The post Michael J. Betts LLC Client Wins $500,000 FINRA Arbitration Award appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>The post Michael J. Betts LLC Client Wins $500,000 FINRA Arbitration Award appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>The post Supreme Court: Contract language must be clear for class arbitration appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>Arbitration is a type of alternative dispute resolution. Parties and their attorneys appear before a neutral arbitrator upon whom they have mutually agreed. The arbitrator can be required to be an expert in the area to be considered. The rules of evidence and court procedure are modified, generally allowing more flexibility. In most cases, an arbitration ruling cannot be appealed or taken back to court.
The case in Lamps Plus involved an alleged breach of security in which private information about some 1,300 employees was released to hackers. When one man found that a tax return had been filed in his name by identity thieves, he filed a federal class action against Lamps Plus.
Lamps Plus argued that its contract with the plaintiff employees required them to resolve any disputes with the company in individual arbitration. The class action was transferred into arbitration, but the federal district court decided to hold open the option for classwide arbitration because the contract language was ambiguous.
Since the case was taking part in California, a California rule was employed. That rule was that, when there is any ambiguity in contract language, the issue should be interpreted against the party that drafted the contract. In other words, the federal district court — and later the Ninth Circuit — held that courts should interpret the contract in the plaintiffs’ favor.
The U.S. Supreme Court disagreed. Writing for the majority, Chief Justice John Roberts opined that contracting parties would be unlikely to choose a contract that called for classwide arbitration because it offers few of the benefits of individual arbitration.
“Neither silence nor ambiguity provides a sufficient basis for concluding that parties to an arbitration agreement agreed to undermine the central benefits of arbitration itself,” he wrote.
In addition, the majority ruled that the California rule does not apply to classwide arbitration. Past cases and the Federal Arbitration Act, the court decided, require both parties’ actual consent before classwide arbitration can be required. Ambiguity in contract language is not enough.
The four dissenters essentially argued that the majority opinion is one of several recent opinions that have required individual arbitration instead of class-based remedies. This, wrote Justice Ruth Bader Ginsberg, “has hobbled the capacity of employees and consumers to band together in a judicial or arbitral forum” against powerful companies.
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]]>The post Resolving disputes through mediation appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>The mediation format ideally sidesteps a contentious courtroom fight by collaboratively working towards an equitable solution that both sides can live with. It is also more private since the courts maintain case information in public records.
People assume that mediators always facilitate negotiations between the parties, but there are a variety of mediation formats. According to the Harvard Law School, the seven most common forms are:
It is often beneficial to discuss case goals and the dispute’s history with an experienced alternative dispute resolution neutral to determine the best resolution strategy. Individual mediators and lawyers have their own approaches, so it is best if the clients and lawyers discuss a desired approach with the prospective mediator. Most effective mediators are able to tailor their approach to what is best suited for each particular case, rather than using a “one size fits all” approach.
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]]>The post United States District Court for the Western District of Pennsylvania Amends ADR Policies and Procedures to Add Flexibility to the ADR Process appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>The amendments are subtle but noteworthy. The first set of changes are to Sections 3.1 and 3.8 of the Policies and Procedures and recognize the ability of mediators to employ an evaluative approach in conducting a mediation. The existing ADR Policies & Procedures require mediators to use a facilitative, rather than evaluative, approach. The amendments provide that although mediations will presumptively be facilitative, the mediator should be prepared to provide “evaluative assessments” if requested by all parties. This additional flexibility in structuring mediations should be helpful in resolving cases, as an evaluative approach, used properly and judiciously, can be an extremely effective tool for mediators to use in assisting the parties and their counsel to recognize the risks of the positions they are taking. Mediators who employ an evaluative approach in a case need to thoroughly prepared for the mediation and have an understanding of the factual and legal issues involved in the case in order to provide a meaningful evaluative assessment. It will be advisable for mediators and counsel to discuss, during the pre-mediation conference call held in advance of a mediation, whether the parties and counsel desire that the mediator to employ an evaluative approach if the mediator believes that using such an approach would enhance settlement possibilities.
The second set of amendments provides the Court with additional flexibility in connection with the timing and scheduling of mediations and ENEs. Section 3.4 of the Court’s ADR Policies and Procedures provides that the deadline for conducting a mediation, unless otherwise ordered by the Court, is sixty days following the Rule 16 initial scheduling conference. This provision is retained, but the amendments add the following sentence: “This is a presumptive timeline for the ADR proceeding, subject to adjustment by the Court to meet the needs of the case.” Section 4.4 of the Policies and Procedures, which relates to the timing and scheduling of ENEs, is similarly amended. These amendments should enhance the overall effectiveness of the Court’s ADR Program, as they recognize that the timing of an ADR session can be a very important factor in determining whether the ADR is successful and that the Judges can adjust the sixty-day deadline where doing so might contribute to the prospects of settlement.
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]]>The post Supreme Court of Pennsylvania Issues Significant Ruling Holding that Employers have Duty to Safeguard Employees’ Personal Information and Clarifying Contours of Economic Loss Doctrine appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>The case was filed as a class action on behalf of certain UPMC employees, arising out of a data breach through which personal information related to UPMC’s employees allegedly was stolen from UPMC’s computer systems. The Complaint further alleged that the stolen data, which UPMC had required the employees to provide to it as a condition of employment, was used to file fraudulent tax returns on behalf of certain employees, resulting in actual damages. The employees claimed that UPMC was negligent in failing to exercise reasonable care in safeguarding their personal information.
The trial court granted UPMC’s preliminary objections, declining to find that a negligence cause of action existed for alleged harm arising from a data breach. Among other reasons, the trial court observed the widespread nature of data breaches and expressed concern that allowing such a cause of action could burden the courts with numerous lawsuits. The trial court also found that the employees’ negligence claim was barred by the economic loss doctrine, as the only losses claimed were economic in nature. In a split decision, a panel of the Superior Court affirmed the trial court’s decision.
In reversing the Superior Court, the Supreme Court applied general negligence principles and had little apparent difficulty in concluding that UPMC owed a duty to the employees, “in collecting and storing Employees’ data on its computers systems, … to exercise reasonable care to protect them against an unreasonable risk of harm arising out of that act.” The Court further held that the criminal wrongdoing of third parties in accessing and misusing the data did not provide a defense to UPMC, at least at the pleadings stage of the case, because the alleged deficiencies in UPMC’s data collection and storage practices were such that “a cybercriminal might take advantage of the vulnerabilities in UPMC’s computer system and steal Employees’ information.”
The Court next addressed whether the employees’ negligence claim was barred by the economic loss doctrine. That doctrine has been generally applied by Pennsylvania courts to bar negligence claims that result solely in economic damages unaccompanied by physical injury or property damage. The Court proceeded with a lengthy discussion of its prior decisions applying the economic loss doctrine – Excavation Technologies, Inc. v. Columbia Gas Co. of Pa., 985 A.2d 840 (Pa. 2009), and Bilt-Rite Contractors, Inc. v. The Architectural Studio, 866 A.2d 270 (Pa. 2005) – and held that “those cases do not stand for the proposition that the economic loss doctrine, as applied in Pennsylvania, precludes all negligence claims seeking economic damages.” The Court explained that the existence of a tort cause of action depends on the source of the duty that the plaintiff contends was owed: “[I]f the duty arises under a contract between the parties, a tort action will not lie from breach of that duty. However, if the duty arises independently of any contractual duties between the parties, then a breach of that duty may support a tort action.” The Court explicitly rejected UPMC’s argument that the Court’s opinion in Bilt-Rite should be read to provide for a broad application of the economic loss doctrine, subject only to a narrow exception for negligent misrepresentation claims under Section 552 of the Restatement (Second) of Torts. The Court concluded: “Employees have asserted that UPMC breached its common law duty to act with reasonable care in collecting and storing their personal and financial information on its computer systems. As this legal duty exists independently from any contractual obligations between the parties, the economic loss doctrine does not bar Employees’ claim.” Interestingly, the Court’s formulation and application of the economic loss doctrine in Dittman arguably results in the further melding of that doctrine with Pennsylvania’s “gist of the action” doctrine. See Bruno v. Erie Ins. Co., 106 A.3d 38 (Pa. 2014).
Dittman undoubtedly will prove to be a significant decision in Pennsylvania jurisprudence – both with respect to the evolving law regarding employer liability for data breaches and to the contours of the economic loss doctrine.
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]]>The post The Federal Defend Trade Secrets Act — Emerging Case Law in the Third Circuit appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>A post earlier this year provided an overview of the DTSA and discussed some of the more significant cases that had been decided under the statute. Now that the DTSA has been in effect for approximately two and one-half years, the case law under the statute is becoming more developed and various decisions have been issued within the Third Circuit under the DTSA. This post discusses those decisions. As the Court of Appeals for the Third Circuit has not yet issued any opinions substantively addressing the provisions of the DTSA, the cases discussed in this post are all district court decisions within the Third Circuit.
In order to pursue a claim under the DTSA for misappropriation of a trade secret, the trade secret must be “related to a product or service used in, or intended for use in, interstate or foreign commerce.” 18 U.S.C. §§ 1836(b)(1). In Marimar Textiles, Inc. v. Jude Clothing & Accessories Corp., No. 17-2900 (JLL), 2017 U.S. Dist. LEXIS 163458, at *18-19 (D.N.J. Oct. 2, 2017), the court ruled that allegations that the defendants improperly used plaintiff’s trade secrets to create infringing goods, which were intended to be sold throughout the United States, were sufficient to survive a motion to dismiss. On the other hand, two district court rulings in the Third Circuit illustrate that the courts will enforce compliance with this jurisdictional requirement. For example, in Government Employees Ins. Co. v. Nealey, No. 17-807, 262 F. Supp. 3d 153 (E.D. Pa. June 13, 2017), the court dismissed a DTSA claim because the plaintiff had failed to allege a nexus between the trade secrets that were the subject of its claim and interstate commerce. Similarly, in Hydrogen Master Rights, Ltd. v. Weston, 228 F. Supp. 3d 320 (D. Del. 2017), the court dismissed a DTSA claim without prejudice where the plaintiff failed to allege a nexus between the alleged trade secret and interstate commerce.
Numerous district court cases in the Third Circuit have addressed the issue of whether a claim may be pursued under the DTSA where the alleged trade secret misappropriation occurred before the effective date of the statute (May 11, 2016) but where the defendant allegedly wrongfully used the trade secret after the effective date. The cases in the Third Circuit have uniformly held that such allegations state a claim under the DTSA. E.g., 123 Exteriors, Inc. v. N. Star Exteriors, LLC, No. 17-4337, 2018 U.S. Dist. LEXIS 128748, at *20-22 (E.D. Pa. Aug. 1, 2018); PDC Machines Inc. v. Nel Hydrogen A/S, No. 17-5399, 2018 U.S. Dist. LEXIS 100506, at *9-11 (E.D. Pa. June 15, 2018); Teva Pharmaceuticals USA, Inc. v. Sandhu, 291 F. Supp. 3d 659, 674-75 (E.D. Pa. 2018); Quintiles IMS Inc. v. Veeva Systems, Inc., No. 17-00177 (CCC), 2017 U.S. Dist. LEXIS 177328, at *11 (D.N.J. Oct. 26, 2017); Marimar Textiles,2017 U.S. Dist. LEXIS 163458 at *17-18; Brand Energy & Infrastructure Servs. v. Irex Contracting Group, No. 16-2499, 2017 U.S. Dist. LEXIS 43497, at *11-19 (E.D. Pa. Mar. 24, 2017). In Brand Energy, Judge Stengel observed that while the Uniform Trade Secrets Act provides that it does not apply to “continuing misappropriation that occurs after the effective date,” the DTSA does not contain such a provision.
At least one court has used a similar approach in determining whether a claim is barred by the DTSA’s three-year statute of limitations. Marimar Textiles, 2017 U.S. Dist. LEXIS 163458 at *18 (denying motion to dismiss based on statute of limitations, where plaintiff alleged that there were continuing violations and that wrongful use of the misappropriated trade secrets occurred within three years of the filing of suit).
The most basic element of a claim under DTSA is a showing that the allegedly misappropriated information qualifies as a “trade secret.” As Judge Cercone observed earlier this year, although DTSA and PUTSA define trade secrets in a different manner, the statutes protect the same information – i.e., information that: (i) the owner has taken reasonable means to keep secret; (ii) derives independent economic value, actual or potential, from being kept secret; (iii) is not readily ascertainable by proper means; and (iv) cannot be readily accessed by others and would obtain economic value from its disclosure or use. Pharmerica Corp., Sturgeon, No. 2:16cv1481, 2018 U.S. Dist. LEXIS 43236, at *10-11 (W.D. Pa. Mar. 16, 2018); accord,123 Exteriors, 2018 U.S. Dist. LEXIS 128748 at *22.
Judge Stengel in Brand Energyidentified various ways in which an actionable misappropriation can be established the DTSA, including (i) the acquisition of a trade secret of another by a person who knows or has reason to know that the trade secret was acquired by improper means, and (ii) when one discloses or uses another’s trade secret without the consent of the trade secret owner. Brand Energy, 2017 U.S. Dist. LEXIS 43497 at 8-9, citing18 U.S.C. § 1839(5)(A), (B).
No cases have been decided within the Third Circuit to date that analyze the remedies available under DTSA. This should not be surprising, as few, if any, DTSA claims have proceeded to trial. In general, the DTSA provides for potential awards of both equitable relief and various forms of monetary damages. 18 U.S.C. § 1836(b)(3). The primary types of damages that may be awarded are: (i) actual losses, i.e., the plaintiff’s lost profits from the misappropriation; and (ii) unjust enrichment damages, to the extent not duplicative of actual loss damages. The third category of potential damages is a reasonable royalty for the unauthorized disclosure or use of the trade secret. 18 U.S.C. § 1836(b)(3)(B). Given the language of the statute as well as its legislative history, it can be anticipated that the courts will not regard this category of potential damages as the preferred remedy and that an award of royalty damages will be considered only if the plaintiff cannot be made whole through an award of the other forms of damages.
Like the Uniform Trade Secrets Act, the DTSA also contains provisions authorizing awards of exemplary damages (up to two times the amount of actual loss and unjust enrichment damages awarded). 18 U.S.C. § 1836(b)(3)(C). The DTSA also parallels the Uniform Act by providing that attorneys’ fees are recoverable (i) by a prevailing plaintiff if the trade secret was willfully and maliciously misappropriated, and (ii) by a prevailing defendant if the claim of misappropriation was made in bad faith. 18 U.S.C. § 1836(b)(3)(D).
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]]>The post Pennsylvania Superior Court Rejects its Prior Decisions and Adopts Expansive Reach of Consumer Protection Statute, Ruling that the UTPCPL Imposes Strict Liability appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>The Gregg case arose out of the purchase of a variable life insurance policy, which the plaintiffs claimed to result from misrepresentations and deceptive conduct on the part of the defendants. At trial, the jury returned defense verdicts on the counts alleging fraudulent and negligent misrepresentations. The trial judge, however, found in favor of the Greggs on a claim under the UTPCPL and awarded damages. Approximately sixty percent of the award consisted of attorney fees and costs claimed on behalf of the Greggs.
In an opinion authored by Judge Kunselman, the Panel addressed whether the jury’s defense verdict on the misrepresentation claims precluded the trial judge’s verdict in favor of the Greggs under the UTPCPL. The Panel ruled that the UTPCPL verdict was not precluded by res judicata or collateral estoppel, finding that “deceptive conduct” under the UTPCPL’s catchall provision can be established in the absence of fraudulent or negligent misrepresentations. In so ruling, the Panel departed from recent Superior Court decisions – e.g., Kirwin v. Sussman Automotive, 149 A.3d 333 (Pa. Super. 2016), and Dixon v. Northwestern Mutual, 146 A.3d 780 (Pa. Super. 2016) – that had expressly held that in order to prove deceptive conduct, consumers were required, at a minimum, to provide a common law negligent misrepresentation. Indeed, Judge Olson had written in Dixon: “Deceptive conduct ordinarily can only take one of two forms, either fraudulent or negligent.” The other panelists in Dixon were President Judge Ford Elliott and Judge Strassburger.
In departing from other Superior Court decisions, the Panel expressed the novel view that the UTPCPL imposes strict liability: “[A]ny deceptive conduct … is actionable … whether committed intentionally (as in a fraudulent misrepresentation), carelessly (as in a negligent misrepresentation), or with the utmost care (as in strict liability).” In support of this view, the Panel relied heavily on a Commonwealth Court decision that involved a public enforcement action under the UTPCPL and that pre-dated Kirwin and Dixon by five years. Commonwealth v. TAP Pharmaceutical Products, Inc., 36 A.3d 1197 (Pa. Cmwlth. 2011), reversed on other grounds, 94 A.3d 350 (Pa. 2014).
The Gregg decision, particularly when accompanied by inconsistent decisions reached by panels in other cases, is likely to engender ongoing confusion among the courts and practitioners concerning the proper interpretation and application of the catchall provision. For example, one might question how one charged with a violation of the UTPCPL could be found to engage in deceptive conduct (i.e., conduct that deceives) in the absence of any intent or fault. It is remarkable that the meaning of “deceptive conduct” as used in the UTPCPL – a fundamental and critically important element of the statute – continues to confound, now twenty-two years after the amendment introducing that prong of actionable conduct. Particularly in light of Gregg, the courts and practitioners will continue to grapple with the interpretation of the UTPCPL’s catchall provision until the Pennsylvania Supreme Court provides guidance and clarity. Several opinions of Pennsylvania’s highest court have made references to the potential scope of the catchall provision. The Court, however, has not yet directly confronted the degree of intent or fault that must be shown to prove deceptive conduct that could give rise to UTPCPL liability. To the extent the Supreme Court has addressed the catchall provision, it has done so in a manner that suggests that Gregg’sstrict liability formulation of the UTPCPL may be of dubious validity. E.g., Grimes v. Enterprise Leasing Co. of Philadelphia, LLC, 105 A.3d 1188, 1192 n.3 (Pa. 2014) (although the Court had granted review in Grimes to consider whether a private plaintiff who alleges deceptive conduct under the catchall provision is required to plead and prove justifiable reliance, the Court declined to address the issue in Grimes because another issue was dispositive); Milliken v. Jacono, 96 A.3d 997, 1003 (Pa. 2014) (stating that in order to establish liability under the catchall provision, “a plaintiff must show that he justifiably relied on the defendant’s wrongful conduct or representation, and that he suffered harm as a result of that reliance”)(concurrence by Madame Justice Todd), citing Yocca v. Pittsburgh Steelers Sports, Inc., 854 A.2d 425, 438 (Pa. 2004). Significantly, the allegedly wrongful conduct involved in all three cases – Grimes, Milliken and Yocca– occurred after the 1996 amendment to the UTPCPL and with the “deceptive conduct” element in effect. The Gregg opinion, however, does not discuss any of these cases or their potential significance.
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]]>The post Pennsylvania Superior Court Applies Two-Year Tort Statute of Limitations in Affirming Dismissal of Legal Malpractice Claim appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>The underlying case was a protracted divorce proceeding in which the plaintiff (Seidner) in the malpractice action had been represented by the defendants in the malpractice action. Seidner filed her legal malpractice action as a breach of contract claim, presumably to have the claim governed by Pennsylvania’s four-year statute of limitations applicable to contract actions. The trial court ruled that, regardless of how Seidner had styled her claim, it was governed by the shorter tort statute of limitations because the claim sounded in tort based on the “gist of the action” doctrine.
In affirming, the Superior Court reviewed the different elements for proving legal malpractice under tort and contract theories. The Court heavily relied on the Pennsylvania Supreme Court’s decision in Bruno v. Erie Ins. Co., 106 A.3d 48 (Pa. 2014), which set forth new standards for application of the “gist of the action” doctrine, including the principle that the mere existence of a contract between the parties does not mean that a claim by one of the contracting parties arising out of performance of the contract necessarily sounds in contract. At bottom, according to the Superior Court in Seidner, the legal malpractice claim before the Court was not predicated on the alleged breach of any specific, executory promise and, rather, was based on the allegation that the defendant lawyers negligently performed their obligations. The Court found support in the expert report of Seidner’s expert, which provided the opinion that the lawyers had failed to exercise ordinary skill and knowledge.
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]]>The post Third Circuit Holds That FINRA Arbitration Requirement Trumps Forum Selection Clause appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>The case arose out of broker-dealer agreements between Bear Stearns (later acquired by J.P. Morgan Securities) and Reading Health System regarding multiple offerings of auction-rate securities (ARS) by Reading Health. J.P. Morgan Securities served as the underwriter and broker-dealer for each offering. The agreements provided that any actions and proceedings arising out of the agreement or the underlying ARS transactions had to be filed in the United States District Court for the Southern District of New York. Following the collapse of the ARS market, Reading Health filed a statement of claim with FINRA, alleging that J.P. Morgan Securities engaged in wrongful conduct with respect to the ARS offerings. J.P. Morgan Securities refused to participate in FINRA arbitration, relying on the forum selection clause, and Reading Health filed a declaratory judgment action to resolve the issue of arbitrability. The district court ordered J.P. Morgan Securities to arbitrate.
In its recent ruling, the Panel affirmed the order of the district court requiring J.P. Morgan Securities to participate in the FINRA arbitration. The Panel ruled that FINRA Rule 12200 – generally requiring FINRA members to arbitrate disputes with their customers at the customers’ request – controlled. The Panel rejected J.P. Morgan Securities’ argument that in agreeing to the forum selection clauses included in the broker-dealer agreements Reading Health waived the right to FINRA arbitration that it otherwise would have had under FINRA Rule 12200. Applying general principles of waiver, the Panel held that the forum selection clauses, which did not refer to arbitration, lacked the specificity that was required in order to support a finding of waiver. The Panel suggested that although waiver of FINRA Rule 12200 might be found in an appropriate case, the assertion of waiver would need to be supported by specific language referring to a waiver of that specific right. The Panel addressed J.P. Morgan Securities’ position that an implied waiver could be found, ruling that the concept of implied waiver would not be applied when the right in question – submitting disputes to FINRA arbitration – arises out of a binding, regulatory rule that has been adopted by FINRA and approved by the SEC.
The Panel acknowledged a split among the circuits on this issue. In particular, as noted by the Panel, the Second and Ninth Circuits have held that forum selection clauses required litigation of the disputes, while the Fourth Circuit has held that FINRA Rule 12200 requires arbitration notwithstanding the presence of a forum selection clause.
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]]>The post U.S. District Court for the Western District of Pennsylvania revises ADR procedures appeared first on Business Law Attorneys | Pittsburgh Law Firm.
]]>A red-lined version of the revised ADR Policies and Procedures can be found here.
The updated ADR Policies and Procedures, effective April 23, 2018, can be found here.
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