Harbor Business Compliance Corp v. Firstbase IO Inc, 25-1278

Firstbase.io, Inc. and Harbor Business Compliance Corporation formed a partnership in 2022 to develop a new software product, but the partnership quickly deteriorated due to performance and workflow disputes.
Firstbase allegedly used proprietary information acquired from Harbor to build and launch its own competing registered agent service across all states after the partnership collapsed.
Harbor sued Firstbase in federal court for breach of contract, trade secret misappropriation (under federal and state law), and unfair competition.
A jury found in favor of Harbor, awarding substantial compensatory and punitive damages under all claims.
Firstbase challenged the verdict through post-trial motions for judgment as a matter of law, new trial, and remittitur, all of which were denied by the district court.
On appeal, Firstbase argued insufficient evidence for trade secret misappropriation and unfair competition, improper expert testimony, and duplicative damages awards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for trade secret misappropriation	Harbor proved access and use of protectable trade secrets	Trade secrets were public/general knowledge or reverse engineered	Sufficient circumstantial evidence supported jury’s verdict; court affirmed denial of JMOL
Sufficiency of evidence for protectability of trade secrets	At least one trade secret (database) was protectable	Harbor failed to prove independent economic value/protectability	Firstbase forfeited challenge by not specifically raising it; court assumed protectability
Improper expert testimony by Dr. Valerdi	Testimony consistent with expert report and not prejudicial	Testimony exceeded scope of report and was inadmissible	Any error in admitting testimony was harmless; no prejudice; denial of new trial affirmed
Damages/remittitur (double recovery)	All damages supported by evidence of separate harms	Jury improperly disgorged same profits twice under two theories	Jury awarded duplicative damages; remittitur required; Harbor may accept reduced award or new trial

Kars 4 Kids Inc. v. Am. Can!, 8 F.4th 209 (3d Cir. 2021) (standard for judgment as a matter of law and appellate review)
Oakwood Lab’ys LLC v. Thanoo, 999 F.3d 892 (3d Cir. 2021) (elements and standards for trade secret misappropriation)
Mallet & Co. v. Lacayo, 16 F.4th 364 (3d Cir. 2021) (compilations of public information can constitute a trade secret in certain circumstances)
Fineman v. Armstrong World Indus., Inc., 980 F.2d 171 (3d Cir. 1992) (double recovery not permitted across legal theories for same harm)
Spence v. Bd. of Educ. of Christina Sch. Dist., 806 F.2d 1198 (3d Cir. 1986) (remittitur is appropriate when a jury award is clearly excessive)