Chicago Lock Co. v. Fanberg
United States Court of Appeals for the Ninth Circuit
676 F.2d 400 (9th Cir. 1982)
Chicago Lock Co. (plaintiff) manufactured tubular locks whose codes it kept confidential, but skilled locksmiths could pick and decode the locks when customers lost keys, often retaining that decoded information; locksmith Fanberg (defendant) compiled codes obtained through his own decoding efforts and through coordination with other locksmiths into a manual making lock duplication easier. Chicago Lock sued for trade secret misappropriation, and the district court found the codes protectable trade secrets that Fanberg had obtained through improper means; Fanberg appealed.
Whether a trade-secret misappropriation claim can succeed when the defendant obtained the confidential information through fair and honest means, such as independent reverse engineering, rather than through theft or deception.