Though not a non-compete case, the decision is a boon for U.S. employers looking to police trade secret theft activity that occurs outside the country. The suit was based on Connecticut's trade secret statute, not the federal Computer Fraud and Abuse Act. But the suit reads like a CFAA claim.
In short, MacDermid claimed Dieter improperly forwarded confidential business information just before her termination of employment. The conduct occurred in Canada. But MacDermid maintained its data on servers in Connecticut. Dieter's defense to jurisdiction - that she did nothing in the United States - did not carry the day, according the Second Circuit.
Read the Chicago Tribune's article for a summary of the case, and then the short Second Circuit opinion below.
MacDermid v. Deiter - Second Circuit Opinion