"At most, SuccessFactors points to a confidentiality disclaimer present on a single email it unilaterally sent to The Magnus Group relatively late in the parties' dealings with each other," the motion states.

"SuccessFactors is embarrassed about what it has done, and it has brought suit alleging untenable claims that are all superseded by California's Uniform Trade Secret Act in an effort to punish Halogen for SuccessFactors' own failings," it adds. "SuccessFactors fails to identify any 'property' that has been permanently deprived by Halogen, any instance in which its information was used or disclosed by Halogen, any specific 'economic relations' that have been interfered with, or any lost sales or profits as resulting from the conduct complained about."

Even if all of SuccessFactors' claims were accepted as true, all the suit succeeds in doing is alleging that "Halogen, via The Magnus Group, freely obtained nonconfidential information that many other companies and individuals already have in their possession," Halogen's motion argues. "There is no legally cognizable claim for relief for such activity."