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April 2, 2002, 9:00 AM ET, Alert No. 401.
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7th Circuit Rules in Software Trade Secrets Case
4/1. The U.S. Court of Appeals (7thCir) issued its opinion in IDX v. Epic Systems, a trade secrets case involving software. The Appeals Court affirmed the District Court's summary judgment that IDX failed to identify with specificity the trade secrets that it accused the defendants of misappropriating. However, it reversed the District Court's ruling that a confidentiality agreement regarding the software was unenforceable.
Background. IDX Systems and Epic Systems both make software for use in managing the financial side of a medical practice. A major customer of IDX, the University of Wisconsin Medical Foundation (UWMF), which comprises more than 1,000 physicians, used IDX software until December 2000, when it switched to Epic software.
The UWMF had contracted with IDX that it would not allow the software and related materials furnished by IDX to be "examined ... for the purpose of creating another system". UWMF also contracted not to "use or disclose or divulge to others any data or information relating to" the system or "the technology, ideas, concepts, know- how, and techniques embodied therein."
District Court. IDX filed a complaint in U.S. District Court (WDWisc) against Epic, UWMF, and two employees of UWMF who had previously worked for Epic. IDX alleged that the UWMF and the two employees stole IDX's trade secrets, and broke contractual promises of confidentiality. IDX alleged that Epic tortiously induced UWMF and the two employees to do these things. Jurisdiction was based upon diversity of citizenship. The Court applied Wisconsin law.
In support of its misappropriation of trade secrets claims, IDX submitted to the District Court a 43 page description of the methods and processes underlying and the inter- relationships among various features making up IDX's software package.
The District Court dismissed the tort claims against Epic on the pleadings, observing that the Wisconsin trade secrets statute overrides any theory that conflicts with the state's law of trade secrets. It also ruled that the confidentiality agreements are invalid under Wisconsin law because they do not contain temporal and geographic limitations. Finally, the District Court granted summary judgment to the defendants on the trade secret claim, after concluding that IDX had failed to identify with specificity the trade secrets that it accused the defendants of misappropriating.
Wisconsin Trade Secrets Statute. The District and Appeals Court applied Wis. Stat. § 134.90(1)(c), which provides that "Trade secret" means "information, including a formula, pattern, compilation, program, device, method, technique or process to which all of the following apply: 1. The information 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. 2. The information is the subject of efforts to maintain its secrecy that are reasonable under the circumstances." See, Wisconsin Statutes, Chapter 134 [PDF].
Appeals Court: Trade Secrets. The Appeals Court affirmed the District Court's conclusion that IDX had failed to identify with specificity the allegedly misappropriated trade secrets. The Appeals Court wrote that "to show that particular information is a trade secret, a firm such as IDX must demonstrate that it is valuable, not known to others who might profit by its use, and has been handled by means reasonably designed to maintain secrecy. Like the district judge, we think that IDX failed to do this. It has been both too vague and too inclusive, effectively asserting that all information in or about its software is a trade secret."
The Court elaborated that IDX's 43 page submission "does not separate the trade secrets from the other information that goes into any software package. Which aspects are known to the trade, and which are not? That's vital under the statutory definition. Likewise, IDX's tender of the complete documentation for the software leaves mysterious exactly which pieces of information are the trade secrets."
The Court also commented on some of the items in IDX's 43 page submission. "Perhaps screen displays could be copyrighted, but no copyright claim has been advanced, and a trade secret claim based on readily observable material is a bust. ... Other details, such as the algorithms that the software uses to do real-time error checking (a vaunted feature of IDX's software), may be genuine trade secrets, but IDX has not tried to separate them from elements such as its input and output formats. Nor does it contend that the defendants decompiled the object code or otherwise obtained access to the algorithms that power the program; it alleges only that [UWMF] transferred to Epic those details that ordinary users of the software could observe without reverse engineering."
The Appeals Court also offered some advice for parties seeking to protect their software related intellectual property. First, it commented that "Reluctance to be specific is understandable; the more precise the claim, the more a party does to tip off a business rival to where the real secrets lie and where the rival's own development efforts should be focused. Still, tools such as protective orders are available to make this process less risky, and unless the plaintiff engages in a serious effort to pin down the secrets a court cannot do its job." Second, the Court wrote that since "it is hard to prove that particular information qualifies as a trade secret, many producers of intellectual property negotiate with their customers for additional protection."
Appeals Court: Confidentiality Agreements and Competition Analysis. The Appeals Court reversed the District Court's holding that the contractual promises are unenforceable because they are unlimited in temporal and geographic scope, and thus unduly restrain trade.
The Appeals Court wrote that the District Court relied, incorrectly, on precedent dealing with restrictive covenants limiting competition between employers and their ex-employees. It wrote that "Rules limiting the extent of no-compete clauses are based on the fact that they tie up human capital and, if widely adopted, may have the practical effect of preventing horizontal competition in economically significant markets. ... But neither rationale applies to contracts that restrict the use of particular information between businesses that have vertical (supplier- to- customer) rather than horizontal (competitor- to- competitor) relations."
The Appeals Court continued that "IDX did not contract for limitations on Epic's ability to compete; contracts between IDX and the [UWMF] are vertical in nature and protect intellectual property without affecting competition. They may compel rivals such as Epic to do more work to develop software independently, but this promotes rather than restricts competition."
The Appeals Court added that "trade secret law is compatible with antitrust law; the same can be said for contracts protecting intellectual property that, though not demonstrably a trade secret, is commercially valuable. Rivals such as Epic, as non-parties to the vertical arrangements, remain entitled to discover and use the information independently and to compete vigorously.
Notable and Quotable. Judge Frank Easterbrook, who wrote the opinion of the Appeals Court, concluded: "Nothing in the antitrust laws gives one producer a right to sponge off another's intellectual property".
EPIC to File FOIA Suit Against Office of Homeland Security
4/2. The Electronic Privacy Information Center (EPIC) announced that it will file a complaint today in U.S. District Court (DC) against the Office of Homeland Security alleging violation of the Freedom of Information Act (FOIA), 5 U.S.C. § 552. The EPIC seeks the expedited release of documents concerning a government national identification system.
The EPIC submitted a FOIA request to the OHS in March. The EPIC stated in a release that "News reports indicate that Governor Ridge, head of the Office of Homeland Security, has drafted legislation that would link state driver's license records to federal agency databases." EPIC Executive Director Marc Rotenberg stated that "the potential privacy implications of these proposals are far reaching. Under well established open record laws, Governor Ridge has an obligation to the American people to ensure that these decisions are made in the open."
The EPIC may face threshhold questions regarding whether the OHS is required to provide access to all or some of its records under the FOIA. The FOIA provides several statutory exemptions, one of which pertains to national defense. Section 552(b)(1) exempts matters that are "(A) specifically authorized under criteria established by an Executive order to be kept secret in the interest of national defense or foreign policy and (B) are in fact properly classified pursuant to such Executive order".
Also, while the FOIA provides that all federal agencies are covered, "including the Executive Office of the President" (see, 5 U.S.C. § 552(f)), this has been limited by court rulings. Many activities of the Executive Office of the President are not subject to the FOIA. The OHS is a part of the Executive Office of the President.
People and Appointments
4/1. The Hewlett Packard Board of Directors announced that it will not nominate Walter Hewlett to the Board. HP stated in a release that "The board's decision not to nominate Walter Hewlett is based on his ongoing adversarial relationship with the company, as evidenced by his recent litigation against HP, as well as concerns about his lack of candor and issues of trust."
4/1. Joanna McIntosh was named director of the Policy for a Networked Society (PNS) program at the Markle Foundation. She was previously vice president of International Affairs at AT&T. She represented AT&T in Washington DC and before the WTO and other multilateral, regional, and bilateral organizations, on international policy matters, including efforts to liberalize trade and foreign investment in international telecommunications networks and services. Markle stated in a release that the PNS program "works to promote international and domestic policy making processes that are open, transparent, and accountable to multiple stakeholders, including public, private and non-profit organizations as well as the public at large."
More News
4/1. The Department of Commerce's (DOC) National Telecommunications and Information Administration (NTIA) announced that it "has exercised the option to extend the term of the contract with ICANN for IANA functions for the six-month period of 04/01/2002 through 09/30/2002." See, Modification of Contract.
4/1. Qwest announced that "as a result of an accounting rule change, SFAS 142, it would potentially reduce the carrying value of goodwill by an estimated $20-$30 billion". See, Qwest release.
4/1. Xerox announced that "it has reached an agreement in principle with the Division of Enforcement of the Securities and Exchange Commission, the terms of which the Division has agreed to recommend to the Commission. The agreement in principle concerns the settlement of proposed allegations on matters that have been under investigation since June 2000. The proposed agreement is subject to the approval of the Commission." Xerox also stated that "The agreement in principle calls for a restatement of Xerox's financials for the years 1997 through 2000 as well as an adjustment of previously announced 2001 results" and that "the agreement in principle calls for the SEC to file a complaint and a consent order in federal district court for injunctive relief and a civil penalty of $10 million." However, "Xerox would neither admit nor deny the allegations of the complaint". See, Xerox release.
3/27. The U.S. District Court (NDCal) entered judgment against Interactive Products and Services, Inc. (IPS) and Matthew Bowin enjoining them from future fraudulent conduct and sales of unregistered securities. IPS is a computer accessories company based in Santa Cruz, California; Bowin is its CEO. The judgment also requires Bowin to pay $236,176 in disgorgement and interest and $110,000 in penalties. The Securities and Exchange Commission (SEC) alleged in its 1998 civil complaint that IPS and Bowin conducted a fraudulent offering of stock over the Internet. Bowin is currently serving a 10 year prison sentence on related state charges. See, SEC release.
4/1. The U.S. Court of Appeals (1stCir) issued its opinion in Cashmere v. Saks Fifth Avenue, a Lanham Act case. The Cashmere & Camel Hair Manufacturers Institute, a trade association of cashmere manufacturers dedicated to preserving the name and reputation of cashmere, and one of its members, filed a complaint in U.S. District Court (DMass) against Saks Fifth Avenue and others alleging the advertising of women's "cashmere" blazers that contained no cashmere, in violation of the Lanham Act, 15 U.S.C. § 1125(a), and Massachusetts state law. The District Court dismissed. The Appeals Court reversed.
Tuesday, April 2
The House and Senate are both in recess for the Spring District Work Period. Both bodies will return on Monday, April 8.
The Supreme Court of the U.S. is on recess until Monday, April 15.
10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in Netscape Communications v. Allen Konrad, No. 01-1455. Location: Courtroom 201, LaFayette Square, 717 Madison Place, NW.
1:00 PM ET. The Electronic Privacy Information Center (EPIC) will hold a press conference call regarding its lawsuit, to be filed on April 2, against the Office of Homeland Security under the Freedom of Information Act seeking the expedited release of documents regarding a government national identification system.
1:00 PM ET. The Federal Trade Commission (FTC) will hold a press conference to announce an international law enforcement initiative targeting deceptive spam and Internet fraud. See, FTC release. Location: the press conference will be held at the FTC office at 915 Second Ave., Suite 2896, Seattle, Washington. There will be a video link at the FTC headquarters, 600 Pennsylvania Ave., NW, Room 481.
2:00 PM. The Institute for Health Freedom will hold a press conference regarding medical privacy. For more information, contact Sue Blevins at 202 429-6610. Location: Lisagor Room, National Press Club, 529 14th St. NW, 13th Floor.
Wednesday, April 3
10:00 AM. A group of trade associations will hold a press conference to announce the formation of a group named the High Tech Broadband Coalition. The speakers will be Robert Holleyman (P/CEO of the Business Software Alliance), Gary Shapiro (P/CEO of the Consumer Electronics Association), Jerry Jasinowski (President of the National Association of Manufacturers), George Scalise (President of the Semiconductor Industry Association), and Matthew Flanigan (President of the Telecommunications Industry Association). For more information, contact Jeff Joseph (CEA) at 703 907-7664 or jjoseph@ce.org. Location: Lisagor Room, National Press Club, 529 14th St. NW, 13th Floor.
12:15 PM. The Federal Communications Bar Association's International Practice Committee will host a brown bag lunch. The speakers will be Tom Tycz (Chief of the FCC's International Bureau's Satellite Division), James Ball (Chief of the FCC's International Bureau's Policy Division), and Kathryn O'Brien (Chief of the FCC's International Bureau's Strategic Analysis and Negotiations Division). RSVP to Laurie Sherman at 202 223-7365 or Patricia Paoletta at 202 719-7532. Location: FCC, 445 12th Street, SW, Conference Room 6-B516.
Thursday, April 4
8:30 AM - 5:30 PM. Day one of a two day event hosted by the Department of Commerce's (DOC's) NTIA titled "Spectrum Summit". The summit will address spectrum allocation and efficiency, the spectrum requirements of new technologies, and regulatory processes. See, NTIA notice and notice in Federal Register, March 8, 2002, Vol. 67, No. 46, at Page 10682. Location: auditorium, Department of Commerce, 1401 Constitution Ave., NW.
2:00 - 4:00 PM. There will be a meeting of the FCC's Advisory Committee for the 2003 World Radiocommunication Conference. See, FCC notice [PDF], and notice in Federal Register, March 14, 2002, Vol. 67, No. 50, at Pages 11483. Location: FCC, Commission Meeting Room, Room TW-C305, 445 12th Street, SW.
4:00 PM. Dan Burk (Professor, University of Minnesota Law School) will give a lecture titled "Anti Circumvention Misuse". He will review the history of the equitable misuse doctrine in the context of patents and copyrights, and argue that the DMCA anti circumvention right is a new form of intellectual property that should be subject to the equitable misuse doctrine. For more information, contact Prof. Robert Brauneis at rbraun @main.nlc.gwu.edu or (202) 994-6138. Location: The George Washington University Law School 720 20th Street, NW.
Friday, April 5
8:30 AM - 4:15 PM. Day two of a two day event hosted by the Department of Commerce's (DOC's) NTIA titled "Spectrum Summit". The summit will address spectrum allocation and efficiency, the spectrum requirements of new technologies, and regulatory processes. See, NTIA notice and notice in Federal Register. Location: Ronald Reagan International Trade Center, 1300 Pennsylvania Ave., NW.
9:00 AM. The FCC's electronic filing systems will be shut down for maintenance purposes. This shut down will last through 1:00 PM on April 7. See, FCC notice.
9:30 AM. The U.S. Court of Appeals (DCCir) will hear oral argument in Global Naps Inc v. FCC, No. 01-1192. Judges Edwards, Roger and Tatel will preside. Location: 333 Constitution Ave. NW.
Extended deadline to submit comments to the Copyright Office in response to its Notice of Proposed Rulemaking on "the requirements for giving copyright owners reasonable notice of the use of their works for sound recordings under statutory license and for how records of such use shall be kept and made available to copyright owners." See, original notice in Federal Register, and extension notice in Federal Register.
Monday, April 8
The House and Senate return from the Spring District Work Period. The Senate is scheduled to meet at 3:00 PM.
9:30 AM. The U.S. Court of Appeals (DCCir) will hear oral argument in Morris Communications v. FCC, No. 01-1123. Judges Edwards, Tatel and Silberman will preside. Location: 333 Constitution Ave. NW.
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