United States v. Lange

Matthew Lange (defendant) worked for Replacement Aircraft Parts Co. (RAPCO), a manufacturer of aftermarket aircraft parts. RAPCO’s work required reverse engineering original equipment parts by taking them apart and preparing drawings and measurements relating to each part. RAPCO would then make its own version using the same or better specifications. Lange handled this work for airplane brakes. From the time the initial reverse engineering was done, it took RAPCO one to two years to develop and test its own version of a complicated product like brakes, a lengthy and expensive process. RAPCO could skip some certification tests, saving itself time and money, if it could demonstrate that its parts were identical to previously certified parts. After leaving RAPCO, Lange offered buyers on the internet the opportunity to pay $100,000 for a copy of RAPCO’s drawing software and all the information required to obtain certifications of several airplane parts identical to some of RAPCO’s currently certified parts. This would permit a buyer looking to make and sell any of those parts and to skip the lengthy and expensive testing process for its own version of the product. A potential buyer informed the government about Lange’s offer. The United States (plaintiff) indicted Lange, and he was convicted of stealing trade secrets from RAPCO and attempting to sell them to a competitor. Lange appealed, arguing that the data he offered for sale was not a trade secret because it stemmed from a reverse-engineering process that any member of the public could replicate.