Appeals Court Affirms Dismissal in Trade Secret Lawsuit

The Tenth Circuit ruled that Flux Drive Inc. failed to establish personal jurisdiction in Colorado against the defendants.

Updated on Oct. 30, 2026 in Financial Crime

Isometric editorial illustration of a water-cooled motor component, representing the legal jurisdiction and trade secret topic in a clinical, structural style. — The Tenth Circuit Court of Appeals upheld the dismissal of Flux Drive Inc.’s lawsuit, ruling that the plaintiff failed to establish personal jurisdiction in Colorado. AI Illustration. Upload story photo >

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The U.S. Court of Appeals for the Tenth Circuit has upheld a lower court decision dismissing a trade secret misappropriation lawsuit against John Quiang Rong, Leigh Wang, and Zyrcon Global Strategies LLP. The court determined the plaintiff did not adequately link the defendants' activities to Colorado.

Why it matters

This ruling highlights the high burden of proof required for plaintiffs to establish jurisdiction in trade secret cases involving out-of-state entities. By affirming the dismissal, the court reinforced protections for defendants against lawsuits that fail to substantiate specific connections to a state.

The appeals court upheld a $185,000 award for attorneys' fees to the defendants after rejecting the plaintiff's jurisdiction claims. The case reached this conclusion after the court found insufficient evidence of defendant activity directed toward Colorado.

The players

Flux Drive Inc.

This entity served as the plaintiff in the trade secret misappropriation lawsuit that was dismissed by the court.

John Quiang Rong

He is one of the defendants who successfully defended against the trade secret allegations in this legal proceeding.

Leigh Wang

He is one of the defendants involved in the lawsuit regarding trade secret misappropriation.

Zyrcon Global Strategies LLP

This is a limited liability partnership named as a defendant in the misappropriation case.

The details

Flux Drive Inc. had accused the defendants of misappropriating trade secrets related to water-cooled motor control technology. The court concluded that the plaintiff failed to meet legal requirements to hold the case within the state's jurisdiction.

October 30, 2026: The Tenth Circuit issued the ruling.

Legal Context

This case follows established judicial standards regarding personal jurisdiction in civil litigation, which require specific links between a defendant and the forum state. The ruling reinforces the necessity for plaintiffs to substantiate these connections before a case can proceed to trial.

This outcome clarifies that businesses and individuals cannot be easily pulled into litigation in states where they lack meaningful operational links. For local businesses, it underscores the importance of gathering comprehensive evidence of activities to satisfy strict jurisdictional requirements.

The takeaway

This decision serves as a reminder that jurisdictional disputes are often dispositive in complex trade secret litigation. Plaintiffs must ensure their legal filings clearly demonstrate a defendant's specific ties to the venue before initiating an action.