Access Optical Networks, Inc. v. Seagate Technology LLC, 5:24-cv-03745

Access Optical Networks, Inc. (AON) alleges that Seagate Technology LLC (Seagate) misappropriated its trade secrets related to holographic data storage (HDS) technology, following NDA-protected information sharing during 2012–2015 related to a possible collaboration.
AON claims Seagate terminated discussions, then subsequently used AON’s proprietary information to accelerate its own Heat Assisted Magnet Recording (HAMR) technology.
AON brings claims for trade secret misappropriation under California and federal law and for breach of contract.
Under California law, AON must identify its alleged trade secrets with reasonable particularity (Code Civ. Proc. § 2019.210) before discovery on those claims can proceed.
Seagate moved to compel AON to provide a more particularized disclosure and to stay discovery until AON complies; AON opposes, and the court held a hearing.
The court found AON’s amended trade secret disclosure inadequate in part, requiring further amendment for specific trade secrets, but allowing limited discovery to proceed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Disclosure scope: limited to written disclosure?	AON: Shared both written and oral information.	Seagate: Must be limited to written disclosures.	Disclosure not limited to written information.
Use of broad/vague descriptions	AON: Trade secrets can include “knowledge” or “use”	Seagate: Vague, overly broad, insufficiently particular.	Some claims lack requisite specificity; must amend certain disclosures.
Distinction from public knowledge	AON: No need to distinguish from public knowledge.	Seagate: Must distinguish from known techniques.	Must describe with enough detail to distinguish from public knowledge for certain secrets.
Catch-all language	AON: Used fairly and does not blur boundaries.	Seagate: Improperly vague, catch-all phrasing.	No improper use of catch-all language here.

Advanced Modular Sputtering, Inc. v. Superior Court, 132 Cal. App. 4th 826 (section 2019.210 requires reasonable particularity, not absolute precision)
Brescia v. Angelin, 172 Cal. App. 4th 133 (trade secret designations should be liberally construed, minor doubts allow discovery to proceed)