IQE's trade-secret case against Newport Fab and Tower hit a California anti-SLAPP problem because the complaint tied alleged misappropriation to patent-application filings.
The Federal Circuit focused on what IQE actually pleaded: disclosure and use of alleged trade secrets in patent applications. On that framing, the protected act of filing patent applications gave rise to the misappropriation claim.
The decision is a drafting warning for trade-secret plaintiffs. If the wrongful conduct is broader than a protected petitioning act, the complaint needs to plead that conduct clearly and support it with facts.
For IP teams, the case also highlights the tension between patent publication and trade-secret protection. Once alleged confidential material is described as part of a patent filing dispute, procedural defenses can become as important as the merits.