Vesta Corp. v. Amdocs Management
United States District Court for the District of Oregon
2018 WL 4354301 (2018)

- Written by Rich Walter, JD
Facts
Both Vesta Corporation (plaintiff) and Amdocs Management, Ltd. (Amdocs) (defendant) engaged in enterprises related to electronic-fund transfers. Over the years, the two companies held several talks to explore collaborative opportunities. Vesta and Amdocs signed an ambiguously worded nondisclosure agreement (NDA) to protect the confidentiality of the proprietary technical and financial information they exchanged in connection with those discussions. None of the discussions came to fruition. Vesta became convinced that Amdocs was misusing the information Vesta had divulged during the failed negotiations and sued Amdocs in federal court for trade-secret misappropriation. The preliminary evidence indicated that Vesta occasionally lapsed in adhering to its policy of imposing and enforcing NDAs against third parties to whom Vesta disclosed proprietary information. Amdocs moved for summary judgment, arguing that in light of those lapses, Vesta had failed to prove that it took reasonable efforts to maintain the confidentiality of either Vesta’s technical trade secrets or Vesta’s financial trade secrets. Vesta downplayed the gravity of the lapses, explaining that (1) most lapses were occasioned by business necessity; (2) the recipients of Vesta’s information knew it was to be kept confidential; (3) the information divulged on these occasions was generalized; and (4) Vesta took other measures to control the disclosure of proprietary information, for example by compartmentalizing sensitive information and marking it as confidential.
Rule of Law
Issue
Holding and Reasoning (Hernández, J.)
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