MEI-GSR Holding, LLC v. Peppermill Casinos, Inc.Annotate this Case
Nev. Rev. Stat. 600A.030 does not preclude a defendant from demonstrating that certain information is readily ascertainable and not a trade secret even where the defendant acquired the information through improper means.
An employee of Peppermill Casino, Inc. accessed slot machines of a casino owned by MEI-GSR Holdings, LLC (GSR) to obtain their theoretical hold percentage information (par values). GSR filed suit against Peppermill and its employee, asserting violation of Nevada’s Uniform Trade Secrets Act. The jury returned a special verdict in favor of Peppermill, finding that GSR’s stolen par values did not constitute a trade secret under section 600A.030 because GSR had failed to prove that its par information was not readily ascertainable by proper means. The Supreme Court affirmed, holding (1) the district court did not err in instructing the jury concerning trade secrets under section 600A.030; and (2) GSR’s other assignments of error lacked merit.