Judge Partially Grants Orbital ATK Motion to Dismiss SSL Data Breach Claims

Two of the six data breach complaints SSL brought against Orbital ATK (see 1707240028) were dismissed. In a docket 17-cv-25 order (in Pacer) Friday, U.S. District Judge Raymond Jackson of Norfolk, Virginia, said the Computer Fraud and Abuse Act, Defend Trade Secrets Act, Virginia Uniform Trade Secrets Act (VUTSA) and Virginia Computer Crimes Act complaints stood. But he said common law complaints of conversion and unjust enrichment were pre-empted by SSL claims under VUTSA since they were premised solely on supposed misappropriation of trade secrets.