C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc.

Background

C.H. Robinson Worldwide, Inc. sued Traffic Tech, Inc. and several former C.H. Robinson employees. C.H. Robinson asserted six claims, including breach of contract and tortious interference with contract. The defendants filed a second motion seeking dismissal of Claims IV, V, and VI.

The court had previously dismissed those three claims without prejudice because C.H. Robinson had not provided a short and plain statement explaining what confidential information each defendant had access to, how the information was allegedly misused, or what conspiratorial conduct each defendant allegedly took. The court allowed C.H. Robinson to amend its complaint. In its amended complaint, C.H. Robinson dropped claims against two former employees and added one sentence referring to a chart in its supplemental answers to an interrogatory. It did not attach the chart to the amended complaint.

Rule 8 analysis

Federal Rule of Civil Procedure 8 requires a complaint to contain a short and plain statement showing that the plaintiff is entitled to relief. The court found that referring to a chart covering more than 40 customers, along with deposition excerpts, discovery materials, and a document that had been clawed back, did not provide the required clarity or brevity. The court also found that C.H. Robinson had not added factual allegations addressing the previously identified deficiencies in its aiding-and-abetting and conspiracy claims.

Because C.H. Robinson had already been given an opportunity to amend, the court dismissed Claims IV, V, and VI for failure to comply with Rule 8.

Failure to state a claim

The court also analyzed the claims under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when the complaint does not state a legally sufficient claim for relief.

For the breach-of-confidentiality claim, the court explained that C.H. Robinson had to allege, among other things, that the information was not generally known or readily ascertainable, provided a competitive advantage, was subject to reasonable efforts to maintain secrecy, and was improperly used or disclosed. After considering the complaint and the materials incorporated by reference, the court found that C.H. Robinson had not sufficiently alleged that the identified customer information was not generally known or readily ascertainable. The court noted examples in which customer contact information came from customer communications, was available to other Traffic Tech employees, or was obtained from a third-party database.

For aiding and abetting, the court found that C.H. Robinson had not alleged facts showing that the defendants substantially assisted one another’s alleged wrongdoing or knew of one another’s unlawful conduct. For civil conspiracy, the court found that C.H. Robinson had not alleged sufficient facts to support an inference that the defendants agreed to accomplish an unlawful purpose and took coordinated action to do so.

Disposition

The court granted the defendants’ Partial Motion to Dismiss. Claims IV, V, and VI were dismissed with prejudice.