Archer Daniels Midland Co. v. Sinele

Archer Daniels Midland Company (Midland) (plaintiff) was one of five major competitors who sold corn-based sweeteners to food producers. Midland kept confidential data on its customers in its Tableau database, which Midland considered to be its trade secret. Lane Sinele (defendant) regularly consulted Tableau’s data in his capacity as a Midland sales manager but, due to the ever-changing nature of the corn-sweetener market, Tableau’s data shifted constantly and was of limited use in predicting future market conditions. Sinele was bound by nondisclosure agreements between himself and Midland, but he never signed noncompetition or nonsolicitation agreements. When Sinele retired from Midland, he set up a brokerage business advising buyers on their dealings with Midland and its rivals. Sinele’s success in advising his new clients depended far more heavily on the expertise he gained from working for Midland than it did on whatever Tableau data Sinele might have remembered. Midland sued Sinele under Illinois’s version of the Uniform Trade Secrets Act but could not prove any actual or threatened trade-secret misappropriation on Sinele’s part. Nevertheless, the trial court issued a preliminary injunction barring Sinele from soliciting business from customers whose accounts he managed for Midland or from disclosing Midland’s trade secrets to any third party. The trial court based its action on PepsiCo, Inc. v. Redmond, a 1995 case in which the Seventh Circuit held that Illinois law recognized the doctrine of inevitable disclosure. Sinele appealed to the Illinois Appellate Court.