Posted on June 15, 2007 by Kevin Lemley

Some Claims Dismissed in Arkansas Trade Secret Case

The Western District of Arkansas dismissed some of the counts in Illumination Station, Inc. v. Cook, 2007 WL 1624458 (W.D. Ark. 6/4/07) (previously posted on 4/13/07).

 

Illumination Station filed suit against defendants claiming trade secret misappropriation and 7 other counts. Defendants moved to dismiss 5 of the counts based on preemption. Their argument was based on R.K. Enterprises, LLC v. Pro-Comp Management, Inc., 356 Ark. 565 (2004) (previously posted 1/10/07), holding that the Arkansas Trade Secret Act preempts tort causes of action.

 

The court granted the motion to dismiss as to the counts for conversion and an accounting. Although the court denied the motion as to the remaining counts, the court granted the defendants leave to file a reply to the motion to dismiss.

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