AAR MANUFACTURING, INC., ET AL., PETITIONERS,
v.
MATRIX COMPOSITES, INC., RESPONDENT
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AAR Manufacturing sought certiorari review of a trial court order denying its motion for a protective order in a trade secret misappropriation action. The court granted the petition in part, finding the trial court's order was overbroad as to two trade secret areas that were not properly before the court, but denied the petition regarding the trapped rubber molding process.
The court granted the petition in part, holding that the trial court's order was overbroad to the extent it encompassed the resin transfer molding process and compression molding areas that were not properly before the court for consideration. However, the court denied the petition regarding the trapped rubber molding process, finding no departure from essential requirements of law. The court rejected the requirement of a threshold finding of existence of trade secrets before ordering discovery in misappropriation cases.
[1] In trade secret misappropriation actions, a plaintiff must identify with reasonable particularity the trade secrets at issue before proceeding with discovery.
[2] A trial court's order compelling discovery of trade secrets is overbroad if it encompasses trade secret areas not properly before the court for consideration.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“To the extent that Revello Medical Management, Inc. v. Med-Data Infotech USA, Inc., 50 So.3d 678 (Fla. 2d DCA 2010), can be read to require a threshold finding as to the existence of the trade secret in misappropriation cases, we reject that notion.”
Establishes that no threshold finding of trade secret existence is required before ordering discovery in misappropriation cases.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceAAR and Matrix were involved in a trade secret misappropriation dispute. AAR filed a motion for a protective order seeking to prevent discovery of its…
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Petitioner, AAR Manufacturing, Inc. (“AAR”), seeks certiorari relief from the trial court’s non-final order denying its motion for a protective order in this trade secret misappropriation action. Pursuant to the motion, AAR sought to prevent the discovery of its own trade secrets until such time as Respondent, Matrix Composites, Inc. (“Matrix”), had identified with reasonable particularity the trade secrets allegedly misappropriated by AAR, as required by the terms of the parties’ agreed-upon discovery order. Following an evi-*188dentiary hearing, the trial court denied AAR’s motion, finding that Matrix had identified with reasonable particularity its trade secrets related to: (1) the trapped rubber molding process; (2) the resin transfer molding process; and (3) compression molding of continuous fiber thermoplastic composite. The trial court ordered AAR to produce within sixty days all documents requested in Matrix’s first request for production.
We are compelled to grant the petition to the extent the trial court concluded that Matrix identified with reasonable particularity the trade secrets associated with the resin transfer molding process and compression molding of continuous fiber thermoplastic composite. It is clear from the record that the parties and the trial court agreed the evidentiary hearing below was to be limited solely to the trade secrets related to the trapped rubber molding process. Matrix’s identification of the trade secrets associated with the resin transfer molding process and compression molding of continuous fiber thermoplastic composite was not before the trial court for its consideration. Accordingly, the trial court’s order is overbroad to the extent that it encompasses these two trade secret areas. However, we deny the instant petition to the extent that AAR challenges the trial court’s determination that Matrix identified with reasonable particularity its trade secrets involving its trapped rubber molding process because we conclude that there has been no departure from the essential requirements of the law. See McDonald’s Rests, of Fla., Inc. v. Doe, 87 So.3d 791, 793 (Fla. 2d DCA 2012).
Furthermore, we reject AAR’s argument that the trial court departed from the essential requirements of the law by failing to make a threshold finding that Matrix’s allegedly misappropriated trade secrets actually existed before ordering AAR to disclose its own trade secrets. In trade secret misappropriation cases, a plaintiff is required to identify with reasonable particularity the trade secrets at issue before proceeding with discovery. See Del Monte Fresh Produce Co. v. Dole Food Co., 148 F.Supp.2d 1322, 1324 (S.D.Fla.2001) (noting difference between trade secret misappropriation cases and cases involving trade secret privilege, and explaining trade secrets are ultimate issue to be decided by court in misappropriation cases). To the extent that Revello Medical Management, Inc. v. Med-Data Infotech USA, Inc., 50 So.3d 678 (Fla. 2d DCA 2010), can be read to require a threshold finding as to the existence of the trade secret in misappropriation cases, we reject that notion.
PETITION GRANTED in part; DENIED in part.
LAWSON, EVANDER and COHEN, JJ., concur.
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Nat'l Staffing Solutions, Inc. v. Ascendo Res., LLC (M.D. Fla. 2025)…with reasonable particularity the trade secrets at issue before proceeding with discovery." DynCorp International v. AAR Airlift Group, Inc., 664 Fed.Appx. 844, 848 (11th Cir. 2016), citing AAR Mfg., Inc. v. Matrix Composites, Inc., 98 So.3d 186, 188 (Fla. 5th DCA 2012); Revello Med. Mgmt., Inc. v. Med-Data Infotech USA, Inc., 50 So.3d 678, 679 (Fla. DCA 2010) (“[Med-Data] concedes that before proceeding with discovery in [a tradesecret misappropriation] suit, the plaintiff…1 / 2
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US Thrillrides, LLC v. Intamin Amusement Rides Int. Corp. Est. (M.D. Fla. 2023)…e issue as follows: Florida courts adjudicating FUTSA cases have said that the “plaintiff is required to identify with reasonable particularity the trade secrets at issue before proceeding with discovery.” AAR Mfg., Inc. v. Matrix Composites, Inc., 98 So. 3d 186, 188 (Fla. 5th Dist. Ct. App. 2012); Revello Med. Mgmt., Inc. v. Med–Data Infotech USA, Inc., 50 So. 3d 678, 679 (Fla. 2d Dist. Ct. App. 2010) (“[Med–Data] concedes that before proceeding with discovery in [a trade-secret misappropriation] suit, the…
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Jabil, Inc. v. Essentium, Inc. (M.D. Fla. 2020)…he plaintiff to “identify with reasonable particularity the trade secrets at issue before proceeding with discovery.” DynCorp Int'l v. AAR Airlift Grp., Inc., 664 F. App'x 844, 848 (11th Cir. 2016) (quoting AAR Mfg., Inc. v. Matrix Composites, Inc., 98 So. 3d 186, 188 (Fla. 5th DCA 2012)). “Reasonable particularity” requires more than generic descriptions of categories, such a list of components to which the alleged trade secrets relate. See Knights Armament Co., 254 F.R.D. at 467. Defendants argue that J…
Authorities Cited
- Revello Med. Mgmt., Inc. v. Med-Data Infotech USA, Inc., 50 So. 3d 678 (Fla. 2d DCA 2010)
- McDONALD'S Rests. OF Fla., Inc. v. DOE, 87 So. 3d 791 (Fla. 2d DCA 2012)
- Del Monte Fresh Produce Co. v. Dole Food Co., Inc., 148 F. Supp. 2d 1322 (S.D. Fla. 2001)