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Smith v. Snap-On Tools Corp.

833 F.2d 578 (1987)

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Smith v. Snap-On Tools Corp.

United States Court of Appeals for the Fifth Circuit
833 F.2d 578 (1987)

  • Written by Meagan Messina, JD

Facts

After making a rachet from parts of two existing tools, Basil Smith (plaintiff) showed the rachet to an independent dealer and submitted a tool suggestion form to Snap-On Tools Corp. (Snap-On) (defendant). Snap-On started manufacturing and selling the rachet but did not give any proceeds to Smith. Smith sued Snap-On, claiming that Smith’s tool was a trade secret, that Smith submitted the tool in confidence, that Snap-On misappropriated the tool, and that Snap-On was liable for misappropriation. The district court held for Smith, awarding Smith damages of 2.5 percent of Snap-On’s gross sales of the tool plus prejudgment interest. Smith appealed the award of damages and sought to recover profits instead of a reasonable royalty. Snap-On cross-appealed.

Rule of Law

Issue

Holding and Reasoning (Rubin, J.)

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