Shatterproof Glass Corp. v. Guardian Glass Co.
United States District Court for the Eastern District of Michigan
322 F. Supp. 854 (1970)

- Written by Rich Walter, JD
Facts
Shatterproof Glass Corporation (Shatterproof) (plaintiff), a maker of replacement car windshields, sued its rival, Guardian Glass Company (Guardian) (defendant), for trade-secret misappropriation. Shatterproof’s alleged trade secrets consisted of work techniques that two of Shatterproof’s ex-employees learned on the job. Shatterproof claimed that the ex-employees breached their implied duty to keep those techniques confidential when they quit Shatterproof and went to work for Guardian, where they used the same techniques. The federal district court heard evidence that (1) Shatterproof’s ex-employees had held modest, low-wage jobs; (2) no one at Shatterproof ever warned the ex-employees that their work techniques constituted trade secrets or cautioned the ex-employees against divulging those techniques to others; (3) all replacement-windshield makers used similar techniques familiar to any experienced worker in the trade; (4) it was common for line workers, engineers, and managers in the trade to move from one replacement-windshield company to another; and (5) Guardian was unaware of any confidential relationship existing between Shatterproof and the ex-employees whom Guardian hired.
Rule of Law
Issue
Holding and Reasoning (Smith, J.)
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