California’s § 2019.210 remains a sharp gatekeeper: a plaintiff must identify alleged trade secrets with “reasonable particularity” before trade-secret discovery begins. Appellate decisions set the lane lines. Advanced Modular says disclosures need not include “every minute detail,” but must let the court cabin discovery. And Perlan affirms that vague, category-level or catch-all designations can be insufficient. See Advanced Modular Sputtering, Inc. v. Superior Court, 132 Cal. App. 4th 826 (2005); Perlan Therapeutics, Inc. v. Superior Court, 178 Cal. App. 4th 1333 (2009).
Courts enforce those lines with teeth. In Jobscience, Inc. v. CVPartners, Inc., the court struck the trade-secret claim after a narrative disclosure failed to isolate the secrets—with no further amendment after plaintiff had seen defendants’ code. No. C 13-04519 WHA, 2014 WL 1724763 (N.D. Cal. May 1, 2014). In Swarmify, Inc. v. Cloudflare, Inc., the court granted in part a motion to strike after the plaintiff reshaped its list post-injunction; it froze the “final” list, shifted fees, and granted the defense extra discovery. No. C 17-06957 WHA, 2018 WL 2445515 (N.D. Cal. May 31, 2018). In Loop AI Labs, Inc. v. Gatti, the court compelled a particularized disclosure and stayed discovery on the CUTSA claim until compliance (2015 WL 9269758, N.D. Cal. Dec. 21, 2015); a later order still found the disclosure insufficient, 195 F. Supp. 3d 1107, 1111–14 (N.D. Cal. 2016). And in Gatan, Inc. v. Nion Co., the court ordered a rewritten disclosure with a numbered list and specific elements—akin to patent claims. No. 15‑cv‑01862‑PJH, 2018 WL 2117379, at *2–5 (N.D. Cal. May 8, 2018).
Why it matters: insist on a stable, bounded list that distinguishes secrets from general know-how; avoid “including but not limited to” phrasing and document dumps; and expect that any stay will be limited to trade-secret-related discovery, not the entire case (see Advanced Modular and Loop AI orders above).
Statute refresher: Cal. Code Civ. Proc. § 2019.210.
