Avidair Helicopter Supply, Inc. v. Rolls-Royce Corp.
663 F.3d 966
| 8th Cir. | 2011Background
- Two consolidated UTSA trade-secret suits: Rolls‑Royce alleges misappropriation of DOILs (distributor overhaul information letters) for Model 250; AvidAir seeks declaration DOILs are not trade secrets and asserts antitrust and tortious interference claims.
- DOILs evolved from Allison to Rolls‑Royce; DOILs bear proprietary legends; AMCs were bound by confidentiality and restricted distribution.
- AvidAir acquired a portion of Precision’s library and argued post‑hoc that AMC restrictions were nonexhaustive, potentially public domain; RR asserted ongoing secrecy and misappropriation risk.
- District court divided the DOILs, holding Revision 13 (DOIL 24, Rev. 13) trade secret while 1–10 were not; injunction required AvidAir to return protected documents.
- Jury awarded Rolls‑Royce $350,000 in damages; court entered a narrow injunction; AvidAir appealed challenging trade-secret status and related claims; court affirmed the district court’s rulings.
- The decision focuses on whether compilations of public information can still constitute a trade secret when they derive value from secrecy and are maintained with reasonable efforts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether DOIL 24, Revision 13 is a trade secret | AvidAir contends revisions 1–10 public; Revision 13 too similar to public data | Rolls‑Royce shown value from secrecy and updates; revisions sustain secrecy | Yes, DOIL 24 Rev.13 protected as a trade secret |
| Whether RR’s secrecy efforts were reasonable | Legends and AMC agreements not enough; information publicly available | Legends and confidentiality commitments showed reasonable efforts | Yes, reasonable secrecy efforts established |
| Whether summary judgment on antitrust and tortious interference was proper | RR’s trade-secret suit was sham to restrain competition | Lawsuit not objectively baseless given damages and outcomes | Affirmed; claims failed as dependent on trade-secret ruling |
| Whether injunction was proper | Secrecy rights did not justify injunction to bar use of public information | Injunction narrowly tailored to protect trade secrets | Affirmed; injunction upheld as proper |
Key Cases Cited
- Amoco Prod. Co. v. Laird, 622 N.E.2d 912 (Ind. 1993) (value of compilations protected; not solely based on novelty)
- Lyn-Flex West, Inc. v. Dieckhaus, 24 S.W.3d 693 (Mo.Ct.App.1999) (compilations with secrecy can be trade secrets)
- Torma v. E. Elec. Co., 819 N.E.2d 417 (Ind.Ct.App.2004) (reasonable secrecy efforts; confidentiality legends relevant)
- Penalty Kick Mgmt. Ltd. v. Coca Cola Co., 318 F.3d 1284 (11th Cir.2003) (secret value even if public information exists; burden on secrecy)
- Kewanee Oil Co. v. Bicron Corp., 416 U.S. 470 (U.S. 1974) (policy justifications for trade secret protection; not requiring novelty)
- Wyeth v. Natural Biologics, Inc., 395 F.3d 897 (8th Cir.2005) (reliance on legends and confidentiality in secrecy analysis)
- Noerr Motor Freight, Inc. v. E.R.R. Presidents Conference, 365 U.S. 127 (U.S. 1961) (petitioning courts generally immune from antitrust liability; sham litigation test)
- Professional Real Estate Investors, Inc. v. Columbia Pictures Indus., Inc., 508 U.S. 49 (U.S. 1993) (Noerr Noerr–type analysis for sham litigation standard)
- Healthcare Servs. of the Ozarks, Inc. v. Copeland, 198 S.W.3d 604 (Mo.2006) (good faith enforcement of rights; justification for interference)