Ninth Circuit Eases Trade Secret Disclosure Requirements in DTSA Claims

On August 12, 2025, the Ninth Circuit Court of Appeals ruled in the case of Quintara Biosciences, Inc. v. Ruifeng Biztech, Inc., determining that the Defend Trade Secrets Act (DTSA) does not mandate plaintiffs to specify their allegedly misappropriated trade secrets with particularity during the pleading stage. This ruling contrasts with the California Uniform Trade Secrets Act (CUTSA), which requires plaintiffs to disclose their trade secrets with “reasonable particularity” before the discovery phase. This decision may significantly influence how trade secret claims are handled within the Ninth Circuit.

In this case, Quintara Biosciences accused Ruifeng Biztech of misappropriating eleven trade secrets, including sensitive customer and vendor databases, marketing strategies, and designs for new products. Before entering the discovery phase, the district court instructed Quintara to provide a summary of these trade secrets, demanding a description of their economic value, how they were kept confidential, and a detailed listing of each secret similar to patent claims. Ruifeng, unsatisfied with the provided disclosures, sought to strike most of Quintara’s claims. The district court sided with Ruifeng, dismissing nine of the eleven trade secrets on the grounds of inadequate disclosure.

The Ninth Circuit’s ruling reversed this district court decision. While acknowledging the CUTSA’s requirement for specificity, the court clarified that federal law does not impose the same standard for DTSA claims. The court emphasized that the identification of trade secrets is fundamentally a factual question to be resolved during summary judgment or trial, rather than at the pleading stage.

The ruling noted that identifying these trade secrets can be a “delicate problem,” yet the Ninth Circuit advocated for the idea that the iterative discovery process provides a pathway for sufficiently particularized identification. The court criticized the district court for overstepping its authority, stating that neither Rule 12(f) nor Rule 16 allowed for the striking of Quintara’s claims in this manner.

Implications for Trade Secret Litigation

The Quintara decision reshapes the landscape of trade secret litigation within the Ninth Circuit. By clarifying that trade secret identification is both a procedural and substantive issue, the ruling may encourage plaintiffs to pursue federal DTSA claims over state law claims that impose stricter pre-discovery requirements. Consequently, defendants may face increased discovery costs and need to implement advanced strategies to refine the definitions of trade secrets before summary judgment.

Moreover, district courts may require additional resources to manage early discovery processes more effectively. This may involve using phased or bifurcated approaches, which could lead to delays and additional motions. As courts now assess trade secret identification based on the merits during summary judgment and trial, this introduces a new layer of complexity for litigants.

The Ninth Circuit’s decision leaves several questions unanswered. It does not clarify when a defendant may seek a pretrial remedy instead of merely requesting additional discovery motions for poorly identified trade secrets. Additionally, the ruling does not address how courts should manage cases where a plaintiff alleges both CUTSA and DTSA claims, nor does it specify the exact level of precision required for identifying misappropriated trade secrets.

The decision also raises questions regarding the binding nature of CUTSA’s disclosure rules on federal courts hearing CUTSA claims. While the Quintara ruling highlights the distinctions between DTSA and CUTSA, it intertwines procedural and substantive elements of trade secret identification, potentially leading to new challenges for litigants and courts alike.

As the Ninth Circuit moves forward, parties should anticipate more iterative discovery processes and innovative case-management techniques from district courts overseeing trade secret identification disputes.