Life Spine, Inc. v. Aegis Spine, Inc.

8 F.4th 531 (2021)

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Life Spine, Inc. v. Aegis Spine, Inc.

United States Court of Appeals for the Seventh Circuit
8 F.4th 531 (2021)

Facts

Life Spine, Inc. (plaintiff) made and sold a spinal-implant device, the ProLift, for which the company obtained a patent in 2017. The following year, Life Spine entered a short-lived distribution agreement with Aegis Spine, Inc. (Aegis) (defendant) under which Aegis promised to protect confidential information pertaining to the ProLift. However, Aegis funneled information about the ProLift’s specifications to its parent company, L&K Biomed, Inc. (L&K), which was able to quickly manufacture a device comprised of essentially the same component parts interconnected in the same way. Upon becoming aware of L&K’s device, Life Spine brought suit against Aegis for misappropriation of trade secrets under both federal and Illinois law as well as breach of the distribution agreement. The federal district court found in favor of Life Spine, granting a preliminary injunction against the sale of the competing product by Aegis and its partners. Aegis appealed to the United States Court of Appeals for the Seventh Circuit, arguing that essential information about the ProLift had already been disclosed through the 2017 patent, though the patent did not disclose every aspect of the product’s construction. Aegis also argued that Life Spine’s display of the ProLift at trade shows and sale of the product for surgical purposes further undermined trade-secret protection.

Rule of Law

Issue

Holding and Reasoning (St. Eve, J.)

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