Conmar Products Corp. v Universal Slide Fastener Co.
United States Court of Appeals for the Second Circuit
172 F.2d 150, 80 U.S.P.Q. 108 (1949)
- Written by Eric Miller, JD
Facts
Conmar Products Corporation (Conmar) (plaintiff) manufactured zippers. Conmar’s employees were bound by agreements to avoid disclosure of the trade secrets involved in the zipper-making process. Universal Slide Fastener Company (Universal) (defendant) employed several former employees of Conmar and was apparently unaware of the nondisclosure agreements. Universal built a machine using seven of Conmar’s trade secrets. However, the subsequent issuance of two patents to Conmar revealed six of these trade secrets, along with part of the seventh. Universal received notice to cease use of the trade secrets, by which time it had invested $40,000 into the machine. A few years later, two more patents were issued, revealing the remainder of the seventh trade secret. Conmar sought an injunction in federal district court, arguing both patent infringement and fraudulent inducement of the employees to reveal confidential trade secrets. The court ruled in favor of Universal with respect to the inducement claim. Conmar appealed to the United States Court of Appeals for the Second Circuit.
Rule of Law
Issue
Holding and Reasoning (Hand, C.J.)
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