Sarkissian Mason, Inc. v. Enter. Holdings

Widely known components of a system limit the value of the concept as a whole making the system ineligible for consideration as a trade secret.

Opinion (Schofield): Sarkissian Mason, Inc. ("Sarkissian") and AutoMatic, Inc. ("AutoMatic") are a privately owned digital marketing agency and its wholly owned subsidiary. Sarkissian brought suit against Defendant Enterprise Holdings, Inc ("Enterprise"), a holding company that operates rental vehicles, alleging misappropriation of a trade secret. Sarkissian alleges that they brought a proprietary business proposal to Enterprise, which Enterprise then misappropriated it for its own use. In July 2011, Enterprise and Sarkissian discussed creating a QR code-based service. In October 2011, Enterprise announced its own QR code-based service called "OnRamp". Under MUTSA, a trade secret is a "formula, pattern, compilation, program" or other business idea that: (a) Derives independent economic value, actual or potential, from not being generally known to, and not being readily ascertainable by proper means by other persons who can obtain economic value from its disclosure or use; and (b) is the subject of efforts that are reasonable under the circumstances to maintain its secrecy. Sarkissian's proposed system was not sufficiently secret to merit legal protection as a trade secret. All of the component parts of the idea were publicly known and in use before they presented their proposal to Enterprise. Sarkissian argued that their proposal as a whole is a trade secret. The court found that the components of the system were widely known, so the concept as a whole is of limited value because it is readily ascertainable. The court found that Sarkissian's system, as an unexecuted concept, was not a trade secret as a matter of law. the "OnRamp" system and website did not constitute misappropriation. Summary judgment is GRANTED as to all claims.