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Pioneer Hi-Bred International, Inc. v. Holden Foundation Seeds, Inc.

Citation. 1987 WL 341211 (S.D. Iowa 1987)
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Brief Fact Summary.

Pioneer Hi-Bred International (Pioneer) sued Holden Foundation Seeds, Inc. for using genetic information from Pioneer’s seed lines.

Synopsis of Rule of Law.

Genetic qualities constitute personal property.


Pioneer Hi-Bred International (Pioneer) created hybrid seed corn through genetic mixing. Pioneer sued Holden Foundation Seeds (Holden) for using genetic information from Pioneer’s seed lines.


Whether genetic qualities constitute personal property?


Yes. Pioneer wins over both the trade secret theory and conversion theory. Pioneer’s genetic mixing constitutes a trade theory and the burden shifts to Holden to prove that they lawfully acquired the genetic information. Holden failed to show that they lawfully acquired the genetic information, and evidence proves that Holden unlawfully used the genetic information obtained from Pioneer. Holding misappropriating the trade secret information constitutes conversion.


Misappropriating a trade secret and conversion are two ways to wrongfully acquire personal property. Trade secrets include any formula or information that gives a business an advantage over competitors.

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