Through a series of preliminary rulings, the Central District of California has found that a nonprofit organization’s confidential membership list could constitute a trade secret under the Defend Trade Secrets Act (DTSA). The case is Brain Injury Association of California v. Yari, No. CV 19-5912-MWF (JCX) (C.D. Cal.).
The plaintiff, Brain Injury Association of California (BIAC), alleges that a former BIAC board member, Naz Yari, took off with BIAC’s “master list”—a detailed compilation of data regarding 100,000 members of the traumatic brain injury community. BIAC used the master list to plan its annual conference, which boasted thousands of attendees and half a million dollars of funds raised. Immediately after resigning from the BIAC board, Yari formed a new nonprofit organization, Brain Society of California (BSC), and began planning a competing conference on BSC’s behalf. BIAC brought suit for misappropriation of trade secrets, among other claims, in July 2019. In August 2019, the court issued a temporary restraining order prohibiting Yari from accessing, using, or disclosing any contact information from BIAC’s master list.
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