DTSA Claim Dismissed For Failure To Plead ‘Interstate Commerce’ Element

Mealey's ( September 25, 2019, 1:36 PM EDT) -- HONOLULU — A federal judge in Hawaii on Sept. 23 ruled that a nonprofit organization that provides hospice care to residents of Hawaii failed to sufficiently plead that its alleged trade secret “relates to a product or service used in, or intended for use in, interstate commerce” as required pursuant to the Defend Trade Secrets Act (DTSA) (Islands Hospice Inc. Michael Duick, et al., No. 19-0202, D. Hawaii, 2019 U.S. Dist. LEXIS 162416)....