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Turret Labs USA, Inc. v. CargoSprint, LLC

Docket 21-0952, U.S. Court of Appeals, Second Circuit (Apr. 16, 2021)
Racketeer/Corrupt Organization (Appeals)
Case Type4470 Racketeer/Corrupt Organization
Tags4470 Racketeer / Corrupt Organization, 4470 Racketeer / Corrupt Organization
Plaintiff - Appellant Turret Labs USA, Inc.
Defendant - Appellee CargoSprint, LLC
Defendant - Appellee Joshua Wolf
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No. 106 SUMMARY ORDER AND JUDGMENT, affirming the judgment of the district court, by DAL, ALK, ECL, ...

Document Turret Labs USA, Inc. v. CargoSprint, LLC, 21-0952, No. 106 (2d Cir. Mar. 9, 2022)
Plaintiff-Appellant Turret Labs USA, Inc. (“Turret Labs”) appeals from the district court’s March 22, 2021 judgment dismissing its second amended complaint (“SAC”) for failure to state a claim pursuant to Federal Rule of Civil Procedure 12(b)(6).
We assume the parties’ familiarity with the underlying facts, the procedural 1 Dock EnRoll is an “air cargo ground handling control application that allows for payment of fees and scheduling of shipments based on synchronized real-time United States Customs release notifications, [and] was the first software of its kind at the time.” SAC ¶ 17.
To survive a motion to dismiss brought under Rule 12(b)(6), a complaint “must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl.
Such “expansive unauthorized access to [Dock EnRoll] and confidential information contained therein allowed [Defendants-Appellees] to reverse engineer the 3 “Freight forwarders” are “the entities that arrange for the storage and shipping of merchandise on behalf of shippers.” SAC ¶ 16.
We agree with the district court that where an alleged trade secret consists “primarily, if not entirely,” of a computer software’s functionality—“functionality that is made apparent to all users of the program”—the reasonableness analysis will often focus on who is given access, and on the importance of confidentiality and nondisclosure agreements to maintaining secrecy.
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