The My Fav Electronics, Inc. v. Currie, et al., No. 24 C 1959, (N.D. Ill. Oct. 18, 2024) (Pallmeyer, J.).

Judge Pallmeyer granted-in-part plaintiff My Fav Electronics’ (“SLM”) motion for preliminary injunction preventing the individual defendant, a former SLM employee, from contacting certain SLM customers and requiring that the individual defendant allow forensic review of certain electronic devices in this Defend Trade Secrets Act (“DTSA”) case.

Of particular interest, the Court held:

• The Court found strong evidence that the individual defendant used at least two of the spreadsheets she allegedly took from SLM after starting work for new employer Diamond Assets, indicating actual use of claimed secrets. The spreadsheets were developed with considerable effort and were not easily reproducible by competitors, thus meriting trade secret protection.
  
• The Court also addressed the alleged breach of the NDA. The Court held that conduct qualifying as trade secret misappropriation would also likely qualify as improper disclosure and use under NDA’s terms.

The court granted the preliminary injunction in part, based on the likelihood of success on the merits, the inadequacy of legal remedies, and the irreparable harm SLM would likely suffer without injunctive relief.