Fail-Safe LLC v. A.O. Smith Corp.

Dist. Ct. did not err in granting defendant's motion for summary judgment that defendant misappropriated trade secrets revealed to it by plaintiff during failed attempt by both parties to develop pump motor for pool suction entrapment prevention device. Record showed that plaintiff failed to take reasonable precautions to protect its trade secrets where information conveyed to defendant was without any intellectual property protection or any indication of contractual agreement for confidentiality. Moreover, plaintiff otherwise failed to mark any proffered information as "confidential" or make it known to defendant that said information was to remain confidential. Fact that plaintiff subjectively believed that it had entered into joint venture with defendant to develop said device did not require different result.