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Law School Case Brief

Mangren Research & Dev. Corp. v. Nat'l Chem. Co - 87 F.3d 937 (7th Cir. 1996)

Rule:

Under the first requirement of 765 Ill. Comp. Stat. 1065/2(d), the information at issue must be sufficiently secret to impart economic value to both its owner and its competitors because of its relative secrecy. This requirement precludes trade secret protection for information generally known within an industry even if not to the public at large. A plaintiff must prove that the real value of the information lies in the fact that it is not generally known to others who could benefit from using it.

Facts:

Plaintiff Mangren Research and Development Corporation manufactured a mold release agent that it developed and protected as a trade secret. Two of plaintiff's former employees were hired by defendants, National Chemical Company and National Mold Release Company, who subsequently shared the formula to defendants, which was slightly altered and then marketed to compete with plaintiff Mangren's product. Plaintiff sued defendants to recover lost profits due to defendants' misappropriation of its trade secret in violation of the Illinois Trade Secrets Act, and the trial court entered a judgment for the plaintiff. Defendants appealed.

Issue:

Was there sufficient proof that defendants misappropriated plaintiff’s trade secret?

Answer:

Yes.

Conclusion:

The trial evidence amply supported the jury's verdict and the district court properly denied defendants' renewed motion for judgment as a matter of law or for a new trial.

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