SpotterRF LLC v. Knoch
3:24-cv-05994
W.D. Wash.May 29, 2025Background
- SpotterRF, a Utah-based surveillance radar company, sued several former employees/contractors (Knoch, Rysavy, and Mandrell) and their associated businesses for alleged breaches of contract, misappropriation, and unfair competition.
- The key contracts at issue contain noncompete, confidentiality, nonsolicitation, and non-disparagement provisions. Knoch and Rysavy each signed multiple employment agreements; Mandrell worked under a contractor agreement with a mediation clause.
- Spotter alleges the defendants aided competitors, downloaded and misused confidential info (including proprietary software), solicited employees, and disparaged Spotter to third parties while still employed or shortly after leaving.
- Spotter brought ten claims including breach of contract, breach of duties of good faith and loyalty, trade secret misappropriation (UTSA/DTSA), and intentional interference with contract.
- Defendants moved to dismiss most claims under FRCP 12(b)(6), arguing failures in fact, law, and improper contract restrictions.
- The court grants in part and denies in part the motion, dismissing or staying several claims but allowing others (mainly against Knoch) to proceed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of noncompete provisions | Agreements are enforceable or can be reformed | Provisions void under Utah law; cannot be saved | Noncompetes are void under Utah law; dismissal with prejudice |
| Breach of solicitation and non-disparagement covenants | Defendants solicited employees/disparaged Spotter | Agreements overbroad/speculative; time-barred | Solicitation & non-disparagement claims against Knoch plausible; others dismissed |
| Sufficiency of confidentiality/misappropriation claims | Defendants misused confidential info/trade secrets | Provisions are too vague; no facts of misuse | Confidentiality breach claim against Knoch survives; not against Rysavy |
| Implied covenant/good faith/fiduciary duties | Defendants acted disloyally to Spotter | Just a restated contract claim; no facts for Rysavy | Breach of implied duty and loyalty claim against Knoch plausible; not for Rysavy |
| Intentional interference with contract | Defendants interfered via disparagement/dishonesty | Allegations are speculative | Claim against Knoch proceeds based on specific statements; claim against Rysavy dismissed |
| Sufficiency of trade secret (UTSA/DTSA) claim | Defendants misappropriated trade secrets | No specific facts of use by Rysavy/SSI | Claims against Rysavy/SSI dismissed as speculative |
| Compulsion of mediation for Mandrell claims | Should proceed with mediation/arbitration | - | Claims against Mandrell stayed/compelled to mediation |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (standard for sufficiency of pleadings under FRCP 12(b)(6))
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleading)
- Brady v. Park, 445 P.3d 395 (Utah contract interpretation principles)
- St. Benedict’s Dev. Co. v. St. Benedict’s Hosp., 811 P.2d 194 (good faith and fair dealing in Utah)
- Oakwood Vill. LLC v. Albertsons, Inc., 104 P.3d 1226 (Utah law on implied covenants)
- Norman v. Arnold, 57 P.3d 997 (independent fiduciary duties under Utah law)
- Eldridge v. Johndrow, 345 P.3d 553 (elements of tortious interference in Utah)
- C.R. England v. Swift Transp. Co., 437 P.3d 343 (defining improper means for interference claims)