This Law Firm Publication by Epstein Becker & Green, P.C. discusses the Arizona Supreme Court's decision in Orca Communication Unlimited, LLC v. Noder, holding that an unfair competition claim about confidential information that did not amount to a trade secret was not pre-empted by Arizona's Uniform Trade Secrets Act (UTSA). The court also discussed the split of authority among states on whether the UTSA preempts all other common law tort claims premised on misappropriation of confidential information.