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Farmers Edge Inc. v. Farmobile, LLC

Farmers Edge Inc. v. Farmobile, LLC

United States Court of Appeals for the Eighth Circuit

February 11, 2020, Submitted; August 17, 2020, Filed

No. 18-2900

Opinion

 [*1029]  KELLY, Circuit Judge.

This case arose after Jason Tatge, Heath Gerlock, and Randy Nuss (the individual defendants) left a company called Crop Ventures to co-found Farmobile (the corporate defendant). Farmers Edge (FEI) is Crop Ventures's successor-in-interest. Both FEI and Farmobile are agriculture technology companies that work on "precision agriculture" and the use of specialized data in farming. Believing the individual defendants [**2]  took proprietary information they developed at Crop Ventures, FEI sued. As relevant here, FEI alleges  [*1030]  the individual defendants's behavior constituted a breach of explicit or implicit contracts with the company; that the defendants were obligated to assign to their employer the ownership rights of products they worked to develop; that the individual defendants breached their duty of loyalty to their employer; and that the individual defendants misappropriated trade secrets. The individual defendants filed counterclaims. On cross-motions for summary judgment, the district court1 denied in full FEI's motion, and granted in part and denied in part Farmobile's motion. Only FEI appeals, and we affirm.

] We review the district court's grant of summary judgment de novo. See Torgerson v. City of Rochester, 643 F.3d 1031, 1042 (8th Cir. 2011) (en banc). We view all facts in the light most favorable to the non-moving party. Id. We affirm if the "movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a).

Each of the individual defendants previously worked for Crop Ventures. Tatge was president of Crop Ventures from April to July 2013. He is a co-founder and CEO of Farmobile. Gerlock was an [**3]  executive vice president of Crop Ventures, and also worked for Crop Ventures as an independent contractor. Gerlock is Farmobile's Director of Products. Nuss worked for Crop Ventures as an independent contractor from April 2012 to August 2012. Later, he was a full-time employee of Crop Ventures from October 2012 to July 2013. Nuss is also a co-founder of Farmobile and its Director of Engineering.

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970 F.3d 1027 *; 2020 U.S. App. LEXIS 25962 **; 171 Lab. L. Rep. (CCH) P62,070; 2020 WL 4742498

Farmers Edge Inc.; Farmers Edge (US) Inc.; Farmers Edge (US) LLC, Plaintiffs - Appellants v. Farmobile, LLC; Jason G. Tatge; Heath Garrett Gerlock; Randall Thomas Nuss, Defendants - Appellees

Prior History:  [**1] Appeal from United States District Court for the District of Nebraska - Omaha.

Farmers Edge Inc. v. Farmobile, LLC, 2016 U.S. Dist. LEXIS 189551 (D. Neb., Oct. 24, 2016)

CORE TERMS

individual defendant, implied contract, district court, trade secret, invent, patent, breached, duty of loyalty, confidential, assign, ownership, alleges, parties, argues, independent contractor, express contract, products, rights

Civil Procedure, Summary Judgment, Entitlement as Matter of Law, Appropriateness, Appeals, Summary Judgment Review, Standards of Review, Judgments, Entitlement as Matter of Law, Genuine Disputes, Legal Entitlement, Business & Corporate Compliance, Contracts Law, Types of Contracts, Contracts Implied in Fact, Contract Formation, Acceptance, Meeting of Minds, Ownership, Conveyances, Assignments, Labor & Employment Law, Conditions & Terms, Trade Secrets & Unfair Competition, Employee Inventions, Patent Law, Invention Date & Priority, Reduction to Practice, Patent Law, Employee Inventions & Shop Rights, Wrongful Termination, Breach of Contract, Implied Contracts, Public Contracts Law, Bids & Formation, Implied Contracts, Implied-in-Fact Contracts, Employment Relationships, Employment Contracts, Contract Interpretation, Covenants, Customers of Former Employer, Trade Secrets Law, Employee Duties & Obligations, Right to Compete, Covenants Not to Compete, Business & Corporate Law, Distributorships & Franchises, Causes of Action, Covenants not to Compete, Noncompetition & Nondisclosure Agreements, Trade Secrets Law, Protection of Secrecy, Duty to Safeguard, Trade Secret Determination Factors, Economic Value, Protected Information, Know-How, Ready Availability, Generally Known, Appellate Briefs, Reviewability of Lower Court Decisions, Preservation for Review