Starkey Laboratories, Inc. v. Saykeo, 0:25-cv-02737

Starkey Laboratories, a leading hearing aid manufacturer, employed Phetsamone Saykeo for over 25 years, during which he had significant access to Starkey's confidential and trade secret information.
Saykeo signed a Confidentiality and Noncompete Agreement in 2005, prohibiting him from disclosing Starkey’s confidential information and from working for hearing aid competitors for 90 days post-employment.
Starkey discovered that, shortly before his planned departure, Saykeo downloaded and printed a confidential document (Windchill Document 0023811) and intended to join a start-up competitor, Chromatic, Inc.
Saykeo failed to satisfactorily return the confidential document or the USB drive, producing instead a bag of unrelated shredded papers and admitting to downloading the document.
Starkey filed for a Temporary Restraining Order (TRO) seeking to enforce the confidentiality, prevent further misappropriation, and enforce the noncompete provision. Saykeo, unrepresented, did not contest and agreed to the TRO.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Existence of Trade Secret	Windchill Document 0023811 contains protectable trade secrets per DTSA and contract	No substantive argument; admitted document	Court found likely existence of protectable trade secret
Misappropriation of Trade Secret	Saykeo improperly downloaded, retained, and failed to return trade secrets	No opposition presented	Sufficient evidence of misappropriation
Breach of Noncompete and Confidentiality	Saykeo violated noncompete by joining Chromatic and failed to protect/return information	No opposition; questioned terms in meeting	Starkey likely to succeed on breach of contract claim
Irreparable Harm	Unauthorized disclosure/use would cause competitive & reputational harm	No opposition	Threat of irreparable harm to Starkey established

Kelley v. First Westroads Bank, 840 F.2d 554 (standard for TRO to preserve status quo)
Watkins Inc. v. Lewis, 346 F.3d 841 (burden on movant for TRO/preliminary injunction)
United Healthcare Ins. Co. v. AdvancePCS, 316 F.3d 737 (likelihood of success on any claim is sufficient for TRO)
Gen. Motors Corp. v. Harry Brown's, LLC, 563 F.3d 312 (irreparable harm occurs where damages are inadequate)
Mod. Controls, Inc. v. Andreadakis, 578 F.2d 1264 (irreparable harm from violation of confidentiality and noncompete)
Carlsen v. GameStop, Inc., 833 F.3d 903 (elements of breach of contract under Minnesota law)
Kallok v. Medtronic, Inc., 573 N.W.2d 356 (enforceability of noncompete for business interests)