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Morpho Corp. v. Laser Applications, Inc.

Citations: 790 So. 2d 577; 2001 Fla. App. LEXIS 10392; 2001 WL 844459Docket: No. 5D01-843

Court: District Court of Appeal of Florida; July 27, 2001; Florida; State Appellate Court

Narrative Opinion Summary

In this case, petitioners sought certiorari review of a trial court's decision regarding the disclosure of a customer list, which they claimed as a trade secret, in the context of an ongoing lawsuit. The lawsuit arose from allegations that respondents sabotaged petitioners' business by falsely accusing them of theft of trade secrets, resulting in their arrest and business interruption. During discovery, respondents requested detailed information about the petitioners' business activities involving 'laser welded bellows' from 1996-2000, including a customer list created after 1999. Petitioners objected, asserting the list was a protected trade secret, while respondents argued its necessity for evaluating damages related to malicious prosecution claims. The appellate court found that the trial court failed to adequately address the trade secret privilege and should have conducted an in-camera review to determine appropriate protective measures. Consequently, the appellate court granted the petition for writ of certiorari and remanded the case for further proceedings to ascertain the trade secret status of the customer list for 1999 and 2000. Judges Sharp and Griffin concurred with the decision.

Legal Issues Addressed

Certiorari Review in Discovery Disputes

Application: Certiorari review is appropriate where a trial court order potentially violates trade secret protections without adequate procedural safeguards.

Reasoning: Petitioners are seeking a certiorari review of a trial court order that denied their objection to interrogatories requiring them to disclose a customer list.

Obligation to Conduct In-Camera Review

Application: The trial court is required to conduct an in-camera review when there is a dispute over the trade secret status of information to ensure proper protection.

Reasoning: The court found that the trial court failed to provide an adequate opportunity for the parties to present their arguments regarding the trade secret privilege and should have conducted an in-camera review to assess protective measures.

Trade Secret Protection under Civil Discovery

Application: The court must assess whether disclosed information in discovery qualifies as a trade secret and determine appropriate protective measures.

Reasoning: The court found that the trial court failed to provide an adequate opportunity for the parties to present their arguments regarding the trade secret privilege and should have conducted an in-camera review to assess protective measures.