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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 (1991)
Rockwell Graphic Systems, Inc. (Rockwell) (plaintiff) and DEV Industries, Inc. (DEV) (defendant) were competing manufactures. When Rockwell needed parts, Rockwell sometimes purchased them from outside vendors. Rockwell provided vendors with a piece-part drawing that instructed the vendor on precisely how to manufacture the needed part. Rather than patent the drawings, Rockwell kept all piece-part drawings in a vault. Rockwell required in-house engineers and outside vendors to keep the drawings confidential. In 1975, Fleck (defendant) left Rockwell and became president of DEV. Rockwell fired an employee named Peloso when a security guard caught Peloso attempting to steal piece-part drawings. Peloso then went to work for DEV. Rockwell sued DEV and Fleck, alleging misappropriation of trade secrets and other claims. During discovery, Rockwell learned DEV possessed 100 of Rockwell’s confidential piece-part drawings. DEV claimed to have obtained Rockwell’s drawings lawfully. DEV also argued that Rockwell’s piece-part drawings were not protectable trade secrets, because Rockwell provided the drawings to numerous vendors and did not strictly control possession or copying of the drawings. The district court granted summary judgment to DEV, finding that Rockwell did not take reasonable steps to maintain the secrecy of the drawings.
Rule of Law
Holding and Reasoning (Posner, J.)
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