Daktronics, Inc. v. McAfee
South Dakota Supreme Court
1999 S.D. 113 (1999)
- Written by Rich Walter, JD
Facts
By the 1980s, devices for tracking the speed of moving objects were being used in amusement arcades and in sporting events such as ski competitions. In 1988, David Baker (defendant) pitched his idea for a baseball pitch-speed indicator to Daktronics, Inc. (plaintiff). The device Baker had in mind consisted of a radar gun and other simple and readily available components. Daktronics built four prototype devices for Baker but otherwise took no action on Baker’s idea. Over the next few years, several manufacturers began selling pitch-speed indicators to baseball stadiums, and in 1996, Daktronics joined their league. By this time, Baker had taken on a partner, Miles McAfee (defendant). The partners complained that Daktronics had stolen Baker’s 1988 idea. Daktronics went to state court and sued for a declaratory judgment against Baker and McAfee, who counterclaimed on several counts, including trade-secret misappropriation and conversion. The trial court granted summary judgment for Daktronics. Baker and McAfee appealed to the South Dakota Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Amundson, J.)
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