AvidAir Helicopter Supply, Inc. v. Rolls-Royce Corp.

A trade secret does not exist for neither its novelty nor its unavailability, so much as for the reasonable efforts taken in securing the secret's secrecy, and the economic value derived from it.

Opinion (MELLOY): Rolls-Royce Corp. (“Rolls-Royce”), the manufacturer of the Model 250 helicopter engine, alleged that AvidAir Helicopter Supply Inc. (“AvidAir”), a company that overhauls a module within the Model 250, misappropriated their trade secrets. Rolls-Royce issued their FAA-approved procedure for overhauling the Model 250 in authorized documents, titled DOILs. Each DOIL specified the proprietary nature of the information, and prohibited the authorized overhauler from disseminating the information. AvidAir managed to acquire DOIL 24, Revisions 1 to 7 from various sources sometime in the 1990s, as well as Rolls-Royce’s most recent DOIL 24, Rev. 13, without Rolls-Royce’s permission. The District Court held that DOIL 24, Revisions 1-10 were no longer trade secrets, but that Revision 13 was. The jury awarded Rolls-Royce $350,000 in actual damages, and the Court enjoined AvidAir from using Revision 13. AvidAir appealed, arguing that Revision 13 was not substantially different from the Revisions not deemed trade secrets, and that Rolls-Royce was attempting to reclaim information previously available to the public. The Appellate Court disagreed, noting that a trade secret does not exist for neither its novelty nor its unavailability, so much as for the reasonable efforts Rolls-Royce took in securing the DOIL’s secrecy, and the economic value derived from it. Holding that Revision 13 was a valid trade secret, and that AvidAir attained it by inappropriate means, the Court of Appeals AFFIRMED the District Court’s holding.