In Biller v. Toyota Motor Corp., 668 F.3d 655 (9th Cir. 2012) (No. 11-55587),the Ninth Circuit affirmed an arbitration award which had granted defendant liquidated damages based on plaintiff’s breach of his Severance Agreement.  Plaintiff, a former in-house attorney for defendant who had sued for wrongful discharge, agreed to settle that suit with a Severance Agreement that protected defendants’ confidential information and required all disputes arising from the Severance Agreement to be arbitrated.  Subsequently, the defendant discovered that the plaintiff had posted defendant’s confidential product liability litigation information on his website.  The court upheld an arbitrator’s award for $2.5 million in liquidated damages, concluding that the plaintiff had violated the confidentiality provisions of the Severance Agreement.