nClosures Inc. v. Block & Co., Inc., No. 14-1097 (7th Cir. 2014)Annotate this Case
In 2011, nClosures and Block began a business relationship in which nClosures designed and Block manufactured metal enclosures for electronic tablets, such as iPads. The parties signed a confidentiality agreement; nClosures then divulged its designs for the enclosure device to Block for manufacture. The first device, the Rhino Elite, entered the market for sale in October 2011. By March 2012, however, Block developed its own competing device, the Atrio. nClosures sued, alleging breach of contract and breach of fiduciary duty. The district court granted summary judgment to Block on both claims, but denied Block attorney fees. The Seventh Circuit affirmed, agreeing that no reasonable jury could find that nClosures took reasonable steps to keep its proprietary information confidential, so that the confidentiality agreement was unenforceable and that no reasonable jury could find that a partnership existed between nClosures and Block that could give rise to a viable breach of fiduciary duty claim.