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ValveTech Inc. v. Aerojet Rocketdyne Inc.

Breach, Trade Secret Theft Claims Dismissed Under California Law; Replevin Claim Survives

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DECISION AND ORDERINTRODUCTION Beginning in 2013, Defendant Aerojet Rocketdyne, Inc., entered into a series of agreements with Plaintiff ValveTech, Inc., under which ValveTech would provide particular valves for thrusters Aerojet was designing for a spacecraft. See ECF No. 1-3 4. After the business relationship soured, ValveTech demanded the return of its proprietary information regarding the design and development of the valves. Id.

13-16. When Aerojet seemingly refused and began to develop the valves internally, ValveTech sued Aerojet in New York State Supreme Court. See ECF No. 1-3. The Complaint contained seven claims, all centering around the alleged misuse of ValveTech’s proprietary information: (1) breach of contract, (2) unjust enrichment, (3) trade secret misappropriation, (4) unfair competition, (5) conversion, (6) replevin, and (7) a requested accounting. See id. Aerojet removed the case to this Court, see ECF No. 1, and moved to dismiss all of ValveTech’s claims. See ECF Nos. 20-21. ValveTech does not oppose Aerojet’s motion as to the fifth and seventh claims, ECF No. 23 at 5 n.1, so the Court considers Aerojet’s motion as to the remaining five claims and grants it in part.BACKGROUNDAs explained above, ValveTech entered into a series of agreements with Aerojet beginning in 2013 in which ValveTech agreed it would develop valves for Aerojet. See ECF No. 1-3

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