Ahern Rentals, Inc. v. EquipmentShare.com, Inc., No. 22-1399 (8th Cir. 2023)
Annotate this Case
Ahern Rentals, Inc. (Ahern), alleges that two competitors— EquipmentShare.com, Inc. (EquipmentShare) and EZ Equipment Zone, LLC (EZ)— misappropriated its trade secrets to gain an unfair advantage in the construction equipment rental industry. The district court first dismissed EZ from the lawsuit, ruling that Ahern failed to state a plausible claim for relief against it. Later, the district court dismissed the case altogether, ruling that Ahern’s remaining claims against EquipmentShare were duplicative of claims against EquipmentShare in several other ongoing lawsuits brought by Ahern. Ahern appealed both rulings, arguing that the district court erred in dismissing its claims.
The Eighth Circuit reversed. The court reasoned that, according to Ahern, EquipmentShare developed programs by exploiting Ahern’s trade secrets. Ahern also alleged that the market information used by EZ to develop profitable utilization and rental rates is based on Ahern’s trade secrets illegally obtained by EquipmentShare. Taking all factual allegations as true, Ahern pled enough facts to make it entirely plausible that EZ is at least using systems developed by EquipmentShare through the exploitation of Ahern’s trade secrets. Further, the court found that Ahern has pled sufficient facts to state a claim against EZ for unjust enrichment. It is not disputed that Ahern’s trade secrets are a benefit with real economic value. And, as alleged in the complaint, EquipmentShare and EZ have used the benefit to their advantage. Finally, Ahern plausibly alleges malfeasance in the acquisition of these confidential trade secrets. Thus, the district court erred in dismissing Ahern’s claims against EZ for civil conspiracy and unjust enrichment.
Court Description: [Shepherd, Author, with Colloton and Grasz, Circuit Judges] Civil case - Civil conspiracy. Plaintiff brought this civil action against a competing equipment rental company, claiming that defendant - a competing equipment rental company - had been hiring away its employees and convincing those employees to bring its trade secrets with them. Plaintiff also named a managed cooperative platform, alleging it conspired with the competing rental company in the misconduct and was unjustly enriched by it. Held: Allegations pled on information and belief are not categorically insufficient to state a claim for relief where proof supporting the allegation is within defendant's sole possession and control and the belief is based on sufficient factual material to make inference of culpability plausible; the district court erred by dismissing the claims against the managed cooperative platform primarily because they were based "upon information and belief," a plaintiff pleaded sufficient facts to state a plausible trade secret misappropriation claim and claims under Missouri state law. Dismissal of plaintiff's claims against the rental equipment company based on a claim-splitting analysis is vacated, and the matter is remanded.
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.