Precision Medicine Group v. Matter

Background

Precision provides market-access consulting services to pharmaceutical companies. Precision alleged that Blue Matter, a competing consulting company, recruited former Precision employees Naina Ahmad, Jose Jauregui, and Mridul Malhotra and induced them to violate non-compete and non-solicitation agreements. Precision also alleged that Blue Matter obtained and used Precision’s confidential information and trade secrets.

The parties filed cross-motions for summary judgment. Precision sought judgment on its claims that Blue Matter aided and abetted breaches of fiduciary duty and the duty of loyalty and tortiously interfered with employment contracts. Blue Matter sought judgment on all claims remaining against it.

Aiding and Abetting Breach of Fiduciary Duty

The court granted Blue Matter summary judgment on this claim and denied Precision’s cross-motion. Precision’s claim had alleged that Blue Matter aided breaches involving Ahmad, Jauregui, and Malhotra. Because Precision did not address Blue Matter’s arguments concerning Jauregui and Malhotra in its opposition, the court treated those portions of the claim as abandoned.

As to Ahmad, the court held that Precision had not provided evidence that Blue Matter actually knew that Ahmad’s five-year plan and financial spreadsheet relied on Precision’s alleged trade-secret or confidential information. The court also held that Precision had abandoned the theory that Blue Matter induced Ahmad to work for Blue Matter in violation of her non-compete agreement. To the extent Precision relied on Ahmad’s post-employment solicitation of Jauregui and Malhotra, the court found no supporting legal authority; to the extent it relied on pre-resignation conduct, the cited evidence did not show that Ahmad solicited them while still employed by Precision.

Tortious Interference with Contract

The court granted Blue Matter summary judgment and denied Precision’s cross-motion. Precision alleged that Blue Matter induced Ahmad to violate her non-solicitation obligations and induced Ahmad, Jauregui, and Malhotra to violate their non-compete obligations.

Regarding Ahmad’s alleged non-solicitation breach, the court found insufficient evidence that Blue Matter directed or induced Ahmad’s communications with Jauregui and Malhotra, her five-year plan, or the meeting at which Malhotra met with Ahmad and Blue Matter’s co-founder. The evidence showed Ahmad took these actions, but did not show that Blue Matter caused her to take them.

Regarding the alleged non-compete breaches, the court held that Precision had not provided evidence of recoverable damages caused by Blue Matter’s conduct. Precision’s damages expert relied on the employees’ historical revenue and profits, rather than evidence that Precision lost particular clients, projects, or matters because of Blue Matter’s alleged interference. The court also found that testimony that Precision would be harmed was too speculative to create a genuine factual dispute.

Trade-Secret and Unfair-Competition Claims

The court denied Blue Matter’s motion for summary judgment on Precision’s claims under the Defend Trade Secrets Act, for New York misappropriation of trade secrets and confidential information, and for unfair competition. The court found material factual disputes about whether the Precision materials found on Blue Matter systems qualified as trade secrets, whether Blue Matter used them, and whether they were obtained through improper means.

The evidence included Jauregui’s copying Precision files onto a thumb drive before leaving Precision, opening and saving those files on a Blue Matter laptop, and allegedly using Precision materials in Blue Matter presentations and proposals. Precision also presented evidence that the materials contained proprietary methodologies and frameworks developed over many years and that Precision used security practices such as passwords, limited access, confidentiality agreements, and non-disclosure agreements.

The court concluded that a reasonable jury could find that the materials contained trade secrets and that Blue Matter used them, including in a presentation for a potential pharmaceutical client. The court therefore declined to resolve those issues as a matter of law at summary judgment.

Tortious Interference with Prospective Economic Advantage

The court granted Blue Matter summary judgment on this claim. Precision alleged that Blue Matter used improperly obtained information and recruited Precision personnel to interfere with Precision’s customer relationships and business opportunities. The court held that Precision had not provided evidence that Precision would have entered into a business relationship with a particular entity but for Blue Matter’s conduct. Evidence that Precision’s practice lost revenue after employees left was not enough to establish the required causation.

Other Dispositions and Case Status

Precision’s claims under the Pennsylvania Uniform Trade Secrets Act and the New Jersey Uniform Trade Secrets Act were dismissed on consent after Precision agreed to withdraw them. Precision’s motion for a status conference was denied as moot. The court directed the clerk to terminate the motions and stated that the case would proceed to trial on November 10, 2025.