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Keywords

jurisdictioninjunctionappealhearingaffidavitwilltrade secretcorporation
injunctionhearingaffidavitwilltrade secret

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Williams v. Curtiss-Wright Corp., 681 F.2d 161, 216 U.S.P.Q. 108

Facts

Curtiss-Wright designed and manufactured the J-65 jet engine and its parts, possessing proprietary drawings and specifications. Williams obtained these specifications through alleged accidental disclosures and a FOIA request, subsequently entering competition with Curtiss-Wright. In 1979, Williams sued Curtiss-Wright for unlawful restraint of trade, while Curtiss-Wright counterclaimed for unfair competition and theft of trade secrets. The district court ordered Williams to produce documents related to the J-65 engine, which he complied with, leading to the court's decision to issue a preliminary injunction against him.

Curtiss-Wright designed, manufactures, and sells the J-65 jet engine, and also produces and sells replacement parts and accessories for that engine.

Issue

The main legal issues were whether the district court properly issued a preliminary injunction against Williams without a hearing and whether the court had jurisdiction to review the production order.

The primary challenge to the district court's injunctive order is procedural.

Rule

A preliminary injunction may be issued based on affidavits and written evidence without a hearing if the evidence does not leave unresolved any relevant factual issues. Additionally, the court must determine if the trade secrets in question can be reverse engineered.

It has long been recognized that a preliminary injunction may issue on the basis of affidavits and other written evidence, without a hearing, if the evidence submitted by both sides does not leave unresolved any relevant factual issue.

Analysis

The court found that the district court did not rely on any disputed facts when issuing the preliminary injunction. Evidence indicated that the drawings could not be reverse engineered, supporting the conclusion that they constituted trade secrets. Williams' claims regarding the means of obtaining the drawings did not affect the legality of their use, as he was aware that the drawings were secret when he acquired them.

We conclude that the court relied on no such disputed facts.

Conclusion

The Court of Appeals affirmed the district court's preliminary injunction against Williams, concluding that the injunction was properly issued based on the evidence presented. The appeal regarding the production order was dismissed for lack of jurisdiction.

The order of the district court granting a preliminary injunction against Williams will be affirmed.

Who won?

Curtiss-Wright Corporation prevailed in the case because the court found that the evidence supported the conclusion that the specifications constituted trade secrets and that Williams had unlawfully obtained and used them.

Curtiss-Wright contends that the specifications constituted trade secrets under applicable New Jersey law, and that their use by Williams was unlawful.

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