William LeJeune v. Coin Acceptors, Inc.

849 A.2d 451 (2004)

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William LeJeune v. Coin Acceptors, Inc.

Maryland Court of Appeals
849 A.2d 451 (2004)

KL

Facts

William LeJeune (plaintiff) worked for Coin Acceptors, Inc. (Coinco) (defendant) in Maryland as a salesperson for several years. Coinco created, sold, and serviced coin acceptors, coin changers, and similar machines. Coinco sold its machines into three separate channels: vending, which included beverage bottlers; amusement, which included video-game manufacturers; and specialty, which included transit companies. LeJeune’s work focused primarily on the vending channel. During his employment, LeJeune worked from his home, using a work-issued computer. Coinco did not ask LeJeune to sign a confidentiality or noncompetition agreement. LeJeune ultimately decided to leave Coinco, and took a job with Mars, Inc., Coinco’s primary competitor. LeJeune’s role at Mars focused on the amusement channel. LeJeune returned his Coinco laptop after giving notice. Before doing so, he downloaded and retained multiple files, including pricing information relating to Coinco’s specialty channel and budgeting software, which contained Coinco’s manufacturing costs and profit margins. Coinco sued LeJeune for misappropriation of trade secrets. The lower court enjoined LeJeune from working for Mars under the inevitable-disclosure doctrine, finding that Coinco would suffer irreparable injury if LeJeune worked for Mars because LeJeune had misappropriated trade secrets that would inevitably give Mars an unfair advantage. LeJeune appealed.

Rule of Law

Issue

Holding and Reasoning (Battaglia, J.)

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