Sonrai Systems, LLC v. Anthony M. Romano
1:16-cv-03371
| N.D. Ill. | Jul 25, 2025Background
- Sonrai Systems, LLC sued former employee Anthony Romano and his new employer, Heil Co. d/b/a Environmental Solutions Group, alleging breach of fiduciary duty and related damages.
- The sole claim against Romano was for breach of fiduciary duty, tied to allegations he misappropriated proprietary data to help develop a competing product at Heil.
- At trial, Sonrai's damages case rested exclusively on a "lost profits" theory, arguing that Heil's Enhance product would not exist but for Romano's alleged misuse of Sonrai data.
- The jury had awarded nearly $29 million in compensatory damages based on this lost sales theory.
- Romano moved for judgment as a matter of law under Federal Rule 50(b), asserting insufficient evidence regarding the taking or use of proprietary data and defective legal theory of damages.
- As an alternative, Romano sought a new trial or remittitur under Rule 59.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of Evidence (Taking Proprietary Data) | Romano took proprietary Sonrai data before leaving | Sonrai failed to show what, if any, data was actually taken | Court held evidence insufficient |
| Sufficiency of Evidence (Use of Proprietary Data) | Data taken was improperly used to benefit Heil, diverting sales | No evidence Romano used specified data to compete | Court held evidence insufficient |
| Damages Theory (Lost Profits) | Romano's actions directly caused lost profits via Enhance sales | Lost profits theory unsupported since no evidence of causation or use | Court found damages theory insufficient |
| Duration of Fiduciary Duty | Fiduciary duty extended to completion of post-resignation work | Relationship ended Jan 15, 2016; later work was as a contractor | Court sided with defendant |
Key Cases Cited
- Beverly v. Abbott Labs., 107 F.4th 737 (7th Cir. 2024) (sets standard for granting judgment as a matter of law)
- Hossack v. Floor Covering Assocs. of Joliet, 492 F.3d 853 (7th Cir. 2007) (discusses when evidence is insufficient to support a jury verdict)
- Garrett v. Barnes, 961 F.2d 629 (7th Cir. 1992) (speculation alone cannot support a jury verdict)
- Perfetti v. First Nat’l Bank, 950 F.2d 449 (7th Cir. 1991) (vacating award where evidence was mostly insubstantial and indirect)
- Veco Corp. v. Babcock, 243 Ill. App. 3d 153 (Ill. App. Ct. 1993) (no breach where allegedly taken info was not shown to be confidential)
- Revcor, Inc. v. Fame, Inc., 85 Ill. App. 2d 350 (Ill. App. Ct. 1967) (employee may use general knowledge and skills post-employment)