IP Law Daily, TRADE SECRETS—E.D. Va.: Parking services corporation secures TRO against former employee, (Dec 16, 2025)

By Carolin Dennis, B.Sc., LL.B., LL.M.

District court finds likelihood of success on merits, irreparable harm, balance of the equities, and public interest favoring granting a temporary restraining order.

The federal district court in Alexandria, Virginia, granted a Temporary Restraining Order (TRO) in favor of LAZ KARP Associates, Inc. (LAZ) on its misappropriation of trade secrets claims against a former employee. The district court found that LAZ is likely to succeed on its misappropriation claims and sufficiently demonstrated the threat of irreparable harm. Concluding that the balance of equities and public interest favored a TRO, the district court granted-in-part the motion for preliminary injunction and issued a TRO (LAZ KARP Associates, Inc. v. Starre, No. 1:25-cv-02111-RDA-WBP (E.D. Va. Dec. 12, 2025)).

Background. LAZ is a parking services corporation. LAZ filed a suit against Anilise Starre, a former employee for sending a batch of emails to her personal Gmail account. The emails contained: various customer-specific documents, including lease agreements, multiple rent calculation spreadsheets; itemized financial information for multiple clients; an email chain listing regional financial results; budget comparisons; lists of new and prospective clients with estimated revenues for each; revenue figures and rosters of parking customers; LAZ’s margins; thousands of pages worth of data in multiple spreadsheets containing comprehensive financial information, such as profit, loss, actual revenue vs. budget, for each division of LAZ’s business; and more such information.

LAZ’s complaint asserted claims for breach of contract, misappropriation of trade secrets in violation of the federal Defend Trade Secrets Act (DTSA) and the Virginia Uniform Trade Secrets Act (VUTSA). LAZ also filed a motion for preliminary injunction requesting that Starre and any other person collaborating with her or acting in concert with her, be: (1) restrained and enjoined from accessing, using, disclosing, sharing, or making available to any person or entity other than LAZ, any of LAZ’s Proprietary Information; (2) restrained and enjoined from altering, destroying, or disposing of any evidence including documents, communications, information, or other tangible or intangible things, in any form, relating to (i) LAZ, (ii) the claims asserted by LAZ in this action, or (iii) Starre’s acquisition, use, transfer, or disposal of LAZ’s Proprietary Information and/or property; and (3) required to account for and return to LAZ any and all of LAZ’s property, including its Proprietary Information, wherever it resides or is stored, and with a full accounting of to whom any such property has been disseminated.

TRO. In granting the TRO, the district court applied the four-factor test from Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7, 20 (2008), considering (1) the likelihood of success on the merits, (2) irreparable harm to the plaintiff, (3) balance of hardships, and (4) public interest.

Likelihood of success on the merits. Under both DTSA and VUTSA, a plaintiff must show (1) the existence of a protectable trade secret, and (2) misappropriation of that trade secret. Here, the alleged trade secrets include highly sensitive cost information for over 50 services, regional financial results and budget comparisons, new and prospective clients with estimated revenues for each, and a lease agreement. The district court found that LAZ took reasonable steps to preserve the secrecy of its information, including sharing only on a need-to-know basis and using password-protected files, confidentiality agreements, and proprietary information policies. Further, after signing multiple agreements establishing and acknowledging her duty to maintain the secrecy of such information, Starre forwarded herself emails containing trade secrets before and after she was terminated. Courts in the Fourth Circuit have routinely held that a former employee sending trade secrets to his or her personal devices in similar circumstances constitutes actual or threatened misappropriation under the DTSA. Accordingly, the district court determined that both elements were satisfied, and that LAZ has shown that it is likely to succeed on its misappropriation of trade secrets claims. Since the district court found that LAZ was likely to succeed on its misappropriation claims, it did not reach the breach of contract claim.

Irreparable harm. As LAZ was likely to succeed on the merits of its trade secrets claims, the district court concluded that it has sufficiently demonstrated the threat of irreparable harm necessary here.

Balance of hardships. The district court cited API Technical Svcs, LLC v. Francis, 2013 WL 12131381, (E.D. Va. Dec. 4, 2013) which held that where “the only harm Defendants would suffer is the self-inflicted harm that comes to those who base their businesses on trade secrets stolen from a competitor, a balancing of the equities strongly favors granting an injunction.” Accordingly, the district court determined that the balance of the equities also favored granting a limited TRO to maintain the status quo.

Public interest. The district court noted that public interest favors the protection of trade secrets, and the prevention of unfair business practices and the injunction provisions in VUTSA and DTSA reflect a legislative recognition that the public interest is furthered by the protection of trade secrets through appropriate injunctive relief. Thus, the district court concluded that public interest also favored granting a narrow TRO.

Therefore, the district court concluded that LAZ satisfied its burden to obtain a limited TRO to maintain the status quo until Starre has the opportunity to retain counsel to review the matter. It also set a bond requirement of a $5,000 bond to account for any harm that could accrue to Starre due to the TRO. The TRO remains in effect until January 28, 2026.

The Case is No. 1:25-cv-02111-RDA-WBP.

Judge: Alston, Jr., R.

Attorneys: Edward Joseph D'Andrea (Squire Patton Boggs (US) LLP) for LAZ KARP Associates, Inc.

Companies: LAZ KARP Associates, Inc.

Cases: TechnologyInternet TradeSecrets VirginiaNews