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Chicago IP Litigation Tracking Northern District of Illinois IP Cases

Loosely Related State Law Claims Sufficient for Supplemental Jurisdiction

Posted in Jurisdiction

Von Holdt v. A-1 Tool, No. 04 C 4123, Slip Op. (N.D. Ill. Aug. 18, 2010) (Manning, J.).

Judge Manning, having granted in part plaintiff’s motion for reconsideration, decided to maintain supplemental jurisdiction over plaintiffs’ remaining state law claims despite having granted defendants summary judgment as to plaintiffs’ federal patent infringement and Computer Fraud and Abuse Act ("CFAA") claims. Plaintiffs’ state law claims – trade secret, tortious interference and breach of fiduciary duty claims – were "loosely" connected to plaintiffs’ CFAA claim because they were based upon the alleged theft of plaintiffs’ confidential information by a former employee.