KPM Analytics North America Corporation v. Blue Sun Scientific, LLC — 1st Cir. (argued July 30, 2026)
The First Circuit hears oral argument in KPM Analytics North America Corporation versus Blue Sun Scientific. KPM is a Massachusetts company that provides spectroscopy equipment and technical support for food and agricultural clients. KPM alleges that Blue Sun and its parent company, ITG, hired away several KPM employees. KPM says those employees then took its trade secrets, and that the defendants interfered with customer contracts. A jury found Blue Sun liable for trade secret misappropriation and both companies liable for tortious interference, and the court awarded doubled damages under Massachusetts Chapter 93A, the state's unfair and deceptive practices statute. Blue Sun and ITG now appeal, arguing primarily that the Massachusetts federal court never had personal jurisdiction over them: they are out-of-state defendants who say their conduct took place elsewhere. The jurisdictional question turns on where the alleged misconduct occurred. KPM says the defendants took and used proprietary data connected to Massachusetts. The defendants say they at most gathered information outside the state, and they point to a company laptop they place in Illinois. The parties dispute both where the data lived and what those facts mean for jurisdiction.
KPM Analytics North America Corporation v. Blue Sun Scientific, LLC (No. 25-1222) — U.S. Court of Appeals for the First Circuit, argued July 30, 2026.
- 0:00Introduction
- 1:45Advocate — Dana Zakarian
- 2:39Rule 12(b)(2) and Chapter 93A
- 8:36Walden and the effects test
- 10:18The Massachusetts long-arm statute, Section 3(c)
- 16:36Counsel for the Appellee
- 38:00Awaiting decision