Background
Signant Health is a clinical-trial technology company that provides electronic patient-reported outcomes platforms and related software for pharmaceutical trials. Definium Therapeutics ran Phase 2 clinical trials using Signant’s technology to test MM120, an LSD-based formulation intended to treat generalized anxiety disorder. When Definium moved to Phase 3 trials, it switched vendors — contracting instead with EMA Wellness, a competitor of Signant.
Signant sued Definium in Delaware federal court in 2026, alleging that Todd Solomon, Definium’s Director of Global Clinical Development, had disclosed Signant’s proprietary clinical trial design information to EMA while maintaining an undisclosed financial stake in EMA. Signant claimed Solomon’s actions allowed EMA to unfairly compete for the Phase 3 contract using Signant’s confidential know-how, violating the federal Defend Trade Secrets Act (DTSA) and related state law. Definium moved to dismiss for failure to state a claim.
The Court’s Holding
Judge Gregory B. Williams dismissed the complaint, finding that Signant failed to identify its alleged trade secrets with sufficient specificity to state a viable DTSA claim.
Under the DTSA, a plaintiff must provide more than a general description of its confidential business information — it must plead specific facts identifying what trade secrets were allegedly misappropriated. The court found that despite access to extensive discovery from related Pennsylvania litigation (which produced thousands of documents), Signant’s complaint described the misappropriated information only in broad, categorical terms, without pinpointing the actual confidential materials Solomon allegedly disclosed. Judge Williams concluded that this level of generality is insufficient at the pleading stage: the DTSA requires a plaintiff to give the defendant — and the court — enough detail to understand what specific information is claimed as a trade secret, so that the case can be properly evaluated and bounded.
Key Takeaways
- DTSA plaintiffs must identify their trade secrets with particularity at the pleading stage — broad, categorical descriptions of “proprietary clinical trial technology” or “confidential know-how” are insufficient.
- Access to prior discovery does not excuse vague pleading: if a plaintiff has already obtained thousands of documents in related litigation, courts expect it to translate that knowledge into specific trade secret allegations.
- The decision reinforces a recurring pleading-specificity problem in trade secret cases, where plaintiffs often prefer to define their secrets broadly to expand litigation scope — an approach courts increasingly reject.
- For clinical trial technology companies, protecting trade secrets requires not only contractual safeguards but also the ability to identify and articulate specific confidential information precisely enough to sue when it is misappropriated.
Why It Matters
Pharmaceutical and health technology companies routinely share confidential clinical trial methodologies with CROs, trial platforms, and other vendors during the drug development process. When a vendor relationship ends and a competitor enters the picture, the risk of trade secret misappropriation is real — but so is the pleading hurdle this case highlights. Judge Williams’ ruling serves as a reminder that the DTSA’s statutory framework requires precision: a company claiming stolen secrets must be able to say exactly what was stolen, not just that something was.