In Krawiec v. Manly, owners of a ballroom dance studio sued two former employees pursuant to a non-compete clause in their employment contracts. The plaintiffs claimed their former employees began working at a competing dance studio where they shared “original ideas and concepts for dance productions, marketing strategies and tactics, as well as student, client and customer lists and their contact information.” However, the studio’s claim under North Carolina’s Trade Secrets Protection Act was dismissed by the North Carolina Business Court based on the pleadings, which did not specifically state each of the required components of a trade secrets claim. In upholding the dismissal, the North Carolina Supreme Court stated, “To plead misappropriation of trade secrets, a plaintiff must identify a trade secret with sufficient particularity so as to enable a defendant to delineate that which he is accurse of misappropriating and a court to determine whether misappropriation has or is threatened to occur.”
