Narrative Opinion Summary
In the case between Med-Data Infotech, Inc. and Revello Medical Management, Inc., Med-Data alleged misappropriation of trade secrets related to a medical insurance billing software program. The dispute arose when a former Med-Data employee allegedly took the software to Revello, which subsequently marketed a similar product. Med-Data sought discovery of Revello's computer source code, which Revello opposed, citing it as a trade secret. The circuit court initially ordered Revello to produce its source code. However, on appeal, the court granted Revello's petition to quash the order, emphasizing that Med-Data did not identify its claimed trade secret with the necessary particularity required under Florida law. The court also stated that Med-Data's refusal to disclose specific details about the source code during discovery weakened its position. The decision highlighted the application of Florida's 'at issue' doctrine, suggesting Med-Data waived any privilege claims over central information to its case. The court noted that should Med-Data establish a valid trade secret, discovery issues might be revisited with potential in-camera reviews considering the technical nature of source code. The order compelling discovery was quashed, with the concurrence of Judges Altenbernd and Wallace, and no opposition from other parties in the circuit court.
Legal Issues Addressed
Discovery and Trade Secret Protectionsubscribe to see similar legal issues
Application: The court ruled that Revello was not required to produce its source code, as Med-Data failed to identify its trade secret with reasonable particularity, which is necessary under Florida law for discovery purposes.
Reasoning: The court granted Revello's petition, ruling that Med-Data failed to identify its trade secret with reasonable particularity, as required by Florida law.
Florida’s 'At Issue' Doctrinesubscribe to see similar legal issues
Application: The court noted that Med-Data's claim of privilege over central information to its legal claim was waived, highlighting the 'at issue' doctrine.
Reasoning: The court noted that under Florida’s “at issue” doctrine, claiming privilege over information that is central to a legal claim is waived.
In-Camera Review of Source Codesubscribe to see similar legal issues
Application: The court suggested that in-camera reviews should account for the complexities involved with computer source code when determining trade secret validity and protection.
Reasoning: While Med-Data is entitled to some protection for its alleged trade secret, the court indicated that any in-camera review of such matters should consider the complexities of computer source code.
Misappropriation of Trade Secretssubscribe to see similar legal issues
Application: Med-Data Infotech, Inc. alleged that a former employee misappropriated its trade secrets by taking a software program when leaving to work for Revello Medical Management, Inc., which is now marketing a similar product.
Reasoning: Med-Data Infotech, Inc. filed a lawsuit against Revello Medical Management, Inc. and Martin Revello, alleging misappropriation of trade secrets related to a software program for medical insurance billing.