Roton Barrier, Inc. v. The Stanley Works
United States Court of Appeals for the Federal Circuit
79 F.3d 1112, 37 U.S.P.Q.2d 1816 (1996)
- Written by Eric Miller, JD
Facts
Austin Baer owned Roton Corporation, which obtained a patent on pinless hinges in 1963. The Stanley Works (Stanley) (defendant) sought to enter the pinless-hinge business but lacked the technical means available to Roton. In 1989, Stanley expressed an interest in acquiring Roton. Stanley and Roton entered a confidentiality agreement governing Stanley’s examination of Roton, which included visits to the production facility and reviews of financial records. Stanley made an acquisition offer, which Roton refused. Roton was acquired by another company and became Roton Barrier, Inc. (plaintiff). Stanley then made and sold its own pinless hinge. Roton Barrier brought suit for trade-secret misappropriation in federal district court, seeking injunctive relief and damages. Illinois law applied. The court found in Roton Barrier’s favor and entered two orders—one enjoining Stanley from engaging in the pinless-hinge business for four years, and the other enjoining Stanley from further disclosure of Roton Barrier’s trade secrets. The court also awarded actual damages, punitive damages, attorney fees, and prejudgment interest. Stanley appealed to the United States Court of Appeals for the Federal Circuit.
Rule of Law
Issue
Holding and Reasoning (Rich, J.)
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