"Applied Predictive Technologies, Inc. v. MarketDial, Inc., No. 24-1751 (Fed. Cir. Jan. 28, 2026) (nonprecedential). This is a reality of trade secret litigation today - plaintiffs must explain the bounds of their alleged trade secrets both with clarity and supporting evidence showing that the specific information derives independent economic value from not being generally known or readily ascertainable by proper means."
"The Federal Circuit has affirmed summary judgment against a trade secret plaintiff who, in the court's view, failed to adequately identify the boundaries of its alleged secrets."
The Federal Circuit affirmed summary judgment in Applied Predictive Technologies v. MarketDial after finding the plaintiff did not adequately identify the boundaries of its alleged trade secrets. The court required clear identification of what constitutes the secret and evidentiary support showing that the specific information derives independent economic value from not being generally known or readily ascertainable by proper means. The decision underscores the need for plaintiffs in trade secret litigation to provide precise descriptions of claimed secrets and concrete evidence of secrecy and economic value to survive summary judgment.
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