To Sue for Theft of Your Trade Secrets in California, You May First Have to
Give Them Away | Trade Secrets Watch

Section 2019.210 provides that before commencing discovery in a trade
secret litigation, the party alleging trade secret misappropriation must
identify the allegedly stolen trade secret “with reasonable particularity.”

For plaintiffs, this rule is no joke.  It has sent many a plaintiff back to
the drawing board trying, again and again, to adequately identify their
stolen “special sauce.” It can be supremely frustrating.  A plaintiff
certain that a defendant stole *something* can’t just conduct discovery to
figure out what.  Instead, the plaintiff has to identify, in advance, what
it thinks defendant stole.

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