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AUA Private Equity Partners, LLC v. Soto

2018 WL 1684339 Slip Opinion) (2018)

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AUA Private Equity Partners, LLC v. Soto

United States District Court for the Southern District of New York
2018 WL 1684339 Slip Opinion) (2018)

  • Written by Tammy Boggs, JD

Facts

Astrid Soto (defendant) was employed as the vice president of business development and investor relations at AUA Private Equity Partners, LLC (AUA) (plaintiff). Soto agreed to abide by the company’s confidentiality and information-technology policies, which prohibited the downloading or transferring of computer files to personal devices or in an unauthorized manner. The use of unsanctioned cloud-based storage was explicitly prohibited. Soto was given access to AUA’s confidential information and trade secrets during her employment for purposes of performing her job, and she was restricted from disclosing the company’s confidential information. Nevertheless, the Friday before Soto was terminated, she uploaded AUA’s files containing proprietary and trade-secret information from her work laptop to a personal, cloud-based storage service, Google Drive. Soto then deleted the local files from her laptop as well as her browser history. The following Monday, Soto was terminated from employment. Thereafter, Soto refused to return the company’s files stored in her Google Drive account. AUA sued Soto, alleging a violation of the federal Defend Trade Secrets Act (DTSA). Soto moved to dismiss the DTSA claim, arguing that AUA had not properly pleaded a violation.

Rule of Law

Issue

Holding and Reasoning (Woods, J.)

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