North Palm Motors, LLC v. Custom Fleet Services, Inc.
After an eleven-day bench trial, the Fourth DCA affirmed a judgment holding the Schumacher defendants liable for trade secret misappropriation on a 'reason to know' basis under FUTSA while affirming the trial court's refusal to find willful and malicious misappropriation (and thus to award attorney's fees or exemplary damages) and its refusal to award 'actual loss' damages. The court reversed only the $864,000 unjust enrichment award, directing a 15% reduction because the plaintiff's own expert conceded 15% of Auto Rentals' revenue could not be tied to the misappropriated customer list.
Key facts
- North Palm Motors, LLC sued Custom Fleet Services, Inc. and the Schumacher defendants for trade secret misappropriation involving a customer list used in the auto rental business.
- After an eleven-day bench trial, the trial court found the defendants liable for misappropriation on a 'reason to know' basis, but declined to award willful and malicious damages, attorney's fees, or actual loss damages; it did award $864,000 in unjust enrichment.
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Why it matters
This is a rare, comprehensive Fourth DCA treatment of damages, fees, and exemplary damages under the Florida Uniform Trade Secrets Act, and it expressly aligns FUTSA's 'willful and malicious' standard with the… — full analysis with a trial
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