Caudill Seed Warehouse v. Jarrow Formulas has an interesting discussion of “combination trade secrets” – collections of public information.
Here, competitor Jarrow Formulas hired away Caudill’s Director of Research and released a competing product in four months without performing any of its own research on the product.
Caudill was able to define its trade secret as a unique collection of procedures and information. The court rejected Jarrow’s defence of the trade secret being mostly public domain information, as the combination was unique.
Additionally, Caudill did not have to show that Jarrow acquired and used “each atom” of the combination trade secret.
Caudill prevailed at trial, and was affirmed in full at Jarrow’s appeal.