Blog Post
May 17, 2012
Another Federal Court Holds That A Compilation Of Non-Trade Secret Data Can Be A Trade Secret; Court Also Holds That An Unambiguous Written Contract With A Provision Precluding Unwritten Amendments Nonetheless Can Be Modified By Conduct
A collaboration between Beacon Wireless Solutions and Garmin International, to integrate Beacon’s Global Positioning System fleet management vehicle tracking program into Garmin’s personal navigation devices, went awry. Allegedly without Beacon’s knowledge or consent, in order to boost Garmin’s sales, Garmin allegedly published to Beacon’s competitors Beacon’s confidential integration application specifications. Beacon sued, alleging trade secret misappropriation, breach of contract, and unjust enrichment. A few days ago, basing his decision on Kansas law, a U.S. District Court Judge in Virginia denied most of Garmin’s motions for summary judgment. Beacon Wireless Solutions, Inc. v. Garmin Int’l, Inc., Civ. Ac. No. 5:11-cv-0025 (May 9, 2012).
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