SunPower Corp. v. SolarCity Corp.

2012 WL 6160472 (2012)

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SunPower Corp. v. SolarCity Corp.

United States District Court for the Northern District of California
2012 WL 6160472 (2012)

Facts

SunPower Corp. (plaintiff) manufactured and distributed solar panels and related equipment. SunPower employed a group of individual sales agents (the agents) (defendants) who signed nondisclosure agreements. Thereafter, SolarCity Corp. (defendant) recruited the agents to work for SolarCity. After the agents left SunPower’s employment, SunPower discovered that each of them had used email and/or electronic devices to store and take SunPower’s computer files shortly before ending their employment. The computer files included sales and marketing information. SunPower believed that the agents had delivered the files to SolarCity and were using the data for the benefit of SolarCity. SunPower sued SolarCity and the agents, asserting numerous causes of action. One cause of action was for violating California’s Uniform Trade Secrets Act (UTSA) (the trade-secret claim). Other causes of action related to the alleged misappropriation of non-trade-secret, “proprietary information,” e.g., conversion, unfair competition, and trespass to chattels (collectively, the non-trade-secret claims). SunPower’s claims were all based on the same conduct—the agents’ taking of computer files—without further specification. SolarCity and the agents filed a motion to dismiss the non-trade-secret claims.

Rule of Law

Issue

Holding and Reasoning (Koh, J.)

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