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Chicago Lock Co. v. Fanberg

United States Court of Appeals for the Ninth Circuit
676 F.2d 400 (1982)


Chicago Lock Co. (Chicago Lock) (plaintiff) sold maximum-security tubular locks. Chicago Lock protected information related to all locks and did not provide customers with spare keys. When keys were lost, skilled locksmiths had the ability to pick and decode the tubular locks. These locksmiths often retained the information for later use. Victor Fanberg (defendant) was a locksmith. Fanberg collected tubular lock codes from locksmiths around the country and also decoded tubular locks himself. Fanberg compiled the codes into a manual that made duplicating tubular-lock keys easier and less expensive. Chicago Lock sued Fanberg for trademark infringement and unfair competition. The district court granted summary judgment to Fanberg on the trademark claim, but the unfair-competition claim went to trial. The court found that Chicago Lock’s tubular-lock codes were protectable trade secrets, which Fanberg had obtained through improper means. Fanberg appealed.

Rule of Law


Holding and Reasoning (Ely, J.)

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