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Saturn Systems, Inc. v. Militare
Colorado Court of Appeals
252 P.3d 516 (2011)
Delbert Militare (defendant) worked for Saturn Systems, Incorporated (plaintiff), a debt-collection agency, for two years as a sales agent. While working for Saturn Systems, Militare was granted access to a confidential database on Saturn’s website. The database was the result of a significant investment of time and money by Saturn Systems. The database contained extensive, real-time information on clients’ debtor accounts. Only clients and sales agents had access to the database via unique usernames and passwords. Militare joined CB Solutions, LLC, a competitor of Saturn Systems, after his employment with Saturn Systems ended. While working for CB Solutions, Militare visited a client of Saturn Systems with the intent to win its business. Saturn Systems learned of this visit from the client and investigated whether Militare had accessed Saturn Systems’s website without authorization. Saturn Systems found that Militare had accessed 15 client accounts and reviewed a total of 72 privileged and confidential Saturn Systems webpages. Saturn Systems filed an action in the trial court for misappropriation of trade secrets and breach of contract. A bench trial followed. The trial court found Militare liable for misappropriation and entered judgment for Saturn Systems.
Rule of Law
Holding and Reasoning (Loeb, J.)
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