U.S. Auto Parts Network, Inc. v. Parts Geek, LLC

MEMORANDUM

The district court erred in granting summary judgment to Parts Geek, Thoma-son, Pine, Tinari, Hendershot, and Mann (collectively, the “Parts Geek defendants”) on U.S. Auto Parts’ (USAP) claim for misappropriation of its trade secrets in the Manager software because a jury could reasonably conclude that USAP owned some rights to Manager. Moreover, in its supplemental response to Thomason’s Interrogatory No. 1, USAP identified the key functional components of the Manager software that it claimed to be trade secrets, and thus “describe[d] the subject matter of the trade secret with sufficient particularity.” Imax Corp. v. Cinema Techs., Inc., 152 F.3d 1161, 1164-65 (9th Cir.1998) (quoting Universal Analytics v. MacNeal-Schwendler Corp., 707 F.Supp. 1170, 1177 (C.D.Cal.1989)) (emphasis omitted). We likewise reject Parts Geek’s argument that it cannot be held liable for misappropriation of trade secrets because it had a license to use Admin, given that USAP raised a genuine issue of material fact that Parts Geek had “reason to know” that Thomason acquired the software code in Admin by improper means. Cal. Civ. Code § 3426.1 (b)(1). Further, a jury could reasonably conclude…