GTY Technology Holdings Inc. v. Wonderware, Inc.
1:24-cv-09069
| N.D. Ill. | May 21, 2025Background
- Euna Solutions (GTY Technology Holdings, Inc.) and its subsidiary CityBase sued their former executives, Michael Duffy (ex-CEO) and Christopher Lewis (ex-SVP of Engagement), and their new employer, Wonderware, Inc. d/b/a Core Business Technologies (CORE), in the Northern District of Illinois.
- Plaintiffs alleged that after Duffy and Lewis left, they took trade secrets, confidential information (including internal business strategy and customer data), and joined a direct competitor, CORE, helping to recruit additional CityBase employees.
- Duffy and Lewis allegedly engaged in acts, including downloading trade secrets and wiping company computers, as part of their departure and transition to CORE.
- Plaintiffs brought claims under the Defend Trade Secrets Act (DTSA), Illinois Trade Secrets Act (ITSA), Computer Fraud and Abuse Act (CFAA), breach of contract, fiduciary duty claims, conspiracy, and related theories.
- Defendants moved to dismiss for lack of personal jurisdiction (as to Lewis), lack of subject matter jurisdiction, and failure to state a claim on all counts.
- The district court (J. Daniel) denied both Lewis' and the defendants' motions in their entirety, ordering answers to the amended complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over Lewis | Lewis's role tethered him to Illinois and suit-related activities occurred there | Lewis is a Canadian citizen; acts occurred in Canada | Jurisdiction proper given duties, travel, and contacts with Illinois |
| Applicability of DTSA to Lewis | At least one act in furtherance occurred in the U.S.; DTSA applies | No act in the U.S.; Lewis is a Canadian citizen | DTSA applies; acts in Chicago and via communications suffice |
| Standing to bring trade secrets claims | Plaintiffs own rights to the trade secrets as employer (and parent/sub relationship) | Plaintiffs not proper trade secret owners/licensees | Plaintiffs sufficiently pled ownership/standing |
| Sufficiency of trade secrets allegations | Trade secret status adequately pled; reasonable protections and value shown | No sufficient measures to protect alleged secrets; info not shown valuable | Allegations sufficient to survive motion to dismiss |
| CFAA claim and relief available | Pled $5,000+ loss; seeks allowed injunctive relief | Lack of damages, no monetary relief possible | CFAA claim survives; injunctive relief available |
| Breach of contract claim (restrictive covenants) | 2019 letter incorporates prior agreements; covenants remain | 2019 agreement superseded old covenants; no breach possible | Covenants remain valid; claim not dismissed |
| Fiduciary duty/conspiracy claims | Breach included more than just info misuse | No actionable breach/insufficient facts | Claims adequately pled |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility in federal court)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for motions to dismiss)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (minimum contacts standard for personal jurisdiction)
- Bristol-Myers Squibb Co. v. Superior Court of Cal., 582 U.S. 255 (necessity of forum contacts for specific jurisdiction)
- Rockwell Graphic Sys., Inc. v. DEV Indus., Inc., 925 F.2d 174 (reasonable measures requirement for trade secret protection)
- Liebert Corp. v. Mazur, 827 N.E.2d 909 (Illinois trade secret misappropriation pleading standard)
- Lawlor v. N. Am. Corp. of Ill., 983 N.E.2d 414 (duty of loyalty from employees to employer under Illinois law)