Pioneer Hi-Bred International v. Holden Foundation Seeds

35 F.3d 1226 (1994)

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Pioneer Hi-Bred International v. Holden Foundation Seeds

United States Court of Appeals for the Eighth Circuit
35 F.3d 1226 (1994)

RW

Facts

Pioneer Hi-Bred International (Pioneer) (plaintiff) and Holden Foundation Seeds, Inc. (Holden) (defendant) were rivals in the lucrative market for genetically engineered, hybrid corn seeds. Popular seed strains included Pioneer’s H3H/H43SZ7 and Holden’s LH-38-39-40 seed lines. Pioneer sued Holden for trade-secret misappropriation, accusing its rival of having poached genetic material from stolen H3H/H43SZ7 seeds to engineer LH-38-39-40. Holden claimed to have developed LH-38-39-40 from its own in-house L120 parent line, but Pioneer derided this claim as Holden’s so-called L120 story. To win its case, Pioneer needed to prove that (1) Pioneer took reasonable measures to protect H3H/H43SZ7’s genetic material as trade secrets, for example by making it extremely difficult for competitors to identify H3H/H43SZ7 seeds in farm fields; (2) Holden was in actual possession of those trade secrets; and (3) Holden obtained those trade secrets by improper means. Pioneer’s trial presentation included evidence that Holden (1) had a history of searching farm fields for specific Pioneer seeds, (2) kept faulty records to support its L120 story, and (3) had discarded all its L120 seeds. The federal district court entered judgment for Pioneer. On appeal, the Eighth Circuit focused its inquiry on whether Holden obtained the H3H/H43SZ7 genetic material by improper means.

Rule of Law

Issue

Holding and Reasoning (Gibson, J.)

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