Whyte v. Schlage Lock Co.
California Court of Appeal
101 Cal. App. 4th 1443 (2002)

- Written by Rich Walter, JD
Facts
J. Douglas Whyte (defendant) signed a nondisclosure agreement, but not a noncompetition agreement, when he went to work for Schlage Lock Company (Schlage) (plaintiff). Whyte left his job as Schlage’s top sales executive under acrimonious circumstances suggestive of bad faith and took a similar position with Schlage’s rival, Kwikset Corporation. Schlage sued Whyte for trade-secret misappropriation. Whyte successfully petitioned the trial court to lift its initial temporary restraining order (TRO) enjoining Whyte from disclosing confidential information relating to Schlage’s sales and marketing strategies. The trial court also found insufficient evidence of misappropriation and denied Schlage’s motion for a preliminary injunction. On appeal, Schlage asked the California Court of Appeal to grant injunctive relief under the doctrine of inevitable disclosure adopted by Illinois and other states.
Rule of Law
Issue
Holding and Reasoning (Fybel, J.)
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