The Federal Circuit overturned a $59.4 million trade secret verdict against EOFlow, holding Insulet's DTSA claims time-barred. Under the single-claim rule, once the limitations clock ran on one trade secret, it ran on all of them, including one Insulet could not detect in the competitor's product.

The Federal Circuit’s April 17, 2026 reversal in International Medical Devices, Inc. v. Cornell applies settled California trade secret law to vacate a $17 million-plus jury verdict and a five-year permanent injunction on two independent CUTSA grounds, either of which would have sufficed.

The ruling underscores that no matter how egregious an employee’s conduct, a trade secret claim under the Defend Trade Secrets Act (“DTSA”) requires allegations that the defendant acquired, induced, or used the stolen information, not just that it hired the people who took it.

Discerning the line between providing too much information in a trade secrets identification (and therefore potentially publicly revealing some of the proprietary information) and disclosing too little information (thereby risking dismissal or the need to amend a trade secrets disclosure) is more art than science

A plaintiff’s identification of trade secrets is one of the most important aspects of trade secrets litigation, as this case illustrates.