CAFC Says Design, Development Knowledge Not Sufficiently Defined in Alleged Self-Inflating Tire Trade Secrets

"[T]he few elements identified by Coda's expert witness as being contained within Goodyear's patents did not support testimony that Goodyear patented 'a perfect knock-off of [Coda's] technology.' Today, the U.S. Court of Appeals for the Federal Circuit issued a precedential ruling in Coda Development S.R.O. v. Goodyear Tire & Rubber Co. affirming the Northern District of Ohio's post-verdict grant of judgment as a matter of law (JMOL) to Goodyear on state trade secret and federal inventorship claims raised by Coda. The Federal Circuit ruled that Coda's trade secret claims were either not defined with sufficient particularity or were publicly disclosed in patent applications filed by Coda, leading the appellate court to dismiss the appellant's correction of inventorship claims as well."

"Coda sued Goodyear in Northern Ohio alleging that Goodyear's self-inflating tire (SIT) technology infringed upon a series of trade secrets, including the design and development of SIT pump and groove solutions, multipurpose interfaces for transporting air, and optimal locations for placing a self-inflating pump within a tire. Coda also included a claim for correcting the inventorship of U.S. Patent No. 8042586, Self-Inflating Tire Assembly."

The U.S. Court of Appeals for the Federal Circuit issued a precedential ruling affirming the Northern District of Ohio's post-verdict grant of judgment as a matter of law (JMOL) for Goodyear on Coda's state trade secret and federal inventorship claims. Coda alleged that Goodyear's self-inflating tire (SIT) technology misappropriated trade secrets related to pump and groove designs, multipurpose air interfaces, and optimal pump placement, and sought correction of inventorship for U.S. Patent No. 8042586. The district court overturned a jury award of $2.8 million compensatory and $61.2 million punitive damages. The Federal Circuit found the alleged trade secrets either insufficiently particularized or publicly disclosed in Coda's patent applications and dismissed the correction of inventorship claim, noting a belated attempt to add specificity failed on appeal.

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