Religious Technology Center v. Wollersheim

The Church of Scientology (the Church) (plaintiff) kept its high-level "auditing" materials, an uncopyrighted self-improvement method requiring specific content and sequence, strictly confidential, sharing them only under conditions of secrecy. David Mayo (defendant), who helped create the materials, later broke from the Church and formed a rival Church of the New Civilization, which taught substantially the same method. After thieves stole high-level materials from the Church in 1983, the Church believed copies reached Mayo's new church and sued for trade-secret misappropriation. The district court granted a preliminary injunction, finding the Church's adherents would suffer irreparable spiritual harm, though the Church never alleged any commercial harm. Mayo's church appealed.