Law School Case Brief
Amoco Prod. Co. v. Laird - 622 N.E.2d 912 (Ind. 1993)
Where the duplication or acquisition of alleged trade secret information requires a substantial investment of time, expense, or effort, such information may be found "not being readily ascertainable" so as to qualify for protection under the Uniform Trade Secrets Act, Ind. Code § 24-2-3-1, et seq.
Plaintiff Amoco Production Company undertook extensive research and travel to locate potential oil fields in the United States and, as a result, developed a certain map delineating locations of such sites. The map was largely produced by geologist John Clemdenning, an employee of plaintiff. Believing that plaintiff would not act on his advice, Clemdenning provided defendants individuals and company with information contained on the map he developed, which defendants actively pursued the oil reserves. When plaintiff discovered defendants' activities, it sought and obtained injunctive relief barring defendants' efforts on the grounds that the information obtained and used by defendants was a trade secret, under Ind. Code § 24-2-3-2. The trial court granted a preliminary injunction The court of appeals reversed.
Was plaintiff Amoco entitled to injunctive relief to protect information as to the location of potential oil fields?
On petition to transfer, the state supreme court reversed, holding that the duplication of plaintiff's alleged trade secret information required where the duplication or acquisition of alleged trade secret information requires a substantial investment of time, expense, or effort, such information may be found "not being readily ascertainable" so as to qualify for protection under the Indiana Uniform Trade Secrets Act. Therefore, the trial court's finding that methods of acquiring the information pertaining to the location of the Indiana oil reserve sites "were not simple or easy to accomplish, and are expensive to develop," is sufficient to support its conclusion that such information was not readily ascertainable and thus entitled to trade secret protection. A trade secrets plaintiff need not prove that every element of an information compilation is unavailable elsewhere. Such a burden would be insurmountable since trade secrets frequently contain elements that by themselves may be in the public domain but taken together qualify as trade secrets.
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