Computer Associates International, Inc., Plaintiff-Appellant-Cross-Appellee v. Altai, Inc., Defendant-Appellee-Cross-Appellant

How later courts described this case

• holding that the plaintiffs former employee who stole a computer code and used it to design a program for the defendant could state a claim of misappropriation of a trade secret that was not preempted by the Copyright Act
• stating that many state law causes of action are not preempted (cjting Balboa Ins. Co. v. Trans Global Equities, 218 Cal.App.3d 1327, 267 Cal.Rptr. 787, cert. denied, 498 U.S. 940, 111 S.Ct. 347, 112 L.Ed.2d 311 (1990))
• noting that “unfair competition claims based upon breaches of confidential relationships” are not preempted (citing Balboa Ins. Co. v. Trans Glob. Equities, 218 Cal. App. 3d 1327 , 1339–53 (Ct. App. 3d Dist. 1990) (holding that § 301 does not preempt unfair competition claims “based on trade secret and breaches of confidence or fiduciary duty,” id. at 1339))
• noting that Congress drafted the Copyright Act of 1976 with an understanding that trade secret claims “contain elements, such as ... breach of trust or confidentiality, that are different in kind from copyright infringement” (quoting H.R. Rep. No. 1476, 94th Cong. 54, reprinted in 1976 U.S.C.C.A.N. 5659, 5748)

Written by the judges who cited it.