Hicklin Engineering Co. v. Bartell
United States Court of Appeals for the Seventh Circuit
439 F.3d 346 (2006)

- Written by Rich Walter, JD
Facts
Hicklin Engineering Company, L.C. (Hicklin) (plaintiff) sued R. J. Bartell (defendant) for trade-secret misappropriation. Bartell was a former part-time engineering consultant for Hicklin’s Axi-Line division, which manufactured transmission-testing equipment. Hicklin accused Bartell of knowingly poaching confidential Axi-Line specifications to set up his own rival transmission-testing business. Hicklin’s evidence suggested that the unique nature of these specifications, and the care Axi-Line took to safeguard them from public disclosure, entitled the specifications to legal protection as trade secrets. Bartlett claimed he did nothing more than check the accuracy of his own work against Axi-Line’s specifications. Because Hicklin never required Bartell to sign a nondisclosure agreement, Hicklin’s case turned on whether Bartell breached an implied duty to keep Hicklin’s trade secrets confidential. A federal district court entered summary judgment for Bartell. Hicklin appealed to the Seventh Circuit.
Rule of Law
Issue
Holding and Reasoning (Easterbrook, J.)
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