Art of Living Foundation v. Does 1-10

Trade secret infringement is possible even when materials are widely distributed if the methods for compiling those materials are not.

The Art of Living Foundation (“AOLF”), founded by “His Holiness Sri Sri Ravi Shankar” (“Shankar”), offered fee based, educational courses. Two bloggers, using the pseudonyms “Skywalker” and “Klim,” had posted criticisms of Shankar’s methods, and included in their posts manuals only distributed to teachers of the method. AOLF claimed that the materials published were trade secrets, and that their revenue had decreased as a result of the manuals being posted. The court determined that there was an independent economic value, since even though the teachings were available to the public, the teacher training materials were not. The court further determined that AOLF had made the necessary efforts to keep the teacher training materials a secret. The free exercise clause did not cause the trade secrets to be dismissed. The second special motion to strike the trade secret claim was GRANTED as to Defendant Klim, and DENIED as to Skywalker.