Syntel Sterling Best Shores Mauritius, Ltd., et al. v. The TriZetto Grp.,, No. 21-1370 (2d Cir. 2023)
Annotate this Case
Plaintiffs appealed from a final judgment entered in favor of Defendants The TriZetto Group, Inc. and Cognizant Technology Solutions Corporation (collectively, “TriZetto”) after a jury trial in district court. Relevant here, the district court ordered and entered judgment that (1) Syntel misappropriated 104 of TriZetto’s trade secrets in violation of the Defend Trade Secrets Act (“DTSA”) and New York law; and (2) TriZetto’s $284,855,192 compensatory damages award was proper under the DTSA. On appeal, Syntel challenges the district court’s judgment with respect to liability and damages.
The Second Circuit affirmed and vacated the judgment of the district court and remanded. The court held that the unambiguous terms of the Amended Master Services Agreement (MSA) are clear, and so is the extrinsic evidence: TriZetto did not authorize Syntel to use TriZetto’s trade secrets to compete with TriZetto. Thus, Syntel misappropriated TriZetto’s intellectual property in violation of the DTSA and New York law. Accordingly, the court affirmed the district court’s denial of Syntel’s Rule 50(b) motion on this issue. The court concluded that, as a matter of law, an unjust enrichment award of avoided costs was unavailable under the specific facts of this case. Syntel’s unjust gain was fully “addressed in computing damages for [TriZetto’s] actual loss,” and TriZetto suffered no compensable harm beyond that actual loss. Thus, the court remanded the case for the district court to address the propriety of the two jury awards based on TriZetto’s damages theory of awarding a reasonable royalty: (1) the $142,427,596 New York trade secret misappropriation award and (2) the $59,100,000 copyright infringement award.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.