EXPRESS ONE INTERN., INC. V. STEINBECK
The trial court granted former employee’s motion for summary judgment. On appeal, represented former employee sued by former employer for trade name dilution, invasion of privacy, negligence, and conversion, after former employee, using screen name of former employer, posted on an internet message board a message containing negative comments about union supporters. Former employer appealed. The court of appeals affirmed in favor of the former employee, holding that: (1) former employer failed to plead damages which would have been recoverable under negligence; (2) former employee did not dilute the value of the trade name; (3) former employee did not commit invasion of privacy by misappropriation; and (4) use of the intangible trade name as screen name was not conversion.