ORCA COMMUNICATIONS UNLIMITED, LLC v. NODER

No. CV-13-0351-PR.

337 P.3d 545 (2014)

ORCA COMMUNICATIONS UNLIMITED, LLC, A Limited Liability Company, Plaintiff/Appellant, v. Ann J. NODER and Christopher C. Noder, Wife and Husband; Pitch Public Relations, LLC, A Limited Liability Company, Defendants/Appellees.

Supreme Court of Arizona.

November 19, 2014.


Attorney(s) appearing for the Case

David B. Earl (argued), Phoenix, for Orca Communications Unlimited, LLC.

Monica A. Limón-Wynn (argued), Law Offices of Monica A. Limón-Wynn Law PLLC, Tempe, for Ann J. Noder, Christopher C. Noder and Pitch Public Relations, LLC.

Vice Chief Justice PELANDER authored the opinion of the Court, in which Chief Justice BALES, Justice BERCH, Justice BRUTINEL, and Justice TIMMER joined.


Vice Chief Justice PELANDER, opinion of the Court.

¶ 1 Arizona's Uniform Trade Secrets Act ("AUTSA"), A.R.S. §§ 44-401 to -407, creates an exclusive cause of action — and displaces conflicting causes of action — for claims based on the misappropriation of trade secrets. We hold that AUTSA does not displace common-law claims based on alleged misappropriation of confidential information that is not a trade secret.

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