Was Quintara Biosciences Really A Sea Change In California Trade Secret Litigation?

Last August the Ninth Circuit issued a decision in a trade secrets case that many viewed at the time as a game changer. In Quintara Biosciences, Inc. v. Ruifeng Biztech, Inc., the Ninth Circuit reversed a district court's order striking as a discovery sanction trade secret claims asserted under the federal Defend Trade Secrets Act based on the plaintiff's failure to disclose its trade secrets with "reasonable particularity." In striking the trade secrets, the district court had "borrowed" from a pre-discovery disclosure requirement under California's statutory Uniform Trade Secret Act, which the Ninth Circuit held was inapplicable to a DTSA claim under the circumstances.

In the wake of this decision many "hot take" summaries and articles breathlessly predicted that the Ninth Circuit's decision would amount to a paradigm shift in California trade secret litigation. It was variously described as a "watershed moment," that it would lead to a relaxation in "pleading standards," and that there would be "no more early gatekeeping" in DTSA cases.

But was this foresight or a false alarm? With the benefit of hindsight, the answer appears to be the latter. In the several months since the Ninth Circuit's decision in Quintara Biosciences, California district courts have met the decision with something of a collective judicial shrug. The fact is that district courts continue to analyze DTSA and CUTSA claims under the same legal standards, and continue to require a plaintiff to identify its trade secrets with "sufficient particularity" to survive a motion to dismiss.

Trial Court Proceedings and the Ninth Circuit's Decision.

Quintara Biosciences is a good old fashioned California trade secret case. The parties in the case, Quintara (the plaintiff), and Ruifeng (the defendant), were engaged in a joint venture that went south, at which point Ruifeng allegedly locked Quintara out of its offices, began hiring Quintara employees, and stole Quintara's proprietary information.

Quintara sued under the DTSA but did not allege a separate cause of action under CUTSA. Under CUTSA, "before commencing discovery" the plaintiff must "identify the trade secret with reasonable particularity."¹ While the DTSA has no such provision, it requires a plaintiff to identify its purported trade secrets with "sufficient particularity."² Since the DTSA's enactment in 2016, trade secret plaintiffs have frequently asserted claims under both the DTSA and CUTSA, and given their similarities, district courts in California had just as frequently analyzed these claims together. Indeed, that approach has been approved by the Ninth Circuit.³

At the outset, Ruifeng did notmove to dismiss the DTSA claim. Instead, it moved for a protective order, at which point the district court directed the plaintiff to disclose its trade secrets with "reasonable particularity." While the district court recognized that state procedure "does not govern here," it had "often borrowed" from the "tried and true" pre-discovery disclosure requirement specified in CUTSA,⁴ as did many other California district courts. Quintara filed the disclosure, but Ruifeng maintained it was inadequate. At that point the district court invited Ruifeng to take a stand: either accept the disclosure and proceed to discovery, or move to strike the disclosure, withhold discovery, and "accept the consequences if wrong."⁵

Ruifeng chose the latter option and moved to strike, at which point the district court struck as inadequate nine of the eleven trade secrets. Following a trial on the remaining trade secret (one of the two remaining trade secrets was abandoned pre-trial), the case went to the Ninth Circuit.

The Ninth Circuit reversed the district court's order striking nine of the eleven trade secrets, holding that "the federal DTSA does not require a plaintiff to identify with particularity its alleged trade secrets from the start."⁶ While it recognized that CUTSA's "reasonable particularity" requirement and the DTSA's "sufficient particularity" requirement were "similar," whether a DTSA plaintiff has identified its purported trade secrets with sufficient particularity was "a question of fact" and "is usually a matter for summary judgment or trial."⁷ The Ninth Circuit explained that neither Rule 12(f) nor Rule 16 authorized the district court's order striking nine of the eleven trade secrets at issue, and that "a DTSA trade-secret claim will rarely be dismissible as a discovery sanction in a situation like this."⁸ The court further emphasized that the case presented only a DTSA claim, and therefore it did not address whether CUTSA's pre-discovery disclosure rule was "binding" on federal courts considering CUTSA claims.⁹

California District Court Decisions Post-Quintara.

It is undoubtedly true that the Ninth Circuit used broad language in delineating the particularity requirements of CUTSA and the DTSA, and in describing the particularity requirement under the DTSA as a "fact" question that is "usually" decided on "summary judgment or trial." Taken literally one could argue, as some plaintiffs have, that since particularity is a "fact" question it cannot be decided on a motion to dismiss. The counter view is based on the procedural posture of the case, and that the Ninth Circuit's broad language must be read within the specific context in which the case arose. In reality, this view goes, the Ninth Circuit decided only a narrow procedural question; whether it was ever appropriate for a district court to strike DTSA claims as a discovery sanction DTSA claims for failure to comply with a pre-discovery disclosure obligation imposed under California law. Even then, the Ninth Circuit emphasized that its holding was context-specific and used hedging language to describe it. Nor did it foreclose the possibility that dismissal as a discovery sanction might be appropriate in a different case.

Whatever the merits of these competing interpretations, the decision has certainly not produced the sea change in trade secret litigation that some predicted. To the contrary, in the wake of Quintara Biosciences, California district courts considering motions to dismiss DTSA and CUTSA claims have continued to apply the same legal framework, including with respect to particularity.

In the Central District, examples include 1nteger LLF v. Almeida which noted "courts often analyze" DTSA and CUTSA claims "together" because they are "substantially similar,"¹⁰ and Paramount Tariff Servs. v. Ace Tariff Sols, Inc., which applied the same pleading test "under both the federal DTSA and the CUTSA."¹¹ In the former case, the district court dismissed trade secret claims because the plaintiff had failed to identify them with particularity,¹² and in the latter case, the district court held that only one out of the five alleged trade secrets were sufficiently pled.¹³ Similarly, in the Eastern District one court held that "the DTSA and the CUTSA share the same pleading requirements for the identification of trade secrets," and analyzing both claims together, held that the plaintiff's trade secrets were too broad, and not "sufficiently particular" to pass muster under Rule 12(b)(6).¹⁴

The same thing is true in the Northern District. In cases asserting DTSA and CUTSA claims, courts have analyzed them together because of their "substantially similar elements."¹⁵ This includes cases involving the defense arguments that trade secrets were not pleaded with particularity. In one such case, the court denied leave to amend to add DTSA and CUTSA claims on futility grounds because the allegations of "trade secrets" as "integrated in the design of the chips" was "not even close to adequate."¹⁶

In another Northern District case, Confluent, Inc. v. Slower, LLC, the court observed that DTSA and CUTSA impose "nearly the same pleading requirements." It held that the plaintiff hadpleaded its trade secrets with sufficient particularity because they were "contained within specific documents" and did not rely on "catch-all" descriptions, but nonetheless dismissed the trade secret claims on other grounds.¹⁷ In Confluent, the district court, in a footnote, mentioned the Ninth Circuit's decision in Quintara Biosciences and observed it was "not relevant here."¹⁸ In other words, the decision was based on the specific allegations presented and on the application of legal principles that long pre-dated Quintara Biosciences.

What is striking in these cases is the absence of any discussion about Quintara Biosciences at all. For the most part, the decisions do not so much as mention or cite Quintara Biosciences, or, as in Confluent it is reduced to a passing reference in a footnote as "not relevant" on a motion to dismiss.

The lone exception to this is PTC Therapeutics, Inc. v. Acurex Biosciences Corp. In that case the district court noted that DTSA and CUTSA claims are "substantially similar" and should be analyzed together.¹⁹ The district court then discussed Quintara Biosciences and that "the Ninth Circuit has recently noted an important distinction between the two statutes."²⁰ The district court after discussing the Ninth Circuit's decision held that, in light of the decision, "the level of specificity required in delineating a plaintiff's trade secrets at the pleading stage differs depending on whether the claim arises under DTSA or CUTSA."²¹ After making this distinction, however, the district court essentially proceeded to ignore it. As in all other cases, it simply applied established legal principles that pre-dated Quintara Biosciences. It asked whether the plaintiff had described its trade secrets "with sufficient particularity to separate it from matters of general knowledge in the trade," or whether it was based upon "catch all phrases."²² After carefully analyzing the five alleged trade secrets, the district court found that two of them passed muster and the others did not, and went on to dismiss the entirety of the DTSA and CUTSA claims for failure to plead misappropriation.²³

So much for a watershed.

Conclusion.

In California district courts, gatekeeping on a motion to dismiss trade secret claims is alive and well. Despite Quintara, pleading requirements remain robust, and trade secret plaintiffs would be wise to avoid generic pleading, high-level abstractions, and catch-all definitions. Given their long history, and CUTSA's influence on the DTSA itself, practitioners should continue to expect claims to be analyzed together. 

Footnote

1. Code Civ. Proc. § 2019.210.

2. InteliClear, LLC v. ETC Glob. Holdings, Inc., 978 F.3d 653, 658 (9th Cir. 2020).

3. Id. at 657 (concluding it was "appropriate" to analyze DTSA and CUTSA claims together given that they are "substantially similar").

4. Quintara Biosciences, Inc. v. Ruifeng Biztech Inc., 2021 WL 965349, at *1 (N.D. Cal. Mar. 13, 2021).

5. Id. at *1.

6. Quintara Biosciences, Inc. v. Ruifeng Biztech, Inc., 149 F.4th 1081, 1085 (9th Cir. 2025).

7. Id.

8. Id. at 1091.

9. Id. at 1088 n.1.

10. 1nteger LLC v. Almeida, 2025 U.S. Dist. LEXIS 256840, at *8 (C.D. Cal. Dec. 11, 2025) (citing InteliClear).

11. Paramount Tariff Servs. v. Ace Tariff Sols., Inc., 2025 WL 3526644, at *2 (C.D. Cal. Dec. 9, 2025).

12. 1nteger LLC, 2025 U.S. Dist. LEXIS 256840, at *9-11.

13. Paramount Tariff Servs., 2025 WL 3526644, at *2.

14. PMM Holdings, LLC v. William W. Meyer & Sons, Inc., 2025 WL 3764051, at *10 (E.D. Cal. Dec. 30, 2025).

15. Ventura v. IQVIA Inc., 2026 WL 776836, at *4 (N.D. Cal. Mar. 19, 2026) (dismissing CUTSA and DTSA claims for failure to sufficiently allege ownership of a trade secret).

16. Google LLC v. Point Fin., Inc., 2026 WL 579462, at *3 (N.D. Cal. Mar. 2, 2026).

17. Confluent, Inc. v. Slower, LLC, 2026 WL 673582, at *10 (N.D. Cal. Mar. 10, 2026).

18. Id. at *9 n.3.

19. 2026 WL 350772, at *5 (N.D. Cal. Feb. 9, 2026).

20. Id. at *5.

21. Id. at *5.

22. Id. at *5.

23. Id. at *1.

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