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Ingersoll-Rand Co. v. Ciavatta
New Jersey Supreme Court
110 N.J. 609, 542 A.2d 879 (1988)
Ingersoll-Rand Company (plaintiff) was in the business of developing, manufacturing, and selling heavy industrial equipment. Ingersoll-Rand held a patent on a system, known as a split set stabilizer, which was designed to prevent underground mines from collapsing. Although Ingersoll-Rand considered the stabilizer’s technology to be proprietary, details about the technology were available in industry trade publications and were widely known. Armand Ciavatta (defendant) was an engineer employed by Ingersoll-Rand. In 1978, Ciavatta was assigned to the role of manufacturing and quality-control manager for the division of Ingersoll-Rand that produced the stabilizer. Ciavatta was not hired to invent or work on design improvements for the stabilizer. In June 1979, Ingersoll-Rand terminated Ciavatta’s employment. During that summer, while he was unemployed, Ciavatta began to develop a new stabilizer. Ciavatta later received two patents for his system, which differed from Ingersoll-Rand’s stabilizer in two significant ways but was based on similar technology. During his employment, Ciavatta had signed an agreement relating to proprietary matter that included a holdover provision in which Ciavatta agreed to assign to Ingersoll-Rand his rights in any invention he might conceive or develop within one year of the termination of his employment if the invention was attributable to work done during the employment. Ingersoll-Rand sued Ciavatta for breaching the holdover provision. The trial court enforced the agreement. The appellate division reversed, and Ingersoll-Rand appealed.
Rule of Law
Holding and Reasoning (Garibaldi, J.)
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