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December 2014: Victory for Pinterest on Idea Theft Claim

December 2014

The firm recently obtained dismissal with prejudice of a “Winklevoss-type” claim for Pinterest. In late 2012, plaintiff Theodore F. Schroeder, the owner of a now defunct website called Rendezvoo.com, filed a complaint in federal court, alleging that he and his fellow Rendezvoo.com co-founders originally developed the idea for a website very similar to the Pinterest.com website. The complaint went on to allege that the idea for their site was stolen from plaintiffs by one of their former partners who, they contended, then gave the idea to Pinterest’s founders. The complaint brought claims for trade secret misappropriation and other related claims.

After the complaint was dismissed for lack of subject matter jurisdiction, plaintiffs subsequently re-filed the action in state court. The firm then moved to dismiss plaintiffs’ complaint, and after briefing by the parties, Justice Melvin Schweitzer of the New York Supreme Court—Commercial Division granted Pinterest’s motion to dismiss in its entirety, and dismissed Pinterest from the case with prejudice. In granting the motion to dismiss, Justice Schweitzer credited Quinn Emanuel’s argument that plaintiffs’ purported trade secrets were not protectable in the first instance, as plaintiffs had previously made them public through their Rendezvoo.com website. The Court also sided with Quinn Emanuel in finding that plaintiffs did not sufficiently allege any relationship between plaintiffs and Pinterest as was required to sustain plaintiffs’ other claims for unjust enrichment and misappropriation of skills and expenditures. And finally, the Court found that plaintiffs had demonstrated no bad faith, corporate espionage or other misconduct by Pinterest, as was needed to support plaintiffs’ claims.