Religious Technology Center v. Wollersheim

The Church of Scientology (the Church) (plaintiff) was a religious organization that provided adherents with a method of self-improvement called auditing. According to the Church, the auditing process required specific content, supervision, and special equipment. The Church’s auditing process had to be executed in a specific sequence. The Church took measures to ensure that high-level auditing materials remained secret. The Church granted access to auditing materials only on the condition of strict confidentiality. The auditing materials were not copyrighted. David Mayo (defendant) was involved in the original creation of the auditing materials. After a dispute with the Church, Mayo formed a new church called the Church of the New Civilization (Mayo’s church) (defendant). Both churches offered substantially the same teaching but were run by different people. In 1983, individuals not party to this case stole high-level auditing materials from the Church. Although the Church recovered the auditing materials, the Church was convinced that copies of the materials were given to Mayo’s church. The Church sued Mayo’s church, arguing that Mayo’s church misappropriated the Church’s trade secrets. The district court granted the Church’s motion for a preliminary injunction, finding that the Church’s adherents would suffer irreparable spiritual harm by unauthorized dissemination of the auditing materials. The Church did not allege commercial harm. Mayo’s church appealed, arguing the auditing materials were not a protectable trade secret.