On July 27, 2012 the Iowa Supreme Court published its opinion in Iowa Film Production Services et al. v. Iowa Department of Economic Development, No. 10-1719 (July 27, 2012). The Iowa Film opinion addresses several issues, including how Iowa courts define trade secrets. The Court explained that to qualify as a trade secret the matter must: (1) constitute information (a question of law); (2) hold independent economic value (a question of fact); and (3) be the subject of efforts that are reasonable under the circumstances to maintain secrecy (a question of fact). See Iowa Film, p. 21. With the foregoing in mind, the Iowa Supreme Court explained just how expansive the definition of a trade secret is:
There is virtually no category of information that cannot, as long as the information is protected from disclosure to the public, constitute a trade secret.
Business information may . . . fall within the definition of a trade secret, including such matters as maintenance of data on customer lists and needs, source of supplies, confidential costs, price data and figures. Trade secrets can range from customer information, to financial information, to information about manufacturing processes, to the composition of products.
Iowa Film, p. 22 (internal citations and quotations omitted).
The Iowa Film opinion contains additional analysis and information that readers may find helpful on the topic of Iowa Trade Secret law. To read more about trade secrets, click here. For further information on Iowa law regarding confidential business information and/or trade secrets, you should consider contacting a licensed attorney in your jurisdiction.
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