Learning Curve Toys, Inc. v. PlayWood Toys, Inc.

During confidential discussions about a possible manufacturing partnership, PlayWood Toys, Inc. (PlayWood) (plaintiff) co-owner Robert Clausi cut grooves into a Learning Curve Toys, Inc. (Learning Curve) (defendant) wooden train track sample, creating a realistic clickety-clack sound and proposing to call it "Clickety-Clack Track" if he manufactured it, then gave Learning Curve the sample piece; PlayWood never received the manufacturing contract, but nearly two years later discovered Learning Curve selling grooved tracks under that exact name, ultimately earning over $20 million in six years. A jury found Learning Curve misappropriated PlayWood's trade secret, but the district court held PlayWood had no protectable trade secret and granted Learning Curve judgment as a matter of law, prompting PlayWood's appeal.