Centurion Industries, Inc. v. Warren Steurer and Associates

Brief Fact Summary.

Centurion Industries, Inc. (plaintiff) sued Warren Steurer and Associates (defendant) and sought production of relevant evidence.

Synopsis of Rule of Law.

Trade Secrets are discoverable in limited situations where the harm of disclosure is outweighed by the necessity at trial, and there are limitations placed on production.

Facts.

Plaintiff invented a “teaching device” and had it manufactured and subsequently sued the defendant alleging patent infringement. The defendant was also a customer of the manufacturer of the teaching device, Cybernetic, who could not be brought into the lawsuit because there was no personal jurisdiction. The plaintiff requested documents from Cybernetic and Cybernetic argued the documents were not discoverable because they were trade secrets. The plaintiff moved to compel and the judge allowed production of the documents with limited access.

Issue.

Whether trade Secrets are discoverable in limited situations where the harm of disclosure is outweighed by the necessity at trial, and there are limitations placed on production.

Held.

Yes. Trade Secrets are discoverable in limited situations where the harm of disclosure is outweighed by the necessity at trial, and there are limitations placed on production.

Discussion.

The court did not err in allowing production of the trade secrets. Under Rule 26(c) of the Federal Rules of Civil Procedure, the defendant must show that if the trade secret is disclosed, the harm to the defendant will be great. If the defendant meets that burden, then the plaintiff must prove that the necessity of disclosing the info outweighs that harm. The court did not abuse their discretion in granting the motion to compel because the information was necessary. Experts testified the information was important to proving the plaintiff’s claims.