ClearValue, Inc. v. Pearl River Polymers, Inc.

(United States Federal Circuit) – In a suit involving claims of indirect patent infringement and misappropriation of a trade secret: 1) the district court’s denial of the defendant’s motions for judgment as a matter of law of invalidity and noninfringement is reversed, where the jury lacked substantial evidence to find that another patent did not anticipate the claim; and 2) the district court’s grant of judgment as a matter of law to the defendant on the plaintiff’s trade secret claim is affirmed, where another patent publicly disclosed the alleged secret before the plaintiff communicated it to the defendant, and thus the jury’s verdict of trade secret misappropriation was not supported by substantial evidence.