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TianRui Group Co. v. International Trade Commission
United States Court of Appeals for the Federal Circuit
661 F.3d 1322 (2011)
Amsted Industries, Inc. (Amsted) (plaintiff), an Illinois company, abandoned its former process for casting steel railway wheels in favor of a newer process. Amsted licensed the old process to a Chinese firm. That firm’s ex-employees divulged process-related trade secrets to another Chinese firm, TianRui Group Company Ltd. (TianRui) (defendant). TianRui used those trade secrets to make its own railway wheels, which TianRui attempted to export to the United States. Amsted complained to the federal International Trade Commission (commission) (plaintiff) on the grounds that importing TianRui’s wheels would violate § 337 of the Tariff Act of 1930, which prohibited unfair acts in the importation of articles into the United States. In investigating Amsted’s complaint, the commission found that TianRui’s trade-secret misappropriation violated Illinois’s trade-secret law and harmed domestic industry. The commission issued a limited exclusion order against TianRui, which appealed the order to the Federal Circuit Court of Appeals. At the outset, the court ruled that federal law, not Illinois law, governed the case. Therefore, TianRui’s appeal turned on the extraterritorial applicability of § 337.
Rule of Law
Holding and Reasoning (Bryson, J.)
Dissent (Moore, J.)
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