Julie Research Lab v. Select Photographic

Citation: Julie Research Labs., Inc. v. Select Photographic Eng'g, Inc., 998 F.2d 65 (2d Cir. 1993).

Factual Background
Plaintiff, Julie Research Laboratories, Inc. (JRL) instituted an action seeking an injunction and damages against Defendant, Select Photographic Engineering, Inc. (Select), and payment of a balance due from PLI Photo Lab, Inc. JRL also brought a claim for unjust enrichment against Jim Linford  for Linford's training on, and use of, a JRL Diamond system owned by JRL. JRL sought to have Select enjoined from marketing or selling an electronic photographic retouching imaging system known as "The Edge", claiming that it utilized technology substantially similar to that of the "JRL Diamond", thus infringing trade secrets of JRL. JRL also sought to enjoin Select, which had previously been a sales agent for JRL, from soliciting any of the sales leads that Select had generated in promoting the JRL Diamond.

District Court Decision
The district court dismissed JRL's claims against Select and found in JRL's favor against PLI for $37,910 plus interest. The court found that there was nothing unique or secret in the combination of twelve system design choices that JRL claimed constituted proprietary information. The court also rejected JRL's unjust enrichment claim.

Court of Appeals Decision
The court of appeals found no error in the district court's holding that JRL failed to establish that the combination of system design choices made by JRL in developing the JRL Diamond constitutes a trade secret. However, the court found that the district court erred in its calculation of damages against PLI. The district court's decision was vacated and remanded for recalculation of damages.