nClosures Inc. v. Block and Company, Inc.

Dist. Ct. did not err in granting defendant’s motion for summary judgment in action alleging that defendant breached confidentiality agreement arising out of defendant’s manufacture of plaintiff’s metal enclosure devices for tablets that arose from designs supplied by plaintiff, when defendant began to manufacture its own enclosure devices. Record showed that plaintiff had failed to take reasonable steps to keep its propriety information confidential by obtaining additional confidentiality agreements from individuals who had access to said designs. As such, plaintiff’s confidentiality agreement was unenforceable. Ct. also found that plaintiff could not maintain similar breach of fiduciary claim, where, although parties may have shared profits generated by defendant’s manufacture of plaintiff’s enclosure devises, record did not show that parties had engaged in other activities that suggested existence of partnership that was required to support any breach of fiduciary claim.