Timothy A. Gognat, Petitioner v. Chet J. Ellsworth, Joanne Ellsworth, Stephen Smith, and Msd Energy Inc., Respondents

Summary

The court affirmed summary judgment dismissing Gognat’s trade-secret misappropriation claim as untimely. It held that the proprietary information allegedly misappropriated constituted one trade secret, so the limitations period began when Gognat knew of an earlier misappropriation, more than three years before suit. The court also held that whether information constitutes one trade secret or multiple trade secrets is a legal question when the underlying historical and scientific facts are undisputed.