Evan Brown provides a recap of the ruling in in MacDermid, Inc. v. Deiter. The relevant background of the case is that an employee of a U.S. firm who lived and worked in Canada allegedly accessed her firm’s server in Connecticut from her Canadian location and forwarded confidential corporate information from her work e-mail account to her personal account. The transfer allgedly occurred after she learned she was to be terminated from her position.
MacDermid sued the employee in federal court in Connecticut, alleging unauthorized access and misuse of a computer system and misappropriation of trade secrets in violation of Conn. Gen. Stat. §§ 53a-251 and 35-51 et seq. The employee moved to dismiss based on lack of personal jurisdiction as she resided and worked in Canada. The District Court agreed with the defendant. McDermid then appealed the dismissal.
On appeal, the Second Circuit reversed and remanded. The court held that Connecticut’s long-arm statute did apply because the the server was located in Connecticut. And although there would be some burden for the defendant to travel to Connecticut to defend the suit, that factor did not make jurisdiction in Connecticut unreasonable:
Further, efficiency and social policies against computer-based theft are generally best served by adjudication in the state from which computer files have been misappropriated. Accordingly, we conclude that jurisdiction is reasonable in this case.
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