Cox Automotive Inc. v. Super Dispatch Inc.
4:24-cv-00292
| W.D. Mo. | May 23, 2025Background
- Cox Automotive operates CentralDispatch, a subscription-based online vehicle transport platform ('load board'), containing proprietary customer and vehicle transport data.
- Access to CentralDispatch is limited to subscribers, is password-protected, and governed by terms prohibiting unauthorized use or disclosure of data.
- Super Dispatch operates a competing load board and developed tools (browser extension, app, scraper) to export and collect Cox's compiled listing information from password-protected portions of CentralDispatch.
- Cox alleges Super Dispatch misused this data for their own competitive and analytic purposes, constituting trade secret misappropriation and unjust enrichment.
- Super Dispatch moved to dismiss Cox’s Second Amended Complaint as to the trade secret (Count II) and unjust enrichment (Count V) claims for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Cox's compiled data is a trade secret under Missouri law | The compilation is valuable, not generally known, and required substantial investment to assemble. | Accessible to subscribers; data not inherently secret or protectable. | Cox plausibly alleged a trade secret; motion to dismiss denied. |
| Whether Cox took reasonable steps to keep its information secret | Access restricted to subscribers, password-protected, and subject to confidentiality policies. | Cox failed to allege sufficient efforts to maintain secrecy. | Cox sufficiently alleged reasonable steps; motion to dismiss denied. |
| Whether unjust enrichment requires a direct benefit to defendant | Direct benefit not required; indirect benefit through unauthorized data use sufficient. | Only direct conferred benefit supports unjust enrichment claim. | Missouri law allows indirect benefit; motion to dismiss denied. |
Key Cases Cited
- AvidAir Helicopter Supply, Inc. v. Rolls-Royce Corp., 663 F.3d 966 (8th Cir. 2011) (compilations of public information can still qualify as trade secrets if they confer a competitive advantage and are not readily ascertainable)
- Conseco Fin. Servicing Corp. v. N. Am. Mortg. Co., 381 F.3d 811 (8th Cir. 2004) (customer information sheets may be trade secrets even if information is partially public)
- Stodghill v. Wellston Sch. Dist., 512 F.3d 472 (8th Cir. 2008) (motion to dismiss standard—court must accept complaint’s factual allegations as true)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard for facial plausibility in federal court)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must contain sufficient facts to state a claim to relief that is plausible)