INDAG GmbH & CO. BETREIBS KG v. IMA SPA
Summary
This case involves allegations of patent infringement and trade secret misappropriation between a former employee, the employer, and the new employer. Plaintiffs, INDAG GmbH & Co. Betreibs KG and Wild Parma S.r.L, allege that defendants infringed U.S. Patent No. 7,648,017 and violated the Illinois Trade Secrets Act by offering for sale pouch filling machinery in the United States derived from plaintiffs' confidential and proprietary information. The court granted defendants' motion to dismiss for lack of personal jurisdiction over non-resident defendants and failure to state a claim for patent infringement. Plaintiffs' request for jurisdictional discovery was denied.
Decision
The court granted defendants' motion to dismiss and denied plaintiffs' request for jurisdictional discovery.
Legal Significance
The decision highlighted the limitations on asserting general jurisdiction over non- resident defendants and emphasized the requirements for establishing a claim for patent infringement and trade secret misappropriation under Illinois law.
Financial Judgement
Not given
Key Takeaways
The key takeaways include the importance of establishing proper jurisdiction in patent infringement and trade secret cases, and the challenges in proving misappropriation of trade secrets and patent infringement claims when key defendants are non-resident entities.
