Minuteman, Inc., Plaintiff-Appellant-Petitioner v. L.d. Alexander, George Cash, and Amity, Inc., Defendants-Respondents

Summary

The Wisconsin Supreme Court held that the Uniform Trade Secrets Act, sec. 134.90, Stats., now supplies Wisconsin's definition of 'trade secret,' displacing the six-factor Restatement test of Corroon & Black, though the Restatement factors remain helpful guidance. It held that improper acquisition alone constitutes misappropriation under sec. 134.90(2)(a) even without subsequent use, that the mere possibility of reverse engineering does not defeat a temporary injunction but bears on its duration, and that customer and inquiry lists may qualify as trade secrets, remanding those questions. It affirmed the denial of a temporary injunction on the computer data claim because the circuit court gave satisfactory reasons: no irreparable harm, an adequate legal remedy, and no reasonable probability of success. No separate writings were filed.