Ninth Circuit Eases Trade Secret Pleading Rules in Landmark Ruling

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 require plaintiffs to specify allegedly misappropriated trade secrets with particularity during the pleading stage. This decision marks a clear distinction from the California Uniform Trade Secrets Act (CUTSA), which mandates that plaintiffs provide a detailed description of their trade secrets prior to discovery.

The case arose when Quintara Biosciences accused Ruifeng Biztech of misappropriating eleven of its trade secrets, including customer databases, marketing strategies, and product designs. Initially, the district court ordered Quintara to summarize these secrets with “reasonable particularity.” This requirement included detailing their independent economic value and explaining how they were kept confidential. Following dissatisfaction with Quintara’s disclosures, Ruifeng successfully moved to strike nine of the eleven trade secrets, leading to a limited focus during the trial.

In its ruling, the Ninth Circuit reversed the district court’s decision, asserting that while CUTSA requires specific identification, federal law under the DTSA does not impose such a requirement before discovery. The court emphasized that determining whether a plaintiff has sufficiently identified a trade secret is a factual matter to be resolved during summary judgment or trial.

Judicial Insights on Trade Secret Identification

The court acknowledged the complexities surrounding trade secret identification but stressed that the discovery process itself can lead to adequately defined trade secrets. It found that the district court had abused its discretion by imposing severe penalties, reminding that neither Rule 12(f) nor Rule 16 permit striking claims in such a manner.

This ruling aligns with recommendations from credible sources, such as the Sedona Conference and the Federal Judicial Center, which state that trade secret identification is primarily a procedural matter, facilitating clarity without adjudicating the merits of the case. As the Ninth Circuit noted, the core issue in assessing trade secrets lies in whether they meet the criteria for statutory or common law definitions once the case reaches a substantive phase.

Implications for Future Trade Secret Cases

The implications of the Quintara decision extend beyond this particular case. It suggests a potential shift in how trade secret claims will be pursued in the Ninth Circuit. Plaintiffs may increasingly favor federal DTSA claims, circumventing the stricter pre-discovery identification standards associated with state law claims like CUTSA. This could lead to heightened discovery costs for defendants, who may need to adopt more sophisticated strategies to address trade secret definitions before summary judgment.

District courts may also need to allocate more resources to manage the early discovery process effectively. The ruling invites the possibility of implementing phased or bifurcated discovery approaches, which could result in increased delays and additional motions. Moreover, courts will now be tasked with evaluating trade secret identification not just procedurally but also substantively during summary judgment and trial.

Despite its clarity, the decision leaves several questions unanswered. For instance, it does not clarify when a defendant might pursue a dispositive pretrial remedy instead of merely requesting further discovery on poorly defined trade secrets. Additionally, the ruling does not set a standard for the level of precision required in identifying allegedly misappropriated trade secrets, nor does it address the applicability of CUTSA’s disclosure requirements in federal court settings.

Overall, the Quintara ruling illustrates the nuanced interplay between procedural and substantive law in trade secret cases. As litigants adapt to these evolving standards, they should brace for a landscape shaped by iterative discovery processes and innovative case-management techniques in the Ninth Circuit.