The US Court of Appeals for the Tenth Circuit affirmed a summary judgment dismissal of a trade secret misappropriation complaint, finding that the plaintiff failed to take reasonable measures to maintain the secrecy of a customer list. The Court also reversed the district court’s Daubert ruling, finding that it improperly exceeded the scope of Fed. R. of Evid. 702. John Snyder v. Beam Technologies Inc., Case No. 24-1136 (10th Cir. Aug. 5, 2025) (Matheson, Bacharach, Federico, C.J.)

John Snyder downloaded a national customer list containing more than 40,000 names from his former employer’s client-relationship management system. According to metadata analysis, Snyder last modified the file only three minutes after its creation, strongly suggesting that no meaningful changes or additions were made after the download. Snyder’s employment with the company ended in 2016. Following a two-year period of unemployment, he accepted a position with Beam in 2018.

Synder claimed that Beam induced him to join the company by promising compensation in exchange for customer information he obtained from his former employer. After beginning his employment at Beam, Synder created derivative documents containing subsets of the customer list. However, he inadvertently included the entire customer list as a separate tab in each of the documents he emailed to Beam employees. The documents were sent without any confidentiality markings or indications that they contained trade secrets. Snyder did not restrict access to the documents, apply password protection, or notify Beam that any of the content was proprietary or confidential.

After realizing he had distributed the full list to multiple Beam employees, Snyder took no action to object to Beam’s use of the data or attempt to retrieve the documents. He also failed to inform Beam that he considered any of the materials to be trade secrets. Instead, Snyder appeared to ratify the disclosure, telling Beam’s chief executive officer that he had intentionally shared the customer list with the recipients. A few months later, Beam terminated Snyder for unexplained reasons.

Synder sued Beam for trade secret misappropriation and several state law claims. Beam moved for summary judgment on the trade secret claims, which the district court granted, finding that Synder failed to show that he owned the customer list. The district court denied Beam’s motion on Synder’s other claims.

Both parties filed motions to exclude expert witness testimony at trial. The district court granted Beam’s motion to exclude Snyder’s damages expert under Fed. R. of Evid. 702, ruling that the expert could not support Snyder’s claimed damages for the remaining causes of action.

The district court found that Synder failed to show that he could obtain lost wages damages on any of the surviving claims. Expanding the scope of its ruling, the district court excluded not only the expert testimony, but also all evidence and fact witnesses related to lost wages damages at trial. Following the court’s ruling, Snyder and Beam settled one of the claims and jointly moved to dismiss the remaining claims. Snyder then appealed.

Synder argued that the district court erredin [...]

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