Alexandria Real Estate Equities Inc. v. Depippo

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
Case No. l:25-cv-10708-RGS
ORDER FOR PERMANENT INJUNCTION
WHEREAS, Alexandria Real Estate Equities, Inc. ("Plaintiff' or "ARE") filed a Complaint
on March 26, 2025, thereby commencing the above-captioned action against William DePippo
("Defendant" or "DePippo") (together with ARE, the "Parties") alleging:
(1) misappropriation of trade secrets under the Defend Trade Secrets Act, 18 U.S.C. § 1832 et seq.;
(2) breach of contract; and (3) breach of fiduciary duty;
WHEREAS, the Parties agreed by way of a separate agreement not before the Court to
resolve the claims in this action (the "Settlement Agreement");
WHEREAS, the Agreement includes an agreement by the Parties to jointly stipulate to this
[Proposed] Order (the "Stipulated Injunction").
IT IS hereby ORDERED that:
1. 	William DePippo ("Defendant") is permanently prohibited from possessing, retaining,
copying, disclosing, transferring, or in any way using any documents, writings, drawings,
graphs, charts, photographs, sound recordings, images, files, and other data or data
Compilations -- stored in any medium from which information can be obtained --
ALEXANDRIA REAL ESTATE
EQUITIES, INC.,
Plaintiff,
V.
WILLIAM DEPIPPO,
Defendant.
Case 1:25-cv-10708-RGS Document 60 Filed 03/18/26 Page 1 of 4

containing or reflecting any Alexandria Proprietary Information (as defined in the
Employee Proprietary Information and Inventions Agreement between Alexandria and
DePippo, Section 1.2) ("Alexandria Proprietary Information").
2. 	Defendant is permanently prohibited from disclosing, publishing, transferring, or using
Alexandria Proprietary Information in any way, including such information that Defendant
knows, irrespective of whether Defendant possessed such information in documentary
form.
3. 	To the extent not destroyed as described in Paragraph 5 below, Defendant shall return to
Plaintiff any originals, copies, facsimiles, or duplicates of any documents, writings,
drawings, graphs, charts, photographs, sound recordings, images, files, and other data or
data compilations -- stored in any medium from which information can be obtained --
in his possession, custody, or control containing or reflecting Alexandria Proprietary
Information.
4. 	Consistent with the Agreement between the Parties, DePippo shall remove (i) all of
Alexandria's Proprietary Information from his publications, including but not limited to
internet domains under his control (including his websites and blogs), podcasts, and other
means of disseminating information to the public ("DePippo Publications"), within three
days of execution of this Agreement. Consistent with the Agreement between the Parties,
DePippo shall permanently refrain from including such information in any DePippo
Publications.
5. 	Within three days after Alexandria's forensic consultant and DePippo's forensic consultant
confirm details of the mechanics of such final destruction, Defendant's forensic consultant
shall destroy all documents designated for destruction in the Adjusted Forensic Review
Protocol filed at Docket No. 33.
Case 1:25-cv-10708-RGS Document 60 Filed 03/18/26 Page 2 of 4

6. 	Defendant shall comply with all ARE policies governing the use of ARE documents and
information, and shall further comply with his ongoing obligations under his Proprietary
Information and Inventions Agreement with ARE, executed by DePippo on or about March
20, 2014 including but not limited to his obligations during Section 1.1 ("Recognition of
Company's Rights; Nondisclosure"), Section 5 ("Non-Solicitation"), and Section 6 ("Non-
Interference").
7. 	Consistent with the Agreement between the Parties, Defendant is permanently prohibited
from making, publishing, or communicating to any person or entity or in any public forum
(including any online forum) any defamatory or disparaging remarks, comments, or
statements concerning ARE or its businesses, or any of its employees, officers, and existing
and prospective customers, suppliers, investors and other associated third parties.
8. 	Within 14 days after entry of the Court's approval of this Stipulated Injunction, Defendant
shall provide written notification of this Stipulated Injunction to any third party to whom
Defendant communicated or distributed any ARE information. In such notice, Defendant
shall also request that the third parties return, destroy or refrain from using any ARE
information in their possession henceforth. Within 21 days of entry of the Court's approval
of this Stipulated Injunction, Defendant shall provide ARE with a copy of all notices
provided to third parties along with certified receipts of delivery of those notices.
9. 	Within 30 days after confirmation by the parties' forensic consultants referenced above in
Paragraph 5, Defendant shall provide a written certification, under penalty of perjury, that
states, "During my employment at Alexandria, I did not use or disclose Alexandria's
Proprietary Information (as defined in my Proprietary Information and Inventions
Agreement), except as authorized by Alexandria. I have not used or disclosed Alexandria's
Proprietary Information since separating from employment at Alexandria. I have returned
Case 1:25-cv-10708-RGS Document 60 Filed 03/18/26 Page 3 of 4

or destroyed all copies and versions of any documents containing Alexandria's Proprietary
Information in my possession, custody, or control."
10. 	Within five business days after entry of the Court's approval of this Stipulated Injunction,
DePippo shall make a payment to Alexandria of $100,000.
11. 	The obligations in Paragraphs 1, 2, 4, 6 and 7 above shall remain in force unless and until
lifted by the Court, irrespective of the final dismissal of this action.
SO ORDERED:
Dated: _____
The Honorable Richard G. Steams
United States District Judge
/s/ Richard G. Stearns	3/18/2026
Case 1:25-cv-10708-RGS Document 60 Filed 03/18/26 Page 4 of 4