Clean Energy v. Trillium Transportation Fuels LLC

The court adopted the magistrate judge's report and recommendation recommending that the plaintiff's tortious interference with contract, civil conspiracy, and alter ego claims be dismissed as time barred. In addition, the court dismissed trade secret misappropriation claims related to renewable natural gas. Confidential and proprietary information that the former employee was alleged to possess included "carbon credit accounting for customers and analysis of customer to claim carbon benefit notwithstanding [low carbon fuel standard] sale."

Clean Energy—a renewable natural gas, compressed natural gas, and liquefied natural gas supplier for medium- and heavy-duty vehicles and fuel station designer and builder—amended its complaint to add allegations that defendants induced former Clean Energy employees to divulge trade secrets related to renewable natural gas (RNG). The trade secrets and confidential information in question were related to pricing RNG, pricing and trading Low Carbon Fuel Standard and renewable fuel credits, and carbon credit accounting.