205 Corp. v. Brandow

517 N.W.2d 548 (1994)


P hired D to manage a restaurant it owns and operates. P provided D with recipes for The Tavern's pizza sauce, pizza crust, and grinder sandwiches. The secret recipes for pizza sauce and grinders were known only to P's president, Charles Celsi, and by the former owner of The Tavern. Several current and former employees knew the pizza crust recipe. P eventually terminated D's employment. D subsequently provided pizza and grinder recipes to his new employer, Mustards Restaurant. P sued Mustards and D personally for misappropriation of trade secrets by Mustards and D under Iowa Code chapter 550 (1991). P also alleged that D breached his duty of loyalty. The jury gave damages to P. The court enjoined Ds from the use of the recipes in the future but denied P's motion for attorney fees. Mustards (D) appealed contending that less than substantial evidence supported the jury's finding that the recipes derived independent economic value and were the subject of reasonable efforts to maintain their secrecy, both being requirements for recovery under chapter 550.