Language Line Services, Inc._v._Language Services Associates, Inc.

The Uniform Trade Secrets Act preempts all common law claims that are based on the same nucleus of facts as the claims of misappropriation and conversion.

Opinion (Seeborg): Language Line Services (“LLS”) contended that its former employees took confidential trade secret information to their new employer company, Language Services Associates (“LSA”). The trade secret information at issue is a product line offered by both companies. Both individual employees worked for LLS in positions that allowed them access to LLS data. Two years after their employment by LSA raised concerns over their possible use of LLS information, LLS filed a claim for misappropriation of trade secrets. The defendant employees moved for a partial summary judgment on LLS’s claim of conversion and misappropriation of trade secret information on the grounds that the question of whether the information at issue was a trade secret and thus misappropriate is preempted, preventing the Court from deciding that issue. The Court found that the California Uniform Trade Secrets Act (CUTSA) preempts all common law claims that arise from the same nucleus of facts as the misappropriation of trade secrets. Because the Court found that LLS twice alleged the same facts in support of its conversion claim and its CUTSA claim, it GRANTED defendant’s motion for partial summary judgment on the issue of conversion.