Wall Street Business Academy, Inc. v. SDSol Technologies, LLC
On certiorari review of a discovery order compelling production of a claimed trade-secret source code repository, the Third District held that the trial court did not depart from the essential requirements of law by proceeding directly to the 'reasonable necessity' step of the trade-secret analysis without an in camera review, where neither party requested the review and both parties operated on the assumption that the code was a trade secret. The court nonetheless quashed the confidentiality portion of the order, holding that broad dissemination of the repository to a competitor entity — rather than to its designated expert — created an irreparable risk of misappropriation. The petition was therefore denied in part and granted in part.
Key facts
- Wall Street Business Academy sued SDSol Technologies for breach of contract in Miami-Dade circuit court, alleging SDSol failed to deliver suitable source code for a web and mobile application, forcing Wall Street to hire in-house developers who created the 'iYurek' application.
- SDSol counterclaimed for unpaid development work and served a request for production seeking a complete copy of the iYurek code repository; Wall Street objected on relevance, burden, and trade secret privilege grounds.
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Holdings
- A trial court does not depart from the essential requirements of law by skipping the first step of the three-step trade secret discovery analysis (in camera review and a finding that the…
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Why it matters
This opinion is a practical roadmap for litigating trade-secret discovery objections in Florida commercial and IP cases. First, it confirms that the in camera review step of the Sea Coast / Lewis Tree three-step… — full analysis with a trial
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