Winston Research Corp. v. 3M Corp.

Mincom (plaintiff) developed an improved 'servo' system for tape players and recorders. Before it reached the market, Johnson, who led Mincom's research and development, left to start Winston Research Corp. (defendant). Winston hired former Mincom technicians and, in just over a year, built a machine with the same functionality. Mincom sued for trade-secret misappropriation. The district court found misappropriation and granted a two-year injunction against Winston selling its machine, choosing two years because Mincom's product was about to become public and that was roughly how long a competitor would need to develop a similar machine from the soon-public information. Mincom appealed seeking a permanent injunction and damages; Winston appealed seeking to vacate the injunction.

Whether a permanent injunction is appropriate for misappropriation of a trade secret where the secret information will soon be publicly disclosed.