Syntel Sterling Best Shores Mauritius Limited v. The Trizetto Group, Inc.

Background

Syntel Sterling Best Shores Mauritius Limited and Syntel, Inc. moved to exclude The Trizetto Group, Inc. and Cognizant Technology Solutions Corp. from introducing evidence that Facets constituted a protectable trade secret. Syntel relied on Federal Rules of Evidence 401, 402, and 403.

Arguments and analysis

The court held that whether Facets constituted a protectable trade secret was an issue for the jury. The jury would determine whether a trade secret existed and what it consisted of. The court declined to decide through a motion in limine, shortly before trial, whether the defendants had described TriZetto’s trade secrets specifically enough. The court noted that TriZetto had previously claimed that the relevant versions of Facets were protectable trade secrets and that Syntel had never moved to require a more specific description.

The court also rejected Syntel’s argument that depositing part of Facets’ source code with the Copyright Office eliminated trade-secret protection. According to the court, the jury could consider that issue when deciding whether the source code was kept secret. The court said the argument could have been raised on summary judgment but could still be raised at trial.

Disposition

Judge Lorna G. Schofield denied Syntel’s motion in limine No. 16. The defendants may introduce evidence concerning whether Facets constituted a protectable trade secret. The Clerk of Court was directed to close the motion at Docket No. 754.