IP Law Daily, TRADE SECRETS—S.D.N.Y.: Dismissal granted in brand name bag and luggage trade secrets dispute, (Mar 3, 2026)

By Kevin M. Finson, J.D.

Claims for misappropriation brought by a seller of luggage were dismissed because the seller did not identify its claimed secrets with the requisite particularity.

A seller of luggage failed to properly identify its claimed trade secrets for the second time, the U.S. District Court in New York City has held. Hunter Bags brought suit against Spray Moret for misappropriation of trade secrets under state and federal law, as well as state law claims for unfair competition and unjust enrichment. Spray Moret moved to dismiss. Because the issue had already been addressed once, leave to amend further was denied (Quanzhou New Hunter Bags & Luggages (Light Industry) Co., Ltd. v. Spray Moret, LLC, No. 1:24-cv-09691-JPO (S.D.N.Y. Feb. 26, 2026)).

Quanzhou New Hunter Bags & Luggages (Lights Industry) Co, Ltd. (Hunter Bags) is a designer and manufacturer of bag and luggage products sold under a number of brand names. Spray Moret, LLC (Spray Moret) is the owner of a brand known as Sprayground, under which Hunter Bags had sold assorted bag products. Rita Zhang was employed by Hunter Bags as Sales Manager of Original Equipment Manufacturer Production and signed a confidentiality agreement as part of her employment. Zhang eventually left her employment with New Hunter and became the Quality Production Supervisor for Spray Moret. Some seven months later, Spray Moret ended its business relationship with Hunter Bags. Spray Moret allegedly misappropriated trade secrets in violation of state and federal law and violated state unfair competition and unjust enrichment laws.

Trade secrets. Spray Moret argued that Hunter Bags had failed to identify its trade secrets with sufficient particularity. The court found that the definition in the complaint, which described the trade secrets as “relat[ing] to, among other things: (1) methods, techniques, and processes to improve raw materials; (2) methods, techniques, and processes of preparing development samples and pre-production prototypes; (3) methods, techniques, and processes for conducting internal quality testing in Plaintiff’s in-house laboratory; (4) procedures for evaluating factories and assembly plants; and (5) procedures for controlling the quality of mass-produced bag and luggage products” was far too vague to state a claim. The court held that this merely gestured to the legal elements of a trade secret in conclusory statements without identifying any particular information about how the claimed techniques operated, what made them valuable, or how easily they could be acquired by others.

State law claims. The court found that each of the state law claims was either duplicative of the trade secrets claim or based on conclusory allegations without sufficient factual material to state a claim.

The court granted the motion to dismiss and denied leave to amend, noting that Hunter Bags had previously been granted leave to amend on the same issue.

The Case is No. 1:24-cv-09691-JPO.

Judge: Oetken, J.

Attorneys: Dariush Keyhani (Keyhani LLC) for Quanzhou New Hunter Bags & Luggages [Light Industry] Co., Ltd. Brad David Rose (Pryor Cashman LLP) for Spray Moret, LLC.

Companies: Quanzhou New Hunter Bags & Luggages (Light Industry) Co., Ltd.; Spray Moret, LLC

Cases: TradeSecrets NewYorkNews