Law360 highlighted some of the most significant trade secret decisions of 2025. Courts addressed procedural standards, juries issued substantial damages awards, and cases demonstrated the varied contexts in which trade secret law can apply. Finnegan partner and leader of the AI + Trade Secrets practice, Erik Puknys, shared insights on some of these developments.
In Quintara Biosciences v. Ruifeng Biztech, the Ninth Circuit reversed a California federal court’s decision to dismiss several trade secret claims at an early stage of litigation. The appellate court held that the federal Defend Trade Secrets Act does not impose California’s “reasonable particularity” requirement at the pleading stage. The court emphasized that determining the level of detail required to identify a trade secret is a fact-driven issue best addressed later in the case, such as at summary judgment or trial.
Erik said the decision may make plaintiffs more willing to file federal trade secret cases in California. “I know a lot of plaintiffs avoid California because of the onerous identification requirement right up front so early in the case,” he said, preferring states where “courts will let you take some discovery before you really nail down exactly what trade secrets were misappropriated.”
In Zest Labs v. Walmart, an Arkansas jury awarded Zest Labs nearly $223 million after finding that Walmart willfully misappropriated technology designed to keep groceries fresh longer.
“Trade secret verdicts continue to shock,” Erik said, referring to the large damages award.
He noted that while it strikes him as “odd” that freshness technology for consumer packaged goods is worth that much, it shows “that’s how you punish in district court in jury trials in the United States.” Erik added that “a very large segment of Americans” have a lot of suspicion about corporate executives. “Maybe a lot of suspicion.”
