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EDVA Denies Alarm.com's Motion to Dismiss SkyBell Trade Secrets Suit

Published
Score
14

Why it matters

The Eastern District of Virginia has denied Alarm.com's motion to dismiss a trade secrets lawsuit brought by former partner SkyBell Technologies. SkyBell accused Alarm.com of misappropriating video doorbell technology and poaching employees after the companies' partnership ended in late 2022. Alarm.com had argued the three-year statute of limitations under the Defend Trade Secrets Act and Virginia Uniform Trade Secrets Act barred SkyBell's July 2025 complaint. Judge Rossie D. Alston Jr. rejected that defense, holding that SkyBell could not have discovered the alleged misappropriation earlier because a 2015 Development and Integration Agreement between the parties explicitly prohibited reverse engineering and required confidentiality—contractual restrictions that remained in force until the agreement terminated in November 2022.

The ruling turns on the discovery rule, which starts the limitations clock when a plaintiff reasonably should have discovered the harm. Alarm.com argued SkyBell should have investigated sooner through independent diligence like reverse engineering its products. The court found this argument failed because the contract itself barred such investigation. Until the DIA ended, SkyBell had no contractual right to examine Alarm.com's competing products and therefore no reasonable opportunity to detect misappropriation.

The decision provides useful guidance for technology companies in trade secret disputes. Contractual restrictions on investigation—particularly reverse engineering bans—can defeat statute of limitations defenses at the motion-to-dismiss stage, shifting the burden to defendants to prove actual discovery rather than constructive notice. Plaintiffs in similar situations should document the contractual barriers that prevented earlier investigation. Defendants relying on limitations arguments should expect courts to scrutinize whether plaintiffs had genuine access to information before claiming they should have known sooner.

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