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Sylmark Holdings Ltd. v. Silicone Zone International, Ltd.
New York Supreme Court, New York County
783 N.Y.S.2d 758 (2004)
Sylmark Holdings Ltd. (Sylmark) (plaintiff) developed silicone oven mitts designed to fit the shape of a person’s hand and withstand very high heat. Sylmark expended significant time and effort to develop its product and obtained patent protection because its mitt design was not generally known to competitors. Sylmark entered into a development agreement with Silicone Zone International, Ltd. (Silicone Zone) (defendant) in which Silicone Zone agreed to manufacture molds for Sylmark’s oven mitts. The companies also signed a confidentiality agreement in which they agreed that the silicone oven mitt was an invention created solely by Sylmark and belonged exclusively to Sylmark. Sylmark subsequently found out that Silicone Zone had made and was marketing a silicone oven-mitt product that was virtually identical to Sylmark’s oven mitt and asked Silicone Zone to stop selling it. Silicone Zone refused, and Sylmark sued in federal court, alleging that Silicone Zone misappropriated Sylmark’s trade secrets, including patented information pertaining to Sylmark’s mitt. Silicone Zone asserted that information relating to the oven mitt was not secret because the patent was in the public domain. Sylmark countered that patent-related information in the public domain was limited to six basic drawings and did not include detailed specifications and other proprietary information concerning the design and manufacture of the mitts, all of which Silicone Zone had access to through its confidential development agreement with Sylmark. Sylmark sought an injunction to enjoin Silicone Zone from selling its rival oven mitts.
Rule of Law
Holding and Reasoning (Cahn, J.)
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