Winston Research Corp. v. Minnesota Mining & Manufacturing Co.

Facts

The Mincom Division of P developed an improved precision tape recorder and reproducer. Machines prior to the Mincom machine employed a flywheel to inhibit fluctuation in tape speed by increasing the inertia of the system. However, the flywheel reduced the effectiveness of the servo system since the increased inertia prevented rapid adjustments in the speed of the motor. To solve these problems, Mincom eliminated the flywheel and reduced the mass of all other rotating parts. After four years of research and development based upon this approach, Mincom produced a successful machine with an unusually low time-displacement error. Johnson, who was in charge of Mincom's program, left Mincom's employment. He joined Tobias, who had previously been discharged as Mincom's sales manager, informing D. In late 1962, D contracted with the government to develop a precision tape reproducer. D hired many of the technicians who had participated in the development of the Mincom machine to work on the design and development of D machine. In approximately fourteen months, D completed a machine having the same low time-displacement error as the Mincom machine. D concedes that Johnson and the other former Mincom employees based D's development program upon the same approach to the problem of achieving a low time-displacement error as they had pursued in developing the Mincom machine. The district court further found that this general approach was not a trade secret of Mincom's. The district court found that the particular embodiment of these general concepts in the Mincom machine was Mincom's trade secret, and had been improperly utilized by the former Mincom employees in developing the D machine. Mincom contends that the court defined Mincom's trade secrets too narrowly; D, that the court's definition was too broad.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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