The case of Bureau Veritas Commodities and Trade, Inc. v. Cotecna Inspection SA, No. 4:21-CV-00622, 2022 WL 912781 (S.D. Tex. 2022) dealt with the application of Federal Rule of Civil Procedure 12(b)(6) to claims under the Defend Trade Secrets Act (DTSA) and the Texas Uniform Trade Secrets Act (TUTSA). Ultimately, the Southern District of Texas determined that the Plaintiff successfully plead a claim under DTSA and TUTSA. In reaching this conclusion, the court determined that the Plaintiff was not required to plead detailed descriptions of its trade secret in a public complaint, especially without a court order in place.
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