Rohm & Haas Co. v. ADCO Chem. Co. - 689 F.2d 424 (3d Cir. 1982)

Rule:

Even though each and every element of a plaintiff's process is known to the industry, the combination of those elements may be a trade secret if it produces a product superior to that of competitors.

Facts:

Plaintiff Rohm and Haas Company claimed a process that it used in the manufacture of its latex paint products was a trade secret that was misappropriated by defendants Adco and Thibaut & Walker. Plaintiff contended that defendants were able to copy this process only through revelations by plaintiff's former employee. The district court rejected plaintiff's claim, holding that the process was not a trade secret. Plaintiff appealed, arguing that the district court erred in denying relief on its trade secret claim.

Issue:

Did the district court err in denying relief on plaintiff’s trade secret claim?

Answer:

Yes.

Conclusion:

The appellate court reversed the decision and remanded solely for a determination of the appropriate relief. The court held that the district court imposed additional, incorrect legal standards of secrecy on plaintiff's trade secret. The court stated that although the elements of the process were widely known in the industry, the process was a trade secret because the combination of those elements was not known and the combination of the elements produced a product superior to that of plaintiff's competitors. Further, specificity of plaintiff's definition of its trade secret was not required.