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Intellectual Property

Mar. 15, 2024

Navigating the complex, ever-shifting landscape of California trade secrets law

A recent trade secrets case between Applied Medical Distribution Corporation and its former employee, Stephen Jarrells, highlights the complexities of protecting confidential information in the digital age.

John-Paul S. Deol

Partner, Dhillon Law Group Inc.

Phone: (415) 741-7935

Santa Clara Univ School of Law

Deol is a partner and head of the Employment Law Practice at Dhillon Law Group Inc.


The long legal battle between Applied Medical Distribution Corporation and its former employee, Stephen Jarrells, highlights the intricacies of trade secrets law, providing valuable lessons for businesses and their attorneys. The case, stemming from allegations of misappropriation, breach of contract, and breach of fiduciary duties, underscores the complexities of safeguarding confidential information in the digital age. It offers a comprehensive look into how the legal system navigates disputes involving proprietary information, setting a significant precedent for future litigation in California and beyond.

Stephen Jarrells, previously employed by Applied Medical, was accused of unlawfully transferring confidential and proprietary data to his new employer, Bruin Biometrics. Despite the jury’s finding of misappropriation, it concluded that there were no direct financial damages incurred by Applied Medical nor unjust enrichment obtained by Jarrells or Bruin. This verdict prompted a careful, detailed legal examination by the court, challenging conventional understandings of what constitutes harm in the context of trade secrets misappropriation.

The appellate court’s analysis centered on several key legal questions, most notably the issuance of a permanent injunction against Jarrells. This decision, despite the absence of proven financial harm to Applied Medical, highlights the court’s intent to go beyond its usual practices to rigorously protect trade secrets. The court’s detailed consideration of the attorney fees and litigation costs in the dispute underscores the broader legal and financial implications of such litigation, offering a broader perspective on the recovery and allocation of these expenses.

Furthermore, the appellate court’s reassessment of excluded expert fees and the determination of willful and malicious misappropriation presents critical insights. The court’s differentiation between expenses for investigating potential misappropriation and those for mitigating actual misappropriation shows the types of costs that can indeed be recouped, providing a clearer framework for businesses seeking to protect their proprietary assets.

The ruling holds profound implications for the protection of trade secrets going forward, particularly when there are no obvious “financial damages” as one might traditionally use that term. By affirming the issuance of a permanent injunction in the absence of financial damages, the court emphasizes the intrinsic value of proprietary information beyond mere monetary assessment. This stance encourages companies to rigorously maintain confidentiality agreements and ensure that breaches of such agreements are met with aggressive legal responses, seeking all possible remedies.

The case also serves as a clarion call for the need for explicit agreements regarding trade secrets and proprietary information. It accentuates the necessity for clear contractual language and thorough understanding between employers and employees regarding the handling and protection of confidential information. For legal professionals, the case highlights the critical importance of a meticulous approach to proving misappropriation and strategically navigating the legal processes for seeking meaningful remedies, financial or otherwise.

The nuanced legal questions addressed in this case provide a comprehensive overview of the judicial handling of trade secrets litigation. The court’s deliberations on permanent injunctions, attorney fees, and the intricacies of calculating damages offer valuable insight for those seeking to prevent and address misappropriation, and to guide businesses in implementing effective protective measures and legal strategies for responses to threats of misappropriation.

Furthermore, the case sheds light on the judicial perspective regarding non-material breaches of trade secrets and the appropriate mechanisms for redress. This insight is particularly valuable for companies navigating the fine line between choosing a measured approach to protecting their intellectual assets and pursuing aggressive legal action against potential breaches.

While Applied Medical may not have secured direct financial remuneration, the remedies granted—including the permanent injunction and the partial award of legal fees—represent significant victories that underscore the court’s commitment to safeguarding trade secrets and proprietary information. This case sets a crucial benchmark in trade secrets litigation, illuminating the path for calculating damages and exploring the breadth of available legal remedies, including injunctive and other equitable relief.

In sum, the Applied Medical case not only reaffirms the paramount importance of trade secrets in contemporary business practices but also highlights the legal blueprints for their protection. As companies increasingly rely on digital and confidential information for competitive advantage, the principles coming from this case will undoubtedly influence corporate policies, contractual agreements, and litigation strategies across California and beyond.


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