In a significant ruling, QUINTARA BIOSCIENCES, INC. V. RUIFENG BIZTECH, INC., No. 23-16093 (9th Cir. 2025), the Ninth Circuit distinguished the federal Defend Trade Secrets Act (“DTSA”) from California’s Uniform Trade Secrets Act (“CUTSA”).
Defendants in trade secret cases frequently invoke CUTSA, CCP Section 2019.210, to stymy discovery until the plaintiff describes the misappropriated trade secrets with “reasonable particularity”. While DTSA does not provide a similar restriction, many Federal District Courts in California have applied the reasonable particularity standard to early discovery disputes and motions to dismiss or strike, especially in cases with both DTSA and CUTSA claims.
Quintara and Biztech are DNA-sequencing-analysis companies that engaged in business together for six years. Things soured and Quintara claimed that Biztech locked Quintara out of its offices, took possession of Quintara’s equipment and hired all of Quintara’s employees. Quintara alleged that Biztech misappropriated trades secrets, including a customer database, customer profiles, its marketing plan, the design of potential new products, a vendor database, software code, customized reagents and protocols, new product designs, and DNA Donor technology.
At the initial discovery conference, and at Biztech’s request with reference to CUTSA, the district court ordered Quintara to provide more details about the trade secrets before discovery could commence....
Four pharmacies in Hudson County agreed to pay more than $4 million to settle claims that they billed federal healthcare programs for medications they never filled, federal prosecutors said. The ph...