Rockwell Graphic Systems, Inc. v. DEV Industries, Inc.

Rockwell (plaintiff) kept confidential piece-part drawings in a vault but occasionally gave copies to outside vendors under confidentiality agreements when it needed parts made. Fleck, a former Rockwell employee, became president of competitor DEV (defendant); another employee, Peloso, was fired after being caught trying to steal drawings and then went to work for DEV. Rockwell discovered DEV possessed 100 of its confidential drawings and sued for trade secret misappropriation. DEV argued it obtained the drawings lawfully and that Rockwell's drawings weren't real trade secrets because Rockwell gave them to many vendors without tightly controlling copying. The district court granted DEV summary judgment, finding Rockwell hadn't taken reasonable steps to maintain secrecy.