REXA, Inc. v. Chester

Federal 7th Circuit Court
Civil Court
Trade Secret
Citation
Case Number: 
Nos. 20-2953 et al Cons.
Decision Date: 
July 28, 2022
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed and vacated in part and remanded

In action under Illinois Trade Secrets Act, alleging that defendants-former plaintiff’s employee and employee’s new employer misappropriated plaintiffs trade secrets arising out of 2002 project that defendant-employee worked on while at plaintiff that was aimed at creating new valve for actuator, Dist. Ct. did not err in granting defendants’ motion for summary judgment, where: (1) plaintiff failed to sufficiently identify concrete trade secret; (2) plaintiff conceded that several aspects of 2002 project were widely known in hydraulic-actuator industry; and (3) actuator developed in 2002 project did not have features contained in defendants’ patent application for their actuator. Dist. Ct. also granted defendants’ motion for summary judgment with respect to plaintiff’s implied-in-fact contract claim, where defendant-employee was not specifically directed to develop actuator while employed at plaintiff. Also, Dist. Ct. erred in awarding defendants $2.357 million in attorney fees as sanction for plaintiff’s litigation misconduct, where remand was required for new determination on said issue, since Dist. Ct. failed to address what amount of fees was traceable to litigation misconduct. Ct. of Appeals additionally held that Dist. Ct. could not impose additional amount as punishment.