Bondpro Corp. v. Siemens Power Generation, Inc.

Siemens Power Generation (defendant) made electrical generators using insulated copper coils shaped in a bowl mold, which sometimes wrinkled. BondPro Corp. (plaintiff) developed a molding process using vacuum, heat, and air pressure (via an autoclave) that reduced wrinkles. Another firm, Torr Technologies, had publicly described using air pressure and heat to mold insulation in trade-show materials. BondPro pitched licensing to Siemens under two confidentiality agreements (which excluded generally or previously known information) and demonstrated its process. Siemens declined to license but filed a patent application for a similar process omitting the autoclave step; the application was rejected and Siemens never used BondPro's process. BondPro sued for trade-secret theft. A jury found misappropriation, but the district court granted judgment as a matter of law for Siemens; BondPro appealed.

Whether information that is not generally known by the public or the industry, and that the owner has made reasonable efforts to keep confidential, constitutes a protectable trade secret.