Federal Circuit Upholds Setting Aside Of Jury Verdict Where Trade Secrets Not Identified With Sufficient Particularity

The Federal Circuit recently confirmed the importance of properly identifying the trade secrets underlying a claim under the Ohio Uniform Trade Secrets Act ("OUTSA") [Ohio Rev. Code §§ 1333.61 et seq.], finding that the plaintiffs' failure to properly identify the trade secrets entitled the defendant to judgment as a matter of law notwithstanding a jury verdict in the plaintiffs' favor.

Coda Development s.r.o., Coda Innovations s.r.o., and Frantisek Hrabal (collectively, "Coda") sued Goodyear Tire & Rubber Company and Robert Benedict (collectively, "Goodyear") in the United States District Court for the Northern District of Ohio, asserting, in part, that Goodyear misappropriated Coda's trade secrets relating to the design and manufacture of self-inflating tires. Coda Dev. s.r.o. v. Goodyear Tire & Rubber Co., 160 F.4th 1350, 1352–54 (Fed. Cir. 2025). After a trial, the jury found that Goodyear had misappropriated five of Coda's alleged trade secrets related to the self-inflating tire technologies and awarded Coda $2.8 million in compensatory damages and $61.2 million in punitive damages.

Following trial, the district court granted Goodyear's motion for judgment as a matter of law under Federal Rule of Civil Procedure 50(b), finding in part that four of Code's claimed trade secrets were not identified with sufficient particularity. On appeal, the Federal Circuit affirmed the trial court's ruling, finding that Coda's descriptions of its trade secrets were "described in vague terms with no detail regarding how [their] functions [were] carried out" or were "articulated as no more than an undifferentiated list of components."

The Federal Circuit's decision in Coda highlights the importance of sufficiently defining an asserted trade secret, for example by identifying the knowledge that would enable one to develop a product where the trade secret at issue describes the functions or components of said product. Even if a jury finds that the plaintiff has met its burden of proof, a court remains free to conclude otherwise.