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Law School Case Brief

Rockwell Graphic Sys., Inc. v. DEV Indus., Inc. - 925 F.2d 174 (7th Cir. 1991)

Rule:

Only in an extreme case can what is a "reasonable" precaution to protect a trade secret be determined on a motion for summary judgment because the answer depends on a balancing of costs and benefits that will vary from case to case, and so require estimation and measurement by persons knowledgeable in the particular field of endeavor involved.

Facts:

Rockwell Graphic Systems (Rockwell), a manufacturer of newspaper printing presses and supplier of parts, sued DEV Industries, Inc. (DEV) a competing manufacturer, and Robert Fleck, a former employee of Rockwell, for misappropriation of trade secrets. The district court granted summary judgment for defendants DEV based on a magistrate's conclusion that Rockwell had no trade secrets because it had failed to take reasonable precautions to maintain secrecy. Pointing out that Rockwell had made some efforts to keep its piece part drawings secret.

Issue:

Did Rockwell forfeit trade secret protection?

Answer:

No

Conclusion:

The court reversed and remanded holding that the mere fact that Rockwell gave piece part drawings to vendors who made parts for Rockwell did not forfeit trade secret protection. The court said that only in an extreme case could what was a reasonable precaution be determined on a motion for summary judgment because the answer depended on a balancing of costs and benefits that would vary from case to case.

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