSA claim. In Pascal Metrics, Inc. v. Health Catalyst, Inc., Pascal alleged it developed algorithm-based products to detect health events. Pascal required all employees to sign confidentiality agreements to protect this technology. After Health Catalyst hired three Pascal employees, Pascal filed suit for misappropriation of trade secrets and tortious interference with contractual relations. Health Catalyst moved to dismiss the tortious interference claim arguing it was preempted by the UTSA. 

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