Digital Development v. International Memory Systems

Citation: ''Digital Dev. Corp. v. International Memory Sys.,'' 185 U.S.P.Q. (BNA) 136 (S.D. Cal. 1973).

Plaintiff claimed to have trade secrets in a disc memory. The court held that no express non-disclosure agreements are necessary where employee actually knows that the information is trade secret. The court also found that non-secret manufacturing conduct at the plant did not destroy trade secret elements of the product.