Oakwood Laboratories LLC v. Thanoo

Dr. Bagavathikanun Thanoo (defendant) worked at Oakwood Laboratories, L.L.C. (Oakwood) (plaintiff), where his primary focus was on microsphere technology. Oakwood spent nearly 20 years and $130 million developing its microsphere project, which the company made efforts to keep confidential. Thanoo was contacted by Aurobindo Pharma Ltd. (defendant), which expressed an interest in entering the microsphere market. With a possible collaboration in mind, Thanoo sent Aurobindo Pharma a 27-page memo discussing products involved in Oakwood’s microsphere project. Aurobindo Pharma then stated that it was no longer interested in pursuing a business relationship. Months later, an Aurobindo Pharma subsidiary company, Aurobindo Pharma U.S.A., Inc. (defendant), recruited Thanoo as an employee. Thanoo assured Oakwood that he would not disclose his microsphere work with his new employer. However, within months of hiring Thanoo, another Aurobindo subsidiary, AuroMedics Pharma LLC (defendant), began marketing its own microsphere products. Oakwood brought suit for trade-secret misappropriation against Thanoo and the Aurobindo companies in federal district court. The court rejected four versions of Oakwood’s complaint on the ground that it had failed to state a claim—or, more particularly, that Oakwood had failed to adequately identify the trade secrets that it alleged had been misappropriated. Oakwood appealed to the United States Court of Appeals for the Third Circuit.