MacDermid v. Deiter
U.S. COURT OF APPEALS, SECOND CIRCUIT
Judge Barrington Parker
From May 2008 until her April 2011 termination, Ontario-resident Deiter was an account manager for Connecticut-based specialty chemical maker MacDermid's Canadian subsidiary MacDermid Chemicals. MacDermid stores proprietary and confidential data on computer servers in Connecticut. MacDermid Chemicals employees can access that information only by accessing the Connecticut servers. Deiter agreed to safeguard and properly use MacDermid's confidential information and that she was not authorized to transfer such information to a personal email account, which she did right before her termination. District court dismissed MacDermid's federal suit alleging Deiter's unauthorized access and misuse of a computer system and misappropriation of trade secrets contrary to Connecticut statutes. It found Deiter had not used a computer in Connecticut and was thus not amendable to that state's long-arm jurisdiction. The Second Circuit reversed and remanded, holding that Deiter's use of a computer in Connecticut satisfied the state's long-arm statute and due process. The Connecticut servers are deemed computers under the long-arm statute, which requires that only the computer or network, not the user, be located in Connecticut.