State Farm and Safelite have filed court documents replying to LYNX Services’ latest arguments in the case over alleged trade secret misappropriation.
State Farm and Safelite moved to dismiss the lawsuit on August 19, claiming LYNX failed to show any actual trade secret misappropriation and had violated its dispute-resolution agreement with State Farm. LYNX responded on September 5, claiming it had not breached the agreement because it had also filed for an injunction. The LYNX also claimed that State Farm had admitted that LYNX owned the alleged trade secrets.
State Farm and Safelite doubled down on their motions to dismiss on September 12, saying LYNX’s injunction attempt would have invalidated the agreement only if it had limited its claims to “equitable relief.” LYNX “seeks a wide variety of monetary and equitable relief,” according to State Farm’s response, which means the agreement still stands.
LYNX had claimed its conflict-resolution agreement with State Farm was ambiguous, especially regarding the definition of “State Farm Information.” Safelite’s latest response quotes portions of the agreement allegedly defining “State Farm Information.”
“[The agreement] specifically defines the scope of STATE FARM Information as ‘including but not limited to Personal Data,’” Safelite’s argument says. “That is not ambiguous.”
Safelite’s court filing also alleges that LYNX’s September 5 filing listed “a new purported trade secret for the first time” called “customized offers.”
“‘Customized offers’ is undefined in the complaint,” Safelite alleges. “LYNX may not use its opposition [filed September 5] to define and claim new rights.”
Safelite’s document also argues that LYNX’s misappropriation allegations aren’t enough to claim unfair competition.
“LYNX’s [September 5 filing] misleadingly excerpts its own allegations to try to escape the fact that its unfair competition claim is premised solely on alleged trade secret misappropriation,” Safelite’s September 12 filing says.
Since State Farm’s filing argues that LYNX still hasn’t plausibly shown that State Farm or Safelite misappropriated trade secrets, both Safelite and State Farm again asked the U.S. District Court of Central Illinois, Peoria Division, to dismiss the case.


