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Altavion, Inc. v. Konica Minolta Sys. Lab., Inc - 226 Cal. App. 4th 26, 171 Cal. Rptr. 3d 714 (2014))

Rule:

The Uniform Trade Secrets Act, Civ. Code, § 3426 et seq., creates a statutory cause of action for the misappropriation of a trade secret. The statute defines a trade secret as information, including a formula, pattern, compilation, program, device, method, technique, or process, that: (1) derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (2) is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.

Facts:

Respondent Konica filed an action for trade misappropriation against Altavion, a research and development subsidiary of a printer manufacturer. The trial court ruled in favor of the Respondent and concluded that Altavion misappropriated trade secrets disclosed during their negotiations. Altavion challenged the ruling of trial court.

Issue:

Does the filing of patent applications disclosing Respondent’s ideas violate the trade secret law?

Answer:

Yes.

Conclusion:

The Court affirmed the judgment of the lower court. Finding that a research and development subsidiary of a printer manufacturer misappropriated an inventor company's trade secrets was proper where the subsidiary secretly filed patent applications disclosing the inventor company's ideas, which were protectable as trade secrets, and subsequently obtained patents covering the inventor company's ideas.

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