Tenth Circuit Affirms Summary Judgment On Trade Secret Claims In Double Eagle v. Hooper

The Tenth Circuit recently upheld an Oklahoma District Court's summary judgment ruling in favor of a trade secret defendant based on insufficient specificity as to the trade secrets at issue, as well as a lack of proper secrecy over those alleged trade secrets. The case, styled as Double Eagle Alloys, Inc. v. Hooper, included claims under the Defend Trade Secrets Act (DTSA), Oklahoma Uniform Trade Secrets Act (OUTSA), common law misappropriation, and civil conspiracy.

The Double Eagle plaintiff alleged that its former employee took sensitive files from the company when he left, including product quality specifications, pricing data, and customer drawings. The district court found that the plaintiff did not prove its materials warranted trade secret protection, including because it did not sufficiently differentiate protected from unprotected information. The court dismissed the common law misappropriation claim for lack of evidence of secrecy, and the civil