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Rockwell Graphic Systems, Inc. v. DEV Industries, Inc.
United States Court of Appeals for the Seventh Circuit
925 F.2d 174 (7th Cir. 1991)
Rockwell Graphic Systems, Inc. (Rockwell) (plaintiff) manufactured printing presses and their replacement parts. The only way to create the replacement parts was to use Rockwell’s “piece part drawings,” which included materials, dimensions, tolerances, and methods of manufacture. That is to say, an individual or company could not recreate a replacement part simply from looking at another replacement part; it must have the piece part drawing. Occasionally, Rockwell subcontracted the manufacture of a part to a vendor. In these cases, Rockwell gave a copy of the relevant piece part drawing to the vendor. The vendor was required to sign a confidentiality agreement that it would not disseminate the drawing. Although the agreements stated that the vendors must return the drawings once the replacement part was created, Rockwell did not enforce the requirement because the vendor would need the drawing if Rockwell were to reorder the same part. The piece part drawings were kept in a vault, to which only select employees had access. Rockwell required these employees to sign confidentiality agreements, promising not to give out the drawings or their contents. And if the employees needed the drawings, they were required to sign them out and return them to the vault when they were done. Rockwell did allow copying of the piece part drawings, but the employees were required to destroy the copies after using them. DEV Industries, Inc. (DEV) (defendant) was a competing manufacturer whose president was fired by Rockwell when he was caught taking piece part drawings from a Rockwell building. Rockwell brought suit against DEV for misappropriation of trade secrets. Through discovery it was learned that DEV possessed 100 of Rockwell’s piece part drawings. DEV claimed that the company obtained the drawings legally from vendors, but did not prove that at trial. The district court granted summary judgment to DEV, finding that the piece part drawings were not trade secrets because Rockwell made only minimal efforts to keep them secret. Rockwell appealed.
Rule of Law
Holding and Reasoning (Posner, J.)
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