Cognate Bioservices, Inc. v. Smith, Civil No. WDQ-13-1797, 2014 WL 988857 (D. Md. Mar. 12, 2014)

Key Insight: Court denied motion for an order to preserve evidence, finding that defendant had complied with his duty to preserve — he gave opposing party notice that the laptop he used in connection with his employment at competitor would be returned after his resignation, provided the name and address of the person in possession of the laptop, and made efforts to ensure that relevant information on the laptop was not deleted

Nature of Case: Employer sued former employee and his new consulting firm for violations of Computer Fraud and Abuse Act, misappropriations of products, misappropriations of trade secrets

Electronic Data Involved: Laptop, computer passwords to former employer’s virtual private network and server computers