An Illinois appellate court recently rejected applying the inevitable disclosure doctrine in a trade secret misappropriation spat arising out of a failed business transaction. After first securing an executed confidentiality agreement, Destiny, the developer of a proprietary healthcare wellness program called “Vitality,” shared details of it with Cigna, a healthcare insurer. The insurer decided instead to create a wellness product of its own called “Empower.” Destiny sued Cigna for trade secret misappropriation and breach of contract, alleging circumstantial evidence and “inevitable disclosure.” Cigna’s summary judgment motion was granted, and the appeals court affirmed. Destiny Health, Inc. v. Connecticut Gen. Life Ins. Co., No 1-14-2530 (Ill. App. Court, 1st Dist., Aug. 21, 2015). Status of the case. Because of a possible interest in “Vitality,” Cigna was considering entering into a joint…
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