Zomm, LLC (“Zomm”) sued Apple Inc. (“Apple”) in April 2018, asserting claims for patent infringement, breach of contract, and unfair competition.  On June 17, 2019, the District Court dismissed Zomm’s breach of contract claim, which relates to Apple’s alleged violation of a confidentiality agreement that the parties executed for purposes of sharing information about the “Wireless Leash,” finding that Zomm only alleged that “Apple began to exploit Zomm’s confidential information in December 2011,” but December 2011 “was after both the Wireless Leash Plus’s release” and the corresponding patent’s publication.  Because the terms of the confidentiality agreement provided that “information either reverse engineerable from the Wireless Leash Plus product” or contained in the corresponding patent “no longer constituted confidential information,” Zomm’s complaint failed “to allege exploited confidential information.”  Apple’s victory may be short lived, however, because the Court also granted Zomm leave to amend its complaint to add details from pre-December 2011.  You can read more about the case here, and you can read the District Court’s entire order here.