On August 12, 2025, the Ninth Circuit Court of Appeals issued a significant ruling in the case of Quintara Biosciences, Inc. v. Ruifeng Biztech, Inc., determining that the Defend Trade Secrets Act (DTSA) does not obligate plaintiffs to specifically identify misappropriated trade secrets at the pleading stage. This decision contrasts sharply with the requirements established under the California Uniform Trade Secrets Act (CUTSA), which mandates a plaintiff to provide a detailed account of the trade secrets in question before discovery begins.
The implications of this ruling could reshape the landscape for trade secret claims within the Ninth Circuit, affecting how legal teams prepare their cases and how courts manage these disputes.
The District Court’s Initial Ruling
In this case, Quintara Biosciences accused Ruifeng Biztech of misappropriating eleven trade secrets, which included sensitive information such as customer and vendor databases, marketing strategies, and innovative product designs. During the early stages of litigation, the district court required Quintara to present its claims with “reasonable particularity.” This involved detailing the independent economic value of the trade secrets, explaining the measures taken to keep them confidential, and listing specific elements akin to what would be expected in a patent claim.
Dissatisfied with the information provided, Ruifeng filed a motion to strike, arguing that Quintara’s disclosures were insufficient. The district court sided with Ruifeng, striking nine of the eleven trade secrets from consideration, which effectively dismissed them as a sanction for non-compliance with its disclosure requirement. The court had relied on section 2019.210 of CUTSA, emphasizing that such detailed disclosures are crucial for defining the scope of discovery and ensuring fair notice for the defendant.
Ninth Circuit’s Reversal and Broader Implications
The Ninth Circuit’s decision reversed the district court’s ruling, clarifying that while CUTSA necessitates a degree of disclosure before discovery, the DTSA does not impose a similar burden. Instead, the court stated that whether a plaintiff has identified a trade secret with adequate particularity is a question of fact reserved for summary judgment or trial.
In its ruling, the Ninth Circuit acknowledged the complexities involved in identifying trade secrets but emphasized that the discovery process should facilitate precise identifications. The court criticized the district court for applying an excessively harsh penalty, noting that neither Rule 12(f) nor Rule 16 permits striking claims in this manner.
The Ninth Circuit’s ruling aligns with recommendations from the Sedona Conference, which asserts that trade secret identification during litigation is primarily a procedural matter, not an evaluation of the merits of the claim. Furthermore, the Federal Judicial Center’s Trade Secret Case Management Judicial Guide supports the idea that trade secret identification should serve as a tool for managing litigation, rather than a definitive ruling on the merits.
As a result of this ruling, litigants should anticipate a shift in how trade secret claims are managed. Plaintiffs may find greater incentive to pursue federal DTSA claims, which could streamline the identification process compared to the more stringent requirements of state laws like CUTSA. Conversely, defendants might encounter increased discovery costs and face the necessity of developing strategies to narrow down the definitions of the trade secrets at issue.
This ruling raises several important questions moving forward. For instance, clarity is needed regarding when a defendant may seek pretrial remedies in response to poorly defined trade secrets, and how to manage discovery when plaintiffs allege both CUTSA and DTSA claims. Additionally, the ruling does not establish a clear standard for how specifically a plaintiff must identify misappropriated trade secrets.
The Quintara decision highlights the evolving nature of trade secret litigation and the need for parties to adapt to new procedural realities. As the Ninth Circuit navigates these complexities, both plaintiffs and defendants must brace for a landscape marked by iterative discovery processes and innovative management techniques as they engage with the intricacies of trade secret identification.
